AUMdb

Goldman Sachs & Co. Llc

SEC-registered Broker-Dealer (Dually Registered) · Mega ($100B+) CRD 361 · SEC file 801-16048 · New York, NY · privatewealth.goldmansachs.com
☆ Save with Pro ADV data as of Jul 27, 2026
Regulatory AUM
$134B
Discretionary
$133B
Clients
46,268
Avg AUM / client
$2.9M
Accounts
46,269
Employees
2,268

AUM over time

$115B $234B
Dec 2011 Jul 2026

Annual snapshots from Form ADV filings · as of Jul 27, 2026

Who they serve

Client typeClientsAUM% of AUM
High net worth individuals 29,104 $51.0B 38.1%
Pension and profit sharing plans 9 $4.7M 0.0%
Charitable organizations 1,040 $17.5B 13.1%
State or municipal government entities 1 $5.8M 0.0%
Insurance companies 28 $289M 0.22%
Corporations and other businesses 506 $16.9B 12.7%
Other 15,580 $47.9B 35.9%

Private funds (171)

View all →

Reported in Form ADV Section 7.B.(1), filing of Nov 2024 · $62.3B combined gross assets

FundTypeDomicileGross assetsOwners
West Street Capital Partners Viii Offshore, L.P. Private Equity Fund Cayman Islands $4.6B 256
West Street Capital Partners Viii, L.P. Private Equity Fund Delaware $3.3B 1,280
West Street Capital Partners Vii, L.P. Private Equity Fund Delaware $3.1B 1,122
West Street Capital Partners Vii Offshore, L.P. Private Equity Fund Cayman Islands $2.8B 300
West Street Offshore Infrastructure Partners Iv, L.P. Private Equity Fund Cayman Islands $2.3B 92
West Street Global Growth Partners Offshore, L.P. Private Equity Fund Cayman Islands $2.1B 272
West Street Capital Partners Co Invest A, Slp Private Equity Fund Luxembourg $2.0B 584
West Street Global Growth Partners L.P. Private Equity Fund Delaware $1.9B 891
West Street Capital Partners Viii Europe, Slp Private Equity Fund Luxembourg $1.7B 518
Wsip Iii Connect Infrastructure Holding 1 Limited Private Equity Fund United Kingdom $1.5B 11
West Street Real Estate Credit Partners Iv, L.P. Hedge Fund Delaware $1.5B 318
West Street Capital Partners Vii Europe, Slp Private Equity Fund Luxembourg $1.2B 386
China U.S. Industrial Cooperation Partnership, L.P. Private Equity Fund Delaware $1.2B 652
West Street European Infrastructure Partners Iii, L.P. Private Equity Fund United Kingdom $1.0B 39
West Street Real Estate Partners (G) Feeder, L.P. Real Estate Fund Cayman Islands $1.0B 3

Nonprofit clients

Charities that reported this firm as a top-paid contractor (investment services) on Form 990.

Charity Location Period
Camphill Village Copake Foundationinc EIN 204565002 Copake, NY 03/31/2025
Old Globe Endowment Trust EIN 336125358 San Diego, CA 12/31/2024
Friends Of Acadia EIN 010425071 Bar Harbor, ME 12/31/2024
The Cullen Trust For Health Care EIN 742001755 Houston, TX 12/31/2024
The Kline Galland Center EIN 911154904 Seattle, WA 12/31/2024
Dte Energy Company Veba Tr EIN 200471790 Detroit, MI 12/31/2024
Lutheran Cemetery EIN 116012575 Middle Vlg, NY 12/31/2024
P E F Israel Endowment Funds Inc EIN 136104086 New York, NY 11/30/2024
Shannon West Texas Memorial Hospital EIN 750800679 San Angelo, TX 09/30/2024
North Harris Montgomery Community College District Foundation EIN 760336902 The Woodlands, TX 08/31/2024
Diocese Of Rockville Centre Catholic Cemetery Perm Maint Trust EIN 821821173 Westbury, NY 08/31/2024
Kinkaid School Endowment Fund Inc EIN 760460841 Houston, TX 07/31/2024
Montclair State University Foundation Inc EIN 226017209 Montclair, NJ 06/30/2024
Queenscare EIN 951644040 Los Angeles, CA 06/30/2024
Interlochen Center For The Arts EIN 381689022 Interlochen, MI 05/31/2024
Siena University EIN 141338498 Loudonville, NY 05/31/2024

Retirement plan clients

Plans that reported this firm as an investment service provider on Form 5500 Schedule C.

Plan Location Plan year
Lorain County Community Action Agency 403(b) Thrif Lorain County Community Action Agency Lorain, OH 2024
Southern California Floor Covering Pension Trust Fund Board Of Trustees, Southern California Floor Covering 2024
Genpact U. S. 401(k) Savings Plan Genpact, Llc 2024
The Albany Medical Center Retirement Plan Albany Med Health System 2024
Ridgeline, Inc. 401(k) Plan Ridgeline, Inc. 2024
Farmers Group, Inc. 401(k) Savings Plan Farmers Group, Inc. 2024
Foster Farms Group Pension Plan Foster Poultry Farms 2024
Th2 Connect Llc 401(k) Retirement Plan Th2 Connect Llc 2024
J.F. Edwards Construction Co. 401(k) P/S Plan J.F. Edwards Construction 2024
The Timken Latrobe Mpb Torrington Retirement Plan The Timken Company 2024
Stanley Black & Decker Pension Plan Black & Decker (U.S.) Inc. 2024
Pension Plan For Hourly Paid Employees Of Stanley Black & Decker, Inc. Stanley Black & Decker, Inc. 2024
The Gates Matchmaker Plan Gates Corporation 2024
Iuoe Stationary Engineers Local 39 Pension Plan Bot Of Iuoe Stationary Engineers Local 39 Pension Plan 2024
Windstream Pension Plan Windstream Services, Llc Little Rock, AR 2024
Williams International Pension Plan For Employees Williams International Co., Llc 2024

People (10)

NameRole / titleCredentialsWith firm sinceOwnership
Solomon, David Michael Managing Director, Manager Apr 2017 (9y) Less than 5%
Matthias, Thomas Fairbanks Chief Compliance Officer Sep 2017 (9y) Less than 5%
Broadbery, Michael Mary Chief Compliance Officer Nov 2018 (8y) Less than 5%
Waldron, John Edward Managing Director, Ceo, Manager Dec 2018 (8y) Less than 5%
Doyle, Brian Richard Managing Director, Cfo Nov 2019 (7y) Less than 5%
Ruemmler, Kathryn Helen Managing Director, Clo, Manager Mar 2021 (5y) Less than 5%
Coleman, Denis Patrick Iii Managing Director, Manager Jan 2022 (5y) Less than 5%
Hempsell, Richard Ian Managing Director, Principal Operations Officer Feb 2022 (5y) Less than 5%
Mccaskill, Mark Managing Director, Principal Operations Officer Jun 2022 (4y) Less than 5%
Greeff, Brian Michael Co Principal Operations Officer Sep 2023 (3y) Less than 5%

Entity owners (Schedule A/B)

EntityTitle / statusSinceSch.Ownership
The Goldman Sachs Group, Inc. Class A Member Apr 2017 A 75% or more

Undisclosed: 0% – 25% of the firm is not attributable from the filed Schedule A bands.

Roster from the IAPD representatives feed; ownership and acquisition dates from Form ADV Schedule A/B. "Since" is the earliest filed registration or acquisition date.

Private funds (171, $62.3B gross assets)

FundTypeGross assetsMin. investmentOwners
West Street Capital Partners Viii Offshore, L.P. Private Equity Fund $4.6B $5.0M 256
West Street Capital Partners Viii, L.P. Private Equity Fund $3.3B $5.0M 1,280
West Street Capital Partners Vii, L.P. Private Equity Fund $3.1B $5.0M 1,122
West Street Capital Partners Vii Offshore, L.P. Private Equity Fund $2.8B $5.0M 300
West Street Offshore Infrastructure Partners Iv, L.P. Private Equity Fund $2.3B $10.0M 92
West Street Global Growth Partners Offshore, L.P. Private Equity Fund $2.1B $5.0M 272
West Street Capital Partners Co Invest A, Slp Private Equity Fund $2.0B $0 584
West Street Global Growth Partners L.P. Private Equity Fund $1.9B $5.0M 891
West Street Capital Partners Viii Europe, Slp Private Equity Fund $1.7B $5.0M 518
Wsip Iii Connect Infrastructure Holding 1 Limited Private Equity Fund $1.5B $4.1M 11
West Street Real Estate Credit Partners Iv, L.P. Hedge Fund $1.5B $0 318
West Street Capital Partners Vii Europe, Slp Private Equity Fund $1.2B $5.0M 386
China U.S. Industrial Cooperation Partnership, L.P. Private Equity Fund $1.2B $5.0M 652
West Street European Infrastructure Partners Iii, L.P. Private Equity Fund $1.0B $10.0M 39
West Street Real Estate Partners (G) Feeder, L.P. Real Estate Fund $1.0B $0 3
Volta Investments, Slp Private Equity Fund $960M $1.0M 1,365
B&B Investors Offshore, Slp Private Equity Fund $879M $1.0M 148
Horizon Energy Storage, L.P. Private Equity Fund $785M $1.0M 315
Horizon Environment & Climate Solutions Partners I Offshore, L.P. Private Equity Fund $758M $0 106
West Street Global Infrastructure Partners Iv, L.P. Private Equity Fund $743M $0 73
Wsip Iii Coyote Holdco S.A R.L. Private Equity Fund $735M $0 5
China U.S. Industrial Cooperation Offshore Partnership, L.P. Private Equity Fund $735M $5.0M 84
China U.S. Industrial Cooperation European Partnership, Slp Private Equity Fund $711M $5.0M 95
Palace Co Invest, Slp Private Equity Fund $688M $0 13
West Street International Infrastructure Partners Iii, L.P. Private Equity Fund $657M $10.0M 19

Top 25 of 171 funds by gross assets · all funds

From Form ADV Section 7.B private fund reporting.

Retirement plans served (16)

PlanSponsorParticipantsPlan assetsAs of
Lorain County Community Action Agency 403(b) Thrif Lorain County Community Action Agency 301 $4.0M 08/01/2024
Southern California Floor Covering Pension Trust Fund Board Of Trustees, Southern California Floor Covering 609 $109M 01/01/2024
Genpact U. S. 401(k) Savings Plan Genpact, Llc 5,783 $602M 01/01/2024
The Albany Medical Center Retirement Plan Albany Med Health System 7,970 $290M 01/01/2024
Ridgeline, Inc. 401(k) Plan Ridgeline, Inc. 447 $19.0M 01/01/2024
Farmers Group, Inc. 401(k) Savings Plan Farmers Group, Inc. 17,891 $5.0B 01/01/2024
Foster Farms Group Pension Plan Foster Poultry Farms 2,026 $382M 01/01/2024
Th2 Connect Llc 401(k) Retirement Plan Th2 Connect Llc 45 $5.8M 01/01/2024
J.F. Edwards Construction Co. 401(k) P/S Plan J.F. Edwards Construction 134 $15.6M 01/01/2024
The Timken Latrobe Mpb Torrington Retirement Plan The Timken Company 898 $154M 01/01/2024
Stanley Black & Decker Pension Plan Black & Decker (U.S.) Inc. 721 $718M 01/01/2024
Pension Plan For Hourly Paid Employees Of Stanley Black & Decker, Inc. Stanley Black & Decker, Inc. 488 $112M 01/01/2024
The Gates Matchmaker Plan Gates Corporation 3,341 $696M 01/01/2024
Iuoe Stationary Engineers Local 39 Pension Plan Bot Of Iuoe Stationary Engineers Local 39 Pension Plan 4,997 $2.0B 01/01/2024
Windstream Pension Plan Windstream Services, Llc 1,298 $438M 01/01/2024
Williams International Pension Plan For Employees Williams International Co., Llc 151 $77.8M 01/01/2024

From Form 5500 service-provider disclosures.

Foundations & charities (16)

OrganizationTypeAssetsAs of
Camphill Village Copake Foundationinc Public charity $84.0M 03/31/2025
Old Globe Endowment Trust Public charity $60.4M 12/31/2024
Friends Of Acadia Public charity $97.3M 12/31/2024
The Cullen Trust For Health Care Public charity $126M 12/31/2024
The Kline Galland Center Public charity $74.7M 12/31/2024
Dte Energy Company Veba Tr Public charity $1.3B 12/31/2024
Lutheran Cemetery Public charity $46.4M 12/31/2024
P E F Israel Endowment Funds Inc Public charity $209M 11/30/2024
Shannon West Texas Memorial Hospital Public charity $631M 09/30/2024
North Harris Montgomery Community College District Foundation Public charity $45.5M 08/31/2024
Diocese Of Rockville Centre Catholic Cemetery Perm Maint Trust Public charity $102M 08/31/2024
Kinkaid School Endowment Fund Inc Public charity $150M 07/31/2024
Montclair State University Foundation Inc Public charity $136M 06/30/2024
Queenscare Public charity $496M 06/30/2024
Interlochen Center For The Arts Public charity $323M 05/31/2024
Siena University Public charity $380M 05/31/2024

From IRS Form 990 investment-management-fee disclosures.

Documents (1 archived)

FormPeriodSize
Form ADV (full filing) 06/30/2026 52.6 MB View · PDF · Source ↗

Archived copies of the firm's regulatory filings, versioned by content hash.

Disciplinary disclosures

Criminal as of Nov 19, 2024

Event Detail: ON AUGUST 26, 2010, MTGLQ ENTERED A PLEA OF "NO CONTEST" TO A MISDEMEANOR VIOLATION OF SECTION 367.12(C) OF THE CITY OF CLEVELAND, OHIO CODIFIED ORDINANCES IN FOUR CASES FILED IN CLEVELAND MUNICIPAL COURT. THE CLEVELAND ORDINANCE REQUIRES A SELLER OF REAL PROPERTY TO FURNISH TO THE PURCHASER A CERTIFICATE OF DISCLOSURE ADDRESSING THE CONDITION OF THE PROPERTY BEFORE ENTERING INTO A CONTRACT FOR SALE; EACH VIOLATION OF THE ORDINANCE CARRIES A MAXIMUM FINE OF $5,000. RATHER THAN IMPOSE THE MAXIMUM FINE, THE CLEVELAND MUNICIPAL COURT REDUCED THE TOTAL FINE TO A SUM OF $2,500 PER VIOLATION, OR $10,000 IN TOTAL. Status: Final Disposition: ON AUGUST 26, 2010, MTGLQ ENTERED A PLEA OF "NO CONTEST" TO A MISDEMEANOR VIOLATION OF SECTION 367.12(C) OF THE CITY OF CLEVELAND, OHIO CODIFIED ORDINANCES IN FOUR CASES FILED IN CLEVELAND MUNICIPAL COURT. RATHER THAN IMPOSE THE MAXIMUM FINE, THE CLEVELAND MUNICIPAL COURT REDUCED THE TOTAL FINE TO A SUM OF $2,500 PER VIOLATION, OR $10,000 IN TOTAL, TO BE PAID BY OCTOBER 1, 2010. Summary: ON AUGUST 26, 2010, MTGLQ ENTERED A PLEA OF "NO CONTEST" TO A MISDEMEANOR VIOLATION OF SECTION 367.12(C) OF THE CITY OF CLEVELAND, OHIO CODIFIED ORDINANCES IN FOUR CASES FILED IN CLEVELAND MUNICIPAL COURT. THE CLEVELAND ORDINANCE REQUIRES A SELLER OF REAL PROPERTY TO FURNISH TO THE PURCHASER A CERTIFICATE OF DISCLOSURE ADDRESSING THE CONDITION OF THE PROPERTY BEFORE ENTERING INTO A CONTRACT FOR SALE; EACH VIOLATION OF THE ORDINANCE CARRIES A MAXIMUM FINE OF $5,000. RATHER THAN IMPOSE THE MAXIMUM FINE, THE CLEVELAND MUNICIPAL COURT REDUCED THE TOTAL FINE TO A SUM OF $2,500 PER VIOLATION, OR $10,000 IN TOTAL. NOTE: FAILURE TO PROVIDE THE CERTIFICATE OF DISCLOSURE REQUIRED BY THE CLEVELAND ORDINANCE WAS DUE TO A MISUNDERSTANDING OF THE REQUIREMENT AS APPLIED TO PARTICULAR TRANSACTIONS.

Civil judicial as of Nov 19, 2024

Allegations: ON OCTOBER 20, 2010, THE LOS ANGELES CITY ATTORNEY'S OFFICE FILED A CIVIL ACTION IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES, CENTRAL DISTRICT, AGAINST THE GOLDMAN SACHS GROUP, INC. ("GS GROUP"), A CONTROL AFFILIATE OF THE APPLICANT, AND HEALTHMARKETS, INC. ("HEALTHMARKETS"), AMONG OTHERS. THE COMPLAINT IS GENERALLY DIRECTED AT ALLEGED PRACTICES BY HEALTHMARKETS AND VARIOUS OF ITS AFFILIATES IN CONNECTION WITH STRUCTURING AND MARKETING INSURANCE PRODUCTS, BUT ALSO NAMES GS GROUP AND BLACKSTONE GROUP L.P. AS THE ALLEGED OWNERS AND "ALTER EGOS" OF HEALTHMARKETS. CERTAIN AFFILIATES OF GS GROUP OWN A MINORITY INTEREST IN HEALTHMARKETS. THE COMPLAINT ALLEGES VIOLATIONS OF CALIFORNIA'S UNFAIR COMPETITION LAW AND FALSE ADVERTISING LAW, AND SEEKS EQUITABLE RELIEF AND CIVIL PENALTIES. PEOPLE OF THE STATE OF CALIFORNIA V. HEALTHMARKETS, INC, ET. AL., BC447836 (SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES, CENTRAL DISTRICT, FILED OCT. 20, 2010). Status: Pending Summary: GS GROUP FILED A DEMURRER TO THE COMPLAINT ON JUNE 27, 2011. ON AUGUST 19, 2011, ALTHOUGH THE COURT SUSTAINED GS GROUP'S DEMURRER, IT GRANTED LEAVE TO AMEND AND PERMITTED THE PLAINTIFFS TO PROPOUND LIMITED DISCOVERY OF HEALTHMARKETS RELATING TO GS GROUP'S INVESTMENT IN HEALTHMARKETS. ON FEBRUARY 29, 2012, AFTER THE CONCLUSION OF SUCH DISCOVERY, PLAINTIFF FILED AN AMENDED COMPLAINT THAT DID NOT ASSERT ANY CLAIMS AGAINST GS GROUP. PLEASE REMOVE THIS DRP.

Civil judicial as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO") AND OTHER UNDERWRITERS OF RESIDENTIAL MORTGAGE-BACKED SECURITIES ("RMBS") WERE NAMED IN A COMPLAINT IN INTERVENTION FILED BY THE STATE OF NEW MEXICO ON AUGUST 31, 2020 AND MOVED TO UNSEAL A QUI TAM ACTION INITIALLY FILED BY INTEGRA REC, LLC. THE COMPLAINT IN INTERVENTION ASSERTED VIOLATIONS OF THE NEW MEXICO FRAUD AGAINST TAXPAYERS ACT, THE NEW MEXICO SECURITIES ACT, AND THE COMMON LAW OF NEW MEXICO BASED ON ALLEGATIONS THE DEFENDANTS MISREPRESENTED THE NATURE, QUALITY, CHARACTERISTICS, AND RISK PROFILE OF RESIDENTIAL MORTGAGE POOLS BACKING RMBS. Status: Final Summary: THE STATE OF NEW MEXICO AND THE DEFENDANTS, INCLUDING GSCO, ENTERED INTO A SETTLEMENT AGREEMENT FOR THE TOTAL AMOUNT OF $32,500,000 ON NOVEMBER 19, 2021, IN WHICH THE DEFENDANTS SETTLED ALL CLAIMS WITHOUT ANY ADMISSION OF LIABILITY OR WRONGDOING. THE COURT ENTERED A STIPULATION OF DISMISSAL ON NOVEMBER 30, 2021, PURSUANT TO WHICH, GSCO WAS DISMISSED WITH PREJUDICE.

Civil judicial as of Nov 19, 2024

Allegations: ON APRIL 28, 2003, THE SEC FILED COMPLAINTS AGAINST TEN INVESTMENT BANKING FIRMS AS PART OF A GLOBAL SETTLEMENT RELATING TO EQUITY RESEARCH ANALYST CONFLICTS OF INTERESTS. THE COMPLAINT AGAINST GOLDMAN SACHS ALLEGES THAT THE FIRM VIOLATED (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY ENGAGING IN ACTS AND PRACTICES DURING THE PERIOD JULY 1, 1999 THROUGH JUNE 30, 2001 THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY ISSUING IN CERTAIN INSTANCES RESEARCH REPORTS FOR COMPANIES THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS, CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS ABOUT THESE COMPANIES, AND/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES OVER RESEARCH ANALYSTS TO PREVENT OR MANAGE CONFLICTS OF INTEREST. Status: Final Summary: THE COURT ENTERED THE FINAL JUDGMENT ON OCTOBER 31, 2003, WHICH PERMANENTLY ENJOINS GOLDMAN SACHS, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM FROM VIOLATING THE NYSE AND NASD RULES IN THE MANNER DESCRIBED IN THE COMPLAINT (SEE RESPONSE 7 ABOVE). THE FINAL JUDGMENT ALSO ORDERS GOLDMAN SACHS TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 13.C. GOLDMAN SACHS NEITHER ADMITTED NOR DENIED LIABILITY AS PART OF THE FINAL JUDGMENT. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF “HOT” IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Civil judicial as of Nov 19, 2024

Allegations: ON APRIL 28, 2003, AS PART OF A GLOBAL SETTLEMENT, THE SEC FILED A COMPLAINT AGAINST TEN INVESTMENT BANKING FIRMS, INCLUDING GS ALLEGING THAT THEY VIOLATED (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY PERMITTING INVESTMENT BANKING TO EXERCISE INAPPROPRIATE INFLUENCE OVER RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY ISSUING RESEARCH REPORTS THAT CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO PREVENT OR MANAGE CONFLICTS OF INTEREST ADEQUATELY. Status: Final Summary: THE COURT ENTERED THE FINAL JUDGMENT ON OCTOBER 31, 2003, WHICH PERMANENTLY ENJOINS GOLDMAN SACHS, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM FROM VIOLATING THE NYSE AND NASD RULES IN THE MANNER DESCRIBED IN THE COMPLAINT (SEE RESPONSE 7 ABOVE). THE FINAL JUDGMENT ALSO ORDERS GOLDMAN SACHS TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 13.C. GOLDMAN SACHS NEITHER ADMITTED NOR DENIED LIABILITY AS PART OF THE FINAL JUDGMENT. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF "HOT" IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Civil judicial as of Nov 19, 2024

Allegations: THE CONDUCT OF THE APPLICANT ALLEGED IN THE SEC COMPLAINT INVOLVED AN OFFERING OF A SYNTHETIC COLLATERALIZED DEBT OBLIGATION, WHICH REFERENCED A PORTFOLIO OF SYNTHETIC RESIDENTIAL MORTGAGE-BACKED SECURITIES, TO QUALIFIED INSTITUTIONAL BUYERS IN RELIANCE ON THE EXEMPTION FROM REGISTRATION UNDER THE SECURITIES ACT OF 1933 PROVIDED BY RULE 144A THEREUNDER AND TO NON-U.S. PERSONS IN RELIANCE ON THE SAFE HARBOR FROM REGISTRATION PROVIDED BY REGULATION S THEREUNDER. SPECIFICALLY, THE COMPLAINT ALLEGED THAT THE OFFERING MATERIALS, IN DESCRIBING THE PORTFOLIO SELECTION AGENT FOR THE PORTFOLIO OF SYNTHETIC RESIDENTIAL MORTGAGE-BACKED SECURITIES, SHOULD HAVE DISCLOSED THAT THE HEDGE FUND ASSUMING THE SHORT SIDE OF THE TRANSACTION HAD PLAYED A ROLE IN THE SELECTION PROCESS. IN ITS CONSENT TO THE COURT JUDGMENT, THE APPLICANT ACKNOWLEDGED THAT IT WAS A MISTAKE NOT TO DISCLOSE THE ROLE OF THE HEDGE FUND. Status: Final Summary: THE COURT'S JUDGMENT WAS ENTERED AS A RESULT OF A SETTLEMENT BETWEEN THE APPLICANT AND THE SEC IN CONNECTION WITH AN ACTION BROUGHT AGAINST THE APPLICANT AND AN INDIVIDUAL DEFENDANT. THE ALLEGED CONDUCT OF THE APPLICANT IS DESCRIBED IN THE RESPONSE TO ITEM 7.

Civil judicial as of Nov 19, 2024

Allegations: ON APRIL 28, 2003, AS PART OF A GLOBAL SETTLEMENT, THE SEC FILED A COMPLAINT AGAINST TEN INVESTMENT BANKING FIRMS, INCLUDING GS ALLEGING THAT THEY VIOLATED (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY PERMITTING INVESTMENT BANKING TO EXERCISE INAPPROPRIATE INFLUENCE OVER RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY ISSUING RESEARCH REPORTS THAT CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO PREVENT OR MANAGE CONFLICTS OF INTEREST ADEQUATELY. Status: Final Summary: THE COURT ENTERED THE FINAL JUDGMENT ON OCTOBER 31, 2003, WHICH PERMANENTLY ENJOINS GOLDMAN SACHS, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM FROM VIOLATING THE NYSE AND NASD RULES IN THE MANNER DESCRIBED IN THE COMPLAINT (SEE RESPONSE 7 ABOVE). THE FINAL JUDGMENT ALSO ORDERS GOLDMAN SACHS TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 13.C. GOLDMAN SACHS NEITHER ADMITTED NOR DENIED LIABILITY AS PART OF THE FINAL JUDGMENT. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF “HOT” IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Civil judicial as of Nov 19, 2024

Allegations: ON APRIL 28, 2003, AS PART OF A GLOBAL SETTLEMENT, THE SEC FILED A COMPLAINT AGAINST TEN INVESTMENT BANKING FIRMS, INCLUDING GS ALLEGING THAT THEY VIOLATED (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY PERMITTING INVESTMENT BANKING TO EXERCISE INAPPROPRIATE INFLUENCE OVER RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY ISSUING RESEARCH REPORTS THAT CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO PREVENT OR MANAGE CONFLICTS OF INTEREST ADEQUATELY. Status: Final Summary: THE COURT ENTERED THE FINAL JUDGMENT ON OCTOBER 31, 2003, WHICH PERMANENTLY ENJOINS GOLDMAN SACHS, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM FROM VIOLATING THE NYSE AND NASD RULES IN THE MANNER DESCRIBED IN THE COMPLAINT (SEE RESPONSE 7 ABOVE). THE FINAL JUDGMENT ALSO ORDERS GOLDMAN SACHS TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 13.C. GOLDMAN SACHS NEITHER ADMITTED NOR DENIED LIABILITY AS PART OF THE FINAL JUDGMENT. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF "HOT" IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Civil judicial as of Nov 19, 2024

Allegations: ON APRIL 28, 2003, AS PART OF A GLOBAL SETTLEMENT, THE SEC FILED A COMPLAINT AGAINST TEN INVESTMENT BANKING FIRMS, INCLUDING GS ALLEGING THAT THEY VIOLATED (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY PERMITTING INVESTMENT BANKING TO EXERCISE INAPPROPRIATE INFLUENCE OVER RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY ISSUING RESEARCH REPORTS THAT CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO PREVENT OR MANAGE CONFLICTS OF INTEREST ADEQUATELY. Status: Final Summary: THE COURT ENTERED THE FINAL JUDGMENT ON OCTOBER 31, 2003, WHICH PERMANENTLY ENJOINS GOLDMAN SACHS, ITS OFFICERS, AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS AND ALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM FROM VIOLATING THE NYSE AND NASD RULES IN THE MANNER DESCRIBED IN THE COMPLAINT (SEE RESPONSE 7 ABOVE). THE FINAL JUDGMENT ALSO ORDERS GOLDMAN SACHS TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 13.C. GOLDMAN SACHS NEITHER ADMITTED NOR DENIED LIABILITY AS PART OF THE FINAL JUDGMENT. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF “HOT” IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Civil judicial as of Nov 19, 2024

Allegations: THE SEC ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED RULE 101 OF REGULATION M UNDER THE SECURITIES ACT OF 1934 BY ATTEMPTING TO INDUCE, OR INDUCING CERTAIN INVESTORS TO MAKE AFTERMARKET PURCHASES OF CERTAIN INITIAL PUBLIC OFFERINGS ("IPOS") UNDERWRITTEN BY GS, DURING 2000. Status: Final Summary: ON SEPTEMBER 23, 2004, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, GS CONSENTED TO THE ENTRY OF THE FINAL JUDGMENT. THE FINAL JUDGMENT WAS ENTERED FEBRUARY 4, 2005. GS WAS PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING RULE 101 OF REGULATION M AND REQUIRED TO PAY A $40 MILLION CIVIL PENALTY.

Regulatory as of Nov 19, 2024

Allegations: MATTER WAS FINALIZED WITH A WARNING LETTER AND IS NO LONGER REPORTABLE. PLEASE MOVE DRP TO ARCHIVE. ON FEBRUARY 23, 2022, ICE CLEAR CREDIT LLC ("ICE") ALLEGED THAT A GOLDMAN SACHS & CO. LLC ("GSCO") MARGIN CALL PAYMENT WAS RECEIVED NINE MINUTES AFTER THE REQUIRED DEADLINE RESULTING IN A TECHNICAL DEFAULT IN VIOLATION OF ICE CLEAR CREDIT RULE 401(I).4 Status: Final Summary: MATTER WAS FINALIZED WITH A WARNING LETTER AND IS NO LONGER REPORTABLE. PLEASE MOVE DRP TO ARCHIVE.

Regulatory as of Nov 19, 2024

Allegations: IN A NOTICE TO GS MACE HOLDINGS LIMITED ("GSMH") AND GOLDMAN SACHS INVESTMENTS (MAURITIUS) I LIMITED ("GSIM"), THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED A DELAY IN AN OWNERSHIP THRESHOLD DISCLOSURE IN ALLEGED VIOLATION OF REGULATION 7(1) OF THE SEBI (SUBSTANTIAL ACQUISITION OF SHARES AND TAKEOVER) REGULATIONS, 1997. Status: Final Summary: ON FEBRUARY 17, 2017, SEBI NOTIFIED GSMH AND GSIM THAT IT HAS WITHDRAWN ITS NOTICE OF ADJUDICATION PROCEEDINGS AGAINST GSMH AND GSIM.

Regulatory as of Nov 19, 2024

Allegations: THE PORTUGUESE SECURITIES MARKET COMMISSION ("CMVM") HAS ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI")WILLFULLY VIOLATED ITS DUTY TO PROTECT THE MARKET IN ALLEGED VIOLATION OF ARTICLES 311 AND 407 OF THE PORTUGUESE SECURITIES CODE. ON JUNE 2, 2020, THE CMVM CLOSED THEIR INVESTIGATION INTO GSI WITHOUT ISSUING ANY FORMAL CHARGES FOR ANY VIOLATIONS OF THE PORTUGUESE SECURITIES CODE. Status: Final Summary: THE CMVM NOTIFIED GSI THAT IT WAS PROPOSING TO IMPOSE A FINE IN THE AMOUNT OF EURO 50,000 (WITH AN ADDITIONAL EURO 50,000 SUSPENDED FOR 2 YEARS). GSI CONTESTED THE FINE. ON JUNE 2, 2020, THE CMVM CLOSED THEIR INVESTIGATION INTO GSI WITHOUT ISSUING ANY FORMAL CHARGES FOR ANY VIOLATIONS OF THE PORTUGUESE SECURITIES CODE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO.("GS") ALLEGEDLY VIOLATED NASD RULES 2110, 2320, 6130(D)AND SEC RULE 11AC1-4, RESPECTIVELY, IN CONNECTION WITH A DISCREET NUMBER OF TRANSACTIONS BY ALLEGEDLY FAILING TO EXECUTE ORDERS PROMPTLY, TO USE REASONABLE DILIGENCE TO ASCERTAIN BEST INTER-DEALER MARKET FOR MOST FAVORABLE CUSTOMER PRICE, REPORT CORRECT TRANSACTION SYMBOLS AND TO IMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTATION. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO THE ENTRY OF FINDINGS. Status: Final Sanction Detail: GOLDMAN SACHS & CO. SIGNED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, WHICH WAS ACCEPTED BY THE NASD ON 8/24/2002 AND PAID A FINE OF $7500.00. ON 9/28/2002.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO.("GS")ALLEGEDLY VIOLATED NASD RULE 4613(E) BY ALLEGEDLY FAILING TO MAKE REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET ON CERTAIN OCCASIONS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO THE ENTRY OF FINDINGS. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. SIGNED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, WHICH WAS ACCEPTED BY THE NASD ON 6/28/02 AND PAID A FINE OF $17500.00 ON 7/23/02.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") AND THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED THAT FIVE BROKER DEALERS, INCLUDING GOLDMAN, SACHS & CO.("GOLDMAN SACHS"), VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THREE YEARS AND/OR TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF ELECTRONIC MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD) Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIVE BROKER DEALERS,INCLUDING GOLDMAN SACHS, CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE-AND-DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND THE RULES OF THE NASD AND NYSE, AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS& PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") AND THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED THAT FIVE BROKER DEALERS, INCLUDING GOLDMAN SACHS VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THREE YEARS AND/OR TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF ELECTRONIC MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD) Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIVE BROKER DEALERS, INCLUDING GOLDMAN SACHS, CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE-AND-DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS SYSTEMS AND PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND THE RULES OF THE NASD AND NYSE, AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. ALLEGEDLY VIOLATED NASD CONDUCT RULE 3360 BY FAILING TO REPORT FULLY ITS SHORT INTEREST POSITION IN CERTAIN SECURITIES FOR CERTAIN PERIODS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE AND A $20,000.00 FINE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE AND A $20,000.00 FINE Summary: AWC WAS ACCEPTED BY THE NASD ON 10/23/02.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE, THE NASD AND THE SEC CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: $25,000,000 AS DISGORGEMENT, $25,000,000 AS PENALTIES, $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH, $10,000,000 FOR INVESTOR EDUCATION. Summary: ON APRIL 28, 2003, WITHOUT ADMITTING OR DENYING LIABILITY, TEN INVESTMENT BANKING FIRMS, INCLUDING GS, ENTERED INTO GLOBAL SETTLEMENTS WITH THE SEC, THE NYSE, THE NASD, THE NEW YORK ATTORNEY GENERAL AND OTHER STATES TO RESOLVE THE INVESTIGATIONS RELATING TO EQUITY RESEARCH ANALYST CONFLICTS OF INTEREST. GS WAS CHARGED WITH VIOLATING NYSE RULES 342, 401, 472 AND 476, AND NASD CONDUCT RULES 2110, 2210 AND 3010. GS ALSO AGREED TO CENSURE BY THE NYSE AND THE NASD AND TO PAY A TOTAL OF $110,000,000. GS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF "HOT" IPO SHARES. THE TERMS OF THE GLOBAL SETTLEMENT WERE ENTERED IN AN ORDER BY A FEDERAL COURT IN THE SOUTHERN DISTRICT OF NEW YORK ON OCTOBER 31, 2003 (CIVIL ACTION NUMBER 03CV2944).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE, THE NASD AND THE SEC CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: $25,000,000 AS DISGORGEMENT, $25,000,000 AS PENALTIES, $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH, $10,000,000 FOR INVESTOR EDUCATION. Summary: ON APRIL 28, 2003, WITHOUT ADMITTING OR DENYING LIABILITY, TEN INVESTMENT BANKING FIRMS, INCLUDING GS, ENTERED INTO GLOBAL SETTLEMENTS WITH THE SEC, THE NYSE, THE NASD, THE NEW YORK ATTORNEY GENERAL AND OTHER STATES TO RESOLVE THE INVESTIGATIONS RELATING TO EQUITY RESEARCH ANALYST CONFLICTS OF INTEREST. GS WAS CHARGED WITH VIOLATING NYSE RULES 342, 401, 472 AND 476, AND NASD CONDUCT RULES 2110, 2210 AND 3010. GS ALSO AGREED TO CENSURE BY THE NYSE AND THE NASD AND TO PAY A TOTAL OF $110,000,000. GS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF "HOT" IPO SHARES. THE TERMS OF THE GLOBAL SETTLEMENT WERE ENTERED IN AN ORDER BY A FEDERAL COURT IN THE SOUTHERN DISTRICT OF NEW YORK ON OCTOBER 31, 2003 (CIVIL ACTION NUMBER 03CV2944).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT IN 128 INSTANCES BETWEEN JULY 2003 AND SEPTEMBER 2003, DURING THE 9 MINUTE PERIOD IMMEDIATELY PRIOR TO THE OPENING OF THE MARKET, GOLDMAN SACHS, AS MARKET MAKER FOR CERTAIN SECURITIES, CAUSED A LOCKED/CROSSED MARKET CONDITION BY ENTERING A BID (ASK) QUOTATION THAT LOCKED/CROSSED ANOTHER MARKET MAKER'S QUOTATION WITHOUT IMMEDIATELY SENDING THROUGH SELECTNET TO SUCH LOCKED/CROSSED MARKET MAKER A TRADE-ON-MOVE MESSAGE THAT WAS AT THE RECEIVING MARKET MAKER'S QUOTED PRICE AND WHOSE AGGREGATE SIZE WAS AT LEAST 5,000 SHARES, IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(L)(C). Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $20,000 Summary: GOLDMAN SACHS ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WITH NASD. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE BY NASD AND THE PAYMENT OF A $20,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NASD ALLEGED THAT GOLDMAN SACHS VIOLATED NASD RULES 2710, 2110 AND 3010 FOR FAILING TO TAKE REASONABLE STEPS TO ENSURE THAT SHARES OF AN ISSUER HELD BY RELATIVES OF CERTAIN EMPLOYEES WERE NOT SOLD PRIOR TO THE EXPIRATION OF LOCK-UP PERIODS IN CONNECTION WITH GOLDMAN SACHS' ROLE AS AN UNDERWRITER OF SUCH ISSUER'S IPO. Status: Final Sanction Detail: GOLDMAN SACHS PAID THE FINE OF $125,000 ON MARCH 28, 2005. Summary: ON MARCH 17, 2005, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, GOLDMAN SACHS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH THE NASD. GOLDMAN SACHS AGREED TO CENSURE BY THE NASD AND TO PAY A FINE OF $125,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT, ON TRADE DATES JULY 22ND AND 23RD, 2003, GOLDMAN, SACHS & CO. ("GSCO") ENGAGED IN CERTAIN TRANSACTIONS THAT IN CERTAIN RESPECTS VIOLATED RULES FOR SHORT SALES TRANSACTIONS AND MARKETPLACE RULES FOR OATS (NASD CONDUCT RULES 3370, 2110 AND 3010, AND NASD MARKETPLACE RULES 4632, 6130 AND 6955(A)), AND THAT GSCO'S SUPERVISORY PROCEDURES IN SUCH AREAS WERE DEFICIENT. Status: Final Sanction Detail: GSCO PAID A FINE OF $25,000. Summary: ON OR ABOUT JUNE 15, 2000, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, GSCO CONSENTED TO A CENSURE AND TO PAY A TOTAL FINE OF $25,000. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY THE NASD ON 7/19/2005.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT, FOR THE PERIOD OF JANUARY 1, 2004 THROUGH APRIL 30, 2004, GOLDMAN SACHS & CO. ("GS") FAILED TO TRANSMIT THROUGH ACT 100 LAST SALE REPORTS OF TRANSACTIONS IN PORTAL EQUITY SECURITIES, BY 6:30 PM EST ON THE DAY OF EXECUTION, IN VIOLATION OF NASD PORTAL MARKET RULE 5322(A)(2). Status: Final Sanction Detail: GS PAID A MONETARY FINE OF $7,500. Summary: ON OCTOBER 12, 2005, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, GS CONSENTED TO A CENSURE AND $7,500 FINE. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY NASD ON NOVEMBER 23, 2005.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT FROM JANUARY 1 THROUGH APRIL 30, 2005, GS VIOLATED NASD RULE 2110 BY FAILING TO TIMELY TRANSMIT THROUGH NASDAQ NATIONAL MARKET CENTER LAST SALE REPORTS OF CERTAIN TRANSACTIONS IN CQS SECURITIES. Status: Final Sanction Detail: GS CONSENTED TO A CENSURE AND ON OCTOBER 3, 2006, PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,500. Summary: GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY THE NASD ON SEPTEMBER 15, 2006. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND PAYMENT OF A $6,500 CIVIL MONETARY FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINRA DEPARTMENT OF MARKET REGULATION AND THE NEW YORK STOCK EXCHANGE ("NYSE") DIVISION OF ENFORCEMENT ALLEGED THAT, DURING THE PERIOD FROM SEPTEMBER 1, 2003 TO SEPTEMBER 30, 2004, A GOLDMAN, SACHS & CO. (THE "FIRM") TRADING DESK VIOLATED FIRM GUIDELINES AND CERTAIN FINRA AND NYSE RULES IN CONNECTION WITH IMPLEMENTING A TRADING STRATEGY, AND THAT THE FIRM ALSO FAILED TO REASONABLY SUPERVISE CERTAIN ACTIVITIES OF ITS TRADING DESK. SPECIFICALLY, NYSE AND FINRA ALLEGED THAT THE FIRM'S TRADING DESK FAILED TO MAINTAIN ITS INDEPENDENCE IN THE CONDUCT OF CERTAIN OVER-THE-COUNTER STOCK TRANSACTIONS IN WHICH A FOREIGN AFFILIATE WAS THE COUNTERPARTY. NYSE AND FINRA ALLEGED THAT THE ACTIVITIES VIOLATED RULES RELATING TO TRADE REPORTING, SHORT SALES, MAINTENANCE OF PROPER BOOKS AND RECORDS AND SUPERVISORY OBLIGATIONS, INCLUDING NASD MARKETPLACE RULES 6420(A) & (B), 5430(A) AND 6130(D)(6), NASD CONDUCT RULES 2110, 3010(A) AND (B) AND 3110, NYSE RULES 342, 410B AND 440, AS WELL AS SECTIONS 10A AND 17A OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 10A-1(A) & (C) AND 17A-3 & 4 THEREUNDER. Status: Final Sanction Detail: THE FIRM CONSENTED TO A JOINT MONETARY PENALTY IN THE AMOUNT OF $600,000, PAID AS $300,000 TO EACH OF FINRA AND NYSE, WHICH WAS PAID ON DECEMBER 15, 2008. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED JOINTLY INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WITH FINRA AND A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH NYSE, AND ON DECEMBER 15, 2008, THE FIRM PAID A JOINT MONETARY PENALTY IN THE AMOUNT OF $600,000, PAID AS $300,000 TO EACH OF FINRA AND NYSE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE INTERNATIONAL SECURITIES EXCHANGE, LLC ("ISE") ALLEGED THAT, DURING THE THIRD AND FOURTH QUARTERS OF 2007, GOLDMAN, SACHS & CO. (THE "FIRM") SENT CERTAIN PRINCIPAL ACTING AS AGENT ("P/A") ORDERS THROUGH THE LINKAGE IN WHICH (1) THE CUSTOMER ORDER HAD ALREADY BEEN FILLED OR (2) THE P/A ORDER EXCEEDED THE CUSTOMER ORDER SIZE OR (3) THE EXECUTION OF THE P/A ORDER WAS NOT PASSED ALONG TO THE CUSTOMER IN ALLEGED VIOLATION OF ISE RULE 400. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A MONETARY PENALTY IN THE AMOUNT OF $10,000, WHICH WAS PAID ON MARCH 27, 2009. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS ACCEPTED BY ISE ON MARCH 18, 2009 AND ON MARCH 27, 2009, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $10,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) FROM JULY 1 TO SEPTEMBER 30, 2007, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR 220 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF NASD RULE 6230(C)(6), AND (II) FROM JANUARY 1 TO MARCH 31, 2009, FAILED TO REPORT TO TRACE 1,077 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION, IN ALLEGED VIOLATION OF FINRA RULE 6730(A) AND ALLEGEDLY CONSTITUTING A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $27,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 28, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JUNE 10, 2011 AND ON JUNE 28, 2011, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $27,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE LEGAL SECTION OF THE MARKET REGULATION DEPARTMENT AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, ON BEHALF OF NYSE REGULATION, INC., ALLEGED THAT, DUE TO THE INADVERTENT INTRODUCTION OF A PROGRAMMING ERROR INTO A SURVEILLANCE REPORT DESIGNED TO DETECT POTENTIAL VIOLATIONS OF RULE 105 OF REGULATION M, AND WHICH HAS SINCE BEEN CORRECTED, GOLDMAN, SACHS & CO. (THE "FIRM"), FROM IN OR ABOUT OCTOBER 2007 THROUGH AUGUST 2008, DID NOT MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO DETECT POTENTIAL VIOLATIONS OF RULE 105 OF REGULATION M, IN ALLEGED VIOLATION OF NYSE ARCA EQUITIES RULE 6.18(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $40,000 WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON JANUARY 26, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT WITH NYSE REGULATION, INC., ON BEHALF OF NYSE ARCA, INC., WHICH WAS ACCEPTED BY THE NYSE ARCA HEARING BOARD ON JANUARY 9, 2012, AND ON JANUARY 26, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $40,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE LEGAL SECTION OF THE MARKET REGULATION DEPARTMENT AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, ON BEHALF OF NYSE REGULATION, INC, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED : (I) (I) ON FIVE OCCASIONS BETWEEN NOVEMBER 14, 2008 AND AUGUST 5, 2009, TO TIMELY SUBMIT THE REGULATION M TRADING NOTICE TO THE NYSE IN CONNECTION WITH DISTRIBUTIONS ON AN NYSE-LISTED COMPANY IN WHICH THE FIRM ACTED AS AN UNDERWRITER OR MANAGER AND (II) TO NOTIFY THE NYSE OF THE FIRM'S INTENTION TO ENGAGE IN CERTAIN SYNDICATE COVERING TRANSACTIONS ON APRIL 27-28, 2010 AND MAY 18, 2010, PRIOR TO ENGAGING IN THE TRANSACTIONS, IN CONNECTION WITH AN OFFERING OF A SECURITY FOR WHICH THE FIRM WAS LEAD MANAGER, EACH IN ALLEGED VIOLATION OF NYSE RULE 5190; (II) ON TWO OCCASIONS BETWEEN JUNE 4, 2009 AND MARCH 5, 2010, TO TIMELY NOTIFY THE NYSE OF ITS PARTICIPATION IN A DISTRIBUTION FOR WHICH ITS AFFILIATED DESIGNATED MARKET-MAKER (DMM) WAS REGISTERED, IN ALLEGED VIOLATION OF NYSE RULE 460.30; AND (III) TO REASONABLY SUPERVISE COMPLIANCE WITH NYSE RULES 5190 AND 460.30, BY FAILING TO HAVE A REASONABLE SYSTEM OF FOLLOW-UP AND REVIEW TO DETERMINE IF ITS REPORTING POLICIES AND PROCEDURES WITH RESPECT TO SUCH RULES WERE FOLLOWED, IN ALLEGED VIOLATION OF NYSE RULE 342. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $10,000 WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON JANUARY 26, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH NYSE REGULATION, INC., WHICH WAS APPROVED BY THE NYSE HEARING BOARD ON JANUARY 9, 2012 AND BECAME FINAL ON FEBRUARY 3, 2012. ON JANUARY 26, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $10,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE LEGAL SECTION OF THE MARKET REGULATION DEPARTMENT AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, ON BEHALF OF NYSE REGULATION, INC., ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN JANUARY 2004 AND JUNE 2011, IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF NYSE ARCA, INC. ("NYSE ARCA") OPTIONS RULES 6.68, 11.1(B) AND 11.16(A), AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF NYSE ARCA OPTIONS RULE 11.18. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO NYSE ARCA AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $671,305 WAS PAID TO NYSE ARCA BY SUBMISSION OF A WIRE ON OCTOBER 2, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO AN OFFER OF SETTLEMENT AND CONSENT WITH NYSE REGULATION, INC., WHICH WAS APPROVED BY THE NYSE ARCA HEARING BOARD ON SEPTEMBER 20, 2012 AND ON OCTOBER 2, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $671,305. THE OFFER OF SETTLEMENT AND CONSENT IS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) BATS EXCHANGE, INC. (BATS); (III) BOSTON OPTIONS EXCHANGE LLC (BOX - A FACILITY OF NASDAQ OMX BX); (IV) THE NASDAQ OPTIONS MARKET (NOM); (V) NASDAQ OMX PHLX, INC. (PHLX): (VI) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); AND (VII) NYSE AMEX LLC (NYSE AMEX).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE LEGAL SECTION OF THE MARKET REGULATION DEPARTMENT AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, ON BEHALF OF NYSE REGULATION, INC., ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN JANUARY 2004 AND JUNE 2011, MISMARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF NYSE AMEX LLC ("NYSE AMEX") RULES 16, 324, 956NY(A) AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF NYSE AMEX RULE 320. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO NYSE AMEX AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $443,700 WAS PAID TO FINRA BY SUBMISSION OF A WIRE ON OCTOBER 19, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH NYSE REGULATION, INC., WHICH WAS APPROVED BY THE NYSE MKT LLC (SUCCESSOR TO NYSE AMEX) HEARING BOARD ON SEPTEMBER 20, 2012 AND BECAME FINAL ON OCTOBER 15, 2012. ON OCTOBER 19, 2012, THE FIRM SUBMITTED A WIRE TO FINRA IN PAYMENT OF THE FINE IN THE AMOUNT OF $443,700. THE STIPULATION OF FACTS AND CONSENT TO PENALTY WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) BATS EXCHANGE, INC. (BATS); (III) BOSTON OPTIONS EXCHANGE LLC (BOX); (IV) THE NASDAQ OPTIONS MARKET (NOM); (V) NASDAQ OMX PHLX, INC. (PHLX): (VI) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); AND (VII) NYSE ARCA, INC. (NYSE ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN MARCH 2008 AND MAY 2010, IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF NASDAQ OPTIONS MARKET, LLC ("NOM") RULES CHAPTER V, SECTIONS 1(B)(III) AND SECTION 7(A), AND CHAPTER IX, SECTION 1; AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF NOM RULES CHAPTER III, SECTIONS 1 AND 2(A)(I). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO NOM AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $63,507 WAS PAID BY SUBMISSION OF A CHECK TO NOM ON OCTOBER 22, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS APPROVED BY FINRA ON SEPTEMBER 14, 2012, AND ON OCTOBER 22, 2012, THE FIRM SUBMITTED A CHECK TO NOM IN PAYMENT OF THE FINE IN THE AMOUNT OF $63,507. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) NASDAQ OMX PHLX, INC. (PHLX); (III) BOSTON OPTIONS EXCHANGE LLC (BOX); (IV) BATS EXCHANGE, INC. (BATS); (V) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN JANUARY 2004 AND MAY 2010, IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF NASDAQ OMX BX, INC. ("BOX") TRADING RULES CHAPTER V, SECTIONS 1 AND 15, AND CHAPTER VIII, SECTION 1; AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF BOX TRADING RULES CHAPTER III, SECTIONS 1 AND 2, AND CHAPTER V, SECTION 1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO BOX AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $297,428 WAS PAID BY SUBMISSION OF A WIRE TO BOX ON OCTOBER 16, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS APPROVED BY FINRA ON SEPTEMBER 14, 2012 AND ON OCTOBER 16, 2012, THE FIRM SUBMITTED A WIRE TO BOX IN PAYMENT OF THE FINE IN THE AMOUNT OF $297,428. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) NASDAQ OMX PHLX, INC. (PHLX); (III) THE NASDAQ OPTIONS MARKET (NOM); (IV) BATS EXCHANGE, INC. (BATS); (V) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION, ON BEHALF OF BATS Z-EXCHANGE, INC. ("BATS"), ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN FEBRUARY 2010 AND MAY 2010, IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF BATS RULES CHAPTER III, RULE 3.1, CHAPTER IV, RULE 4.1, AND CHAPTER XXIV, RULES 24.1 AND 24.4(A); AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF BATS RULES CHAPTER V, RULES 5.1 AND 5.2, AND CHAPTER XVIII, RULE 18.1. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO BATS AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $813.00 WAS PAID BY SUBMISSION OF A CHECK TO BATS ON OCTOBER 22, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS ACCEPTED AND WHICH WAS PUBLISHED BY BATS ON SEPTEMBER 21, 2012, AND ON OCTOBER 22, 2012, THE FIRM SUBMITTED A CHECK TO BATS IN PAYMENT OF THE FINE IN THE AMOUNT OF $813.00. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) NASDAQ OMX PHLX, INC. (PHLX); (III) BOSTON OPTIONS EXCHANGE LLC (BOX); (IV) THE NASDAQ OPTIONS MARKET ("NOM"); (V) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); (VI) NYSE AMEX LLC (AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF JULY 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT ONE (1) INDEX END OF DAY PRICE IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM OF $1,000, WHICH WAS MADE FINAL ON NOVEMBER 6, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 19, 2013. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM OF $1,000, WHICH WAS MADE FINAL ON NOVEMBER 6, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 19, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF DECEMBER, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT TWO (2) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $2,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $2,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN A NOTICE OF SUMMARY FINE DATED JANUARY 10, 2014, ICE FUTURES U.S., INC. ("ICE") COMPLIANCE DEPARTMENT INFORMED GOLDMAN, SACHS & CO. (THE "FIRM") THAT ON OCTOBER 23, 2013, OCTOBER 29, 2013, AND NOVEMBER 20, 2013, CERTAIN BLOCK TRADES WERE REPORTED LATE IN ALLEGED VIOLATION OF ICE RULE 4.07(C). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON FEBRUARY 3, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON FEBRUARY 3, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2014, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT THREE (3) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $3,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $3,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT IN CONNECTION WITH EFFORTS BY GOLDMAN, SACHS & CO. (THE "FIRM") AND OTHER BROKER-DEALERS TO PARTICIPATE IN A COMPANY'S PLANNED INITIAL PUBLIC OFFERING (IPO), THE FIRM: (A) ALLOWED A RESEARCH ANALYST TO PARTICIPATE IN THE SOLICITATION OF CERTAIN INVESTMENT BANKING BUSINESS; (B) OFFERED FAVORABLE RESEARCH COVERAGE TO INDUCE THE RECEIPT OF INVESTMENT BANKING BUSINESS; AND (C) FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF NASD RULE 2711, IN ALLEGED VIOLATION OF NASD RULES 2711(C)(4), 2711(E), AND 2711(I), RESPECTIVELY, AND EACH IN ALLEGED VIOLATION OF FINRA RULE 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 18, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 10, 2014, AND ON DECEMBER 18, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $5,000,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") AND THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED THAT FIVE BROKER DEALERS, INCLUDING GOLDMAN, SACHS & CO.("GOLDMAN SACHS"), VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THREE YEARS AND/OR TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF ELECTRONIC MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD) Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIVE BROKER DEALERS,INCLUING GOLDMAN SACHS, CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE-AND-DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND THE RULES OF THE NASD AND NYSE, AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS& PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS ALLEGEDLY VIOLATED (I) SECTION 15(C)(1) AND RULE 15C1-2 OF THE EXCHANGE ACT AS A RESULT OF CERTAIN TRADING IN U.S. TREASURY BONDS ON OCTOBER 31, 2001; AND (II) SECTION 15(F) OF THE EXCHANGE ACT BY FAILING TO MAINTAIN POLICIES AND PROCEDURES SPECIFICALLY ADDRESSED TO THE POSSIBLE MISUSE OF NON-PUBLIC INFORMATION OBTAINED FROM OUTSIDE CONSULTANTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS CONSENTED TO THE ENTRY OF AN ORDER THAT, AMONG OTHER THINGS, (I) CENSURED GOLDMAN SACHS; (II) DIRECTED GOLDMAN SACHS TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTION 15(C)(1)(A) & (C) AND 15(F) AND RULE 15C1-2 OF THE EXCHANGE ACT; (III) ORDERED GOLDMAN SACHS TO PAY DISGORGEMENT AND PREJUDGMENT INTEREST IN THE AMOUNT OF $1,742,642, AND A CIVIL MONETARY PENALTY OF $5 MILLION; AND (IV) DIRECTED GOLDMAN SACHS TO CONDUCT A REVIEW ITS POLICIES AND PROCEDURES ADOPT, IMPLEMENT AND MAINTAIN POLICIES AND PROCEDURES CONSISTENT WITH THE ORDER AND THAT REVIEW. GOLDMAN SACHS ALSO UNDERTOOK TO PAY $2,562,740 IN DISGORGEMENT AND INTEREST RELATING TO CERTAIN TRADING IN U.S. TREASURY BOND FUTURES. Summary: ON SEPTEMBER 4, 2003, THE SEC ENTERED ITS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TO SECTIONS 15(B)(4) & 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AS TO GOLDMAN, SACHS & CO., AS DESCRIBED ABOVE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO. VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD RULE G-36 BY FAILING TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB AS REQUIRED FROM APPROXIMATELY SEPT. 1995 THROUGH SEPT. 1996. Status: Final Sanction Detail: GS&CO. CONSENTED TO A CENSURE AND A $25,000 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. Summary: ON DEC. 3, 1997, THE NASDR CENSURED AND FINED NUMEROUS MUNICIPAL SECURITIES DEALERS FOR ALLEGED VIOLATIONS OF MUNICIPAL SECURITIES RULEMAKING BOARD RULE G-36 BY FAILING TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB AS REQUIRED FROM APPROXIMATELY SEPT. 1995 THROUGH SEPT. 1996. WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GS&CO. CONSENTED TO A CENSURE AND A $25,000 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ON DEC. 3, 1997. THE AWC WAS ACCEPTED ON DEC. 15, 1997.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. VIOLATED RULE 11AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, PART V, SECTION 2(B) OF SCHEDULE D TO THE NASD BY-LAWS AND ARTCLE III, SECTION 1 AND 6 OF THE NASD'S RULES OF FAIR PRACTICE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING, GOLDMAN, SACHS & CO. SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO THE NASD AND LATER PAID A FINE OF $2,500. Summary: ON JUNE 1, 1995, WITHOUT ADMITTING OR DENYING, GOLDMAN, SACHS & CO. SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO THE NASD AND LATER PAID A FINE OF $2,500 FOR ALLEGED VIOLATIONS OF RULE 11AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, PART V, SECTION 2(B) OF SCHEDULE D TO THE NASD BY-LAWS AND ARTCLE III, SECTION 1 AND 6 OF THE NASD'S RULES OF FAIR PRACTICE, ON JUNE 9, 1994 (CMS950026 AWC). THE AWC WAS ACCEPTED BY THE NASD ON SEPT. 25, 1995.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBT ALLEGED THAT GOLDMAN, SACHS & CO. VIOLATED CBT RULES AND REGULATIONS WITH RESPECT TO SEGREGATED AND SECURED ACCOUNTS MAINTAINED WITH THIRD PARTY BANKS FOR THE CUSTODY OF CUSTOMER FUTURES MARGIN. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. CONSENTED TO PAY THE CBT A $10,000 FINE. Summary: ON JULY 17, 1996, GOLDMAN, SACHS & CO. CONSENTED TO PAY THE CBT A $10,000 FINE FOR THE ALLEGED VIOLATION OF CBT RULES AND REGULATIONS WITH RESPECT TO SEGREGATED AND SECURED ACCOUNTS MAINTAINED WITH THIRD PARTY BANKS FOR THE CUSTODY OF CUSTOMER FUTURES MARGIN.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GOLDMAN, SACHS & CO. VIOLATED NASD MARKETPLACE RULE 4613(D). THE NASDR ALLEGED THAT GS & CO. ENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THE MAXIMUM ALLOWABLE SPREADS. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. CONSENTED TO A $4,000 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. Summary: ON JULY 30, 1996, THE NASDR FINED GOLDMAN, SACHS & CO. FOR ALLEGED VIOLATIONS OF NASD MARKETPLACE RULE 4613(D). THE NASDR ALLEGED THAT GS & CO. ENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THE MAXIMUM ALLOWABLE SPREADS. WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GOLDMAN, SACHS & CO. CONSENTED TO A $4,000 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ON AUGUST 19, 1996. THE AWC WAS ACCEPTED ON JUNE 13, 1997.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GS&CO. VIOLATED MARKETPLACE RULE 6240 AND CONDUCT RULE NO. 2110 BY FAILING TO REPORT CERTAIN FIPS TRANSACTIONS DURING THE PERIOD 5/1/95 - 4/18/96 AND FAILING TO REPORT IN A TIMELY MANNER CERTAIN TRANSACTIONS DURING THE TIME PERIOD 6/15/95 - 7/19/95. Status: Final Sanction Detail: GS&CO. PAID A $5,000 FINE AND CONSENTED TO THE NASD IMPOSING A CENSURE. Summary: ON AUGUST 5, 1996 THE NASD ALLEGED THAT GS&CO. VIOLATED MARKETPLACE RULE 6240 AND CONDUCT RULE NO. 2110 BY FAILING TO REPORT CERTAIN FIPS TRANSACTIONS DURING THE PERIOD 5/1/95 - 4/18/96 AND FAILING TO REPORT IN A TIMELY MANNER CERTAIN TRANSACTIONS DURING THE TIME PERIOD 6/15/95 - 7/19/95. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS&CO. PAID A $5,000 FINE AND CONSENTED TO THE NASD IMPOSING A CENSURE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO. VIOLATED RULE 11AC1-1(C) OF THE SECURITIES AND EXCHANGE ACT OF 1934, NASD MARKETPLACE RULE 4613(B) AND NASD CONDUCT RULES 2110 AND 3320. THE NASDR ALLEGED THAT GS&CO. FAILED TO EXECUTE CERTAIN ORDERS AT GS&CO.'S PUBLISHED BID OR OFFER. Status: Final Sanction Detail: GS&CO. CONSENTED TO A CENSURE AND $6,250 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. Summary: ON APRIL 1, 1998, NASDR CENSURED AND FINED GS&CO. FOR ALLEGED VIOLATIONS OF RULE 11AC1-1(C) OF THE SECURITIES AND EXCHANGE ACT OF 1934, NASD MARKETPLACE RULE 4613(B) AND NASD CONDUCT RULES 2110 AND 3320. THE NASDR ALLEGED THAT GS&CO. FAILED TO EXECUTE CERTAIN ORDERS AT GS&CO.'S PUBLISHED BID OR OFFER. WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GS&CO. CONSENTED TO A CENSURE AND $6,250 FINE BY SIGNING A LETTER OF ACCEPTANC, WAIVER AND CONSENT ON APRIL 1, 1998. THE AWC WAS ACCEPTED ON APRIL 1, 1998.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO. VIOLATED NASD MARKETPLACE RULE 6620 AND NASD CONDUCT RULES 2110 AND 3010. THE NASDR ALLEGED THAT GS&CO. UNTIMELY FILED CERTAIN TRANSACTIONS IN OTC EQUITY SECURITIES ON FORMS T WITH THE NASD. THE NASD ALSO ALLEGED THAT GS&CO. FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE RULES OF THE NASD RELATING TO THE REPORTING OF TRANSACTIONS VIA FORM T. Status: Final Sanction Detail: GS&CO. CONSENTED TO A CENSURE AND A $17,500 FINE BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT. Summary: ON 7/28/99, NASDR ALLEGED THAT GS&CO. VIOLATED NASD MARKETPLACE RULE 6620 AND NASD CONDUCT RULES 2110 AND 3010. THE NASDR ALLEGED THAT GS&CO. UNTIMELY FILED CERTAIN TRANSACTIONS IN OTC EQUITY SECURITIES ON FORMS T WITH THE NASD. THE NASD ALSO ALLEGED THAT GS&CO. FAILED TO ESTABLISH WRITTEN PROCEDURES TO ACHIEVE COMPLIANCE WITH THE APPLICABLE RULES OF THE NASD RELATING TO THE REPORTING OF TRANSACTIONS VIA FORM T. GS&CO. CONSENTED TO A CENSURE AND A $17,500 FINE BY SIGNING AN AWC ON 7/28/99 - AWC WAS ACCEPTED ON 2/14/2000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO. VIOLATED NASD CONDUCT RULE 3360. THE NASDR ALLEGED THAT GS&CO. FAILED TO REPORT ITS SHORT INTEREST POSITION IN ONE SECURITY. Status: Final Sanction Detail: GS&CO. CONSENTED TO A $1,000 FINE BY SIGNING A AWC. Summary: ON SEPT. 15, 1999, NASDR ALLEGED THAT GS&CO. VIOLATED NASD CONDUCT RULE 3360. THE NASDR ALLEGED THAT GS&CO. FAILED TO REPORT ITS SHORT INTEREST POSITION IN ONE SECURITY. WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GS&CO. CONSENTED TO A $1,000 FINE BY SIGNING A LETTER OF AWC ON SEPT. 15, 1999. THE AWC WAS ACCEPTED ON DEC. 16, 1999.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-12 AND G-14. THE NASDR ALLEGED THAT GS&CO. FAILED TO PROVIDE ACCURATE AND/OR TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NATIONAL SECURITIES CLEARING CORPORATION ("NSCC"). Status: Final Sanction Detail: GS&CO. CONSENTED TO A $1,000 FINE BY SIGNING AN AWC. Summary: ON NOV. 8, 1999, NASDR ALLEGED THAT GS&CO VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-12 AND G-14. THE NASDR ALLEGED THAT GS&CO. FAILED TO PROVIDE ACCURATE AND/OR TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NATIONAL SECURITIES CLEARING CORPORATION ("NSCC"). WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GS&CO. CONSENTED TO A $1,000 FINE BY SIGNING AN AWC. THE AWC WAS ACCEPTED ON DEC. 16, 1999.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE CHARGED THAT GS&CO. ALLEGEDLY VIOLATED EXCHANGE RULE 4.1 BY ENTERING AN ORDER PRIOR TO DISCLOSING THE TERMS AND CONDITIONS OF THE ORIGINAL ORDER TO THE RELEVANT TRADING CROWD, AS REQUIRED BY EXCHANGE RULE 6.9(E). Status: Final Sanction Detail: GS&CO. AGREED TO PAY A FINE OF $10,000. Summary: ON APRIL 17, 2000, THE CBOE ORDERED DISCIPLINARY PROCEEDINGS UNDER CHAPTER 17 OF THE RULES OF THE EXCHANGE. CBOE CHARGED THAT GS&CO. ALLEGEDLY VIOLATED EXCHANGE RULE 4.1 BY ENTERING AN ORDER PRIOR TO DISCLOSING THE TERMS AND CONDITIONS OF THE ORIGINAL ORDER TO THE RELEVANT TRADING CROWD, AS REQUIRED BY EXCHANGE RULE 6.9(E). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS&CO. AGREED TO PAY A FINE OF $10,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS&CO. VIOLATED NASD MARKETPLACE RULE 4613(E) - LOCKED AND CROSSED - DURING THE PERIODS OF JUNE 1, 1997 THROUGH DEC. 31, 1997 AND JULY 1, 1999 THROUGH SEPT. 30, 1999. Status: Final Sanction Detail: GS&CO SIGNED AN AWC CONSENTING TO A CENSURE AND A FINE OF $13,000. Summary: NASDR ALLEGED THAT GS&CO. VIOLATED NASD MARKETPLACE RULE 4613(E) - LOCKED AND CROSSED - DURING THE PERIODS OF JUNE 1, 1997 THROUGH DEC. 31, 1997 AND JULY 1, 1999 THROUGH SEPT. 30, 1999. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ON JULY 24, 2000, GS&CO SIGNED AN AWC CONSENTING TO A CENSURE AND A FINE OF $13,000, WHICH WAS ACCEPTED ON OCT. 10, 2000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE INTERNATIONAL SECURITIES EXCHANGE, LLC ("ISE") ALLEGED THAT, DURING THE PERIOD FROM MAY 2009 THROUGH AUGUST 2009, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT LARGE OPTION POSITION REPORTS WITH REGARD TO CERTAIN ACCOUNTS THAT MET THE REPORTING REQUIREMENT THRESHOLD IN ALLEGED VIOLATION OF ISE RULE 415. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $17,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 4, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY ISE ON MAY 20, 2010 AND ON JUNE 4, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $17,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. ("GS") ALLEGEDLY VIOLATED NASD RULES 2110, 2320, 6130(D) AND SEC RULE 11AC1-4. GS ALLEGEDLY FAILED TO EXECUTE ORDERS PROMPTLY, TO USE REASONABLE DILIGENCE TO ASCERTAIN BEST INTER-DEALER MARKET FOR MOST FAVORABLE CUSTOMER PRICE, REPORT CORRECT TRANSACTION SYMBOLS AND TO IMMEDIATELY DISPLAY CUSTOMER LIMIT ORDERS IN ITS PUBLIC QUOTATION. WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS CONSENTED TO THE ENTRY OF FINDINGS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING, GOLDMAN, SACHS & CO. SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO THE NASD AND LATER PAID A FINE OF $7,500 AND RESTITUTION TO INVESTORS IN THE TOTAL AMOUNT OF $1,056.00 PLUS INTEREST FROM THE DATE OF THE ALLEGED VIOLATIVE CONDUCT UNTIL THE DATE THE AWC WAS ACCEPTED. Summary: ON JUNE 25, 2002, WITHOUT ADMITTING OR DENYING, GOLDMAN, SACHS & CO. SUBMITTED AN AWC TO THE NASD AND LATER PAID A FINE OF $7,500 AND RESTITUTION TO INVESTORS IN THE TOTAL AMOUNT OF $1,056.00 PLUS INTEREST FOR ALLEGED VIOLATIONS OF NASD RULES 2110, 2320, 6130(D) AND SEC RULE 11AC1-4. THE AWC WAS ACCEPTED BY THE NASD ON AUGUST 24, 2002.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. ("GS") ALLEGEDLY VIOLATED NASD RULE 4613(E). GS, A MARKET MAKER, ALLEGEDLY FAILED TO MAKE REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO THE ENTRY OF FINDINGS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING GOLDMAN, SACHS & CO. SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO THE NASD AND LATER PAID A FINE OF $17,500. Summary: ON MAY 23, 2002, WITHOUT ADMITTING OR DENYING, GOLDMAN, SACHS & CO. SUBMITTED AN AWC TO THE NASD AND LATER PAID A FINE OF $17,500 FOR ALLEGED VIOLATIONS OF NASD RULE 4613(E). THE AWC WAS ACCEPTED BY THE NASD ON JULY 23, 2002.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. ALLEGEDLY VIOLATED CBOT REGULATIONS 444.03 AND 545.02 ON A SINGLE OCCASION BY NETTING DOWN US TREASURY BOND FUTURES AND TO ACCURATELY REPORT TO THE CBOT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS PAID A FINE OF $15,000.00. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS PAID A FINE OF $15,000.00. Summary: ON 01/10/2003, GOLDMAN SACHS SENT A CHECK IN THE AMOUNT OF $15,000.00 TO THE CBOT.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. ALLEGEDLY VIOLATED NASD CONDUCT RULE 3360 BY FAILING TO REPORT FULLY ITS SHORT INTEREST POSITION IN CERTAIN SECURITIES FOR CERTAIN PERIODS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE AND A $20,000.00 FINE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE AND A $20,000.00 FINE. Summary: AWC WAS ACCEPTED BY THE NASD ON 10/23/02.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SEC, NASD AND NYSE ALLEGED THAT FIVE BROKER DEALERS INCLUDING GOLDMAN SACHS VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 HEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE E-MAIL COMMUNICATIONS FOR 3 YEARS AND/OR TO PRESERVE E-MAIL COMMUNICATIONS FOR THE FIRST 2 YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF E-MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD). Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, 5 BROKER-DEALERS INCLUDING GOLDMAN SACHS CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE AND DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF E-MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND RULES OF THE NASD AND NYSE AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SEC, NASD AND NYSE ALLEGED THAT FIVE BROKER DEALERS INCLUDING GOLDMAN SACHS VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 HEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE E-MAIL COMMUNICATIONS FOR 3 YEARS AND/OR TO PRESERVE E-MAIL COMMUNICATIONS FOR THE FIRST 2 YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF E-MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD). Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, 5 BROKER-DEALERS INCLUDING GOLDMAN SACHS CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE AND DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF E-MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND RULES OF THE NASD AND NYSE AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) GOLDMAN, SACHS & CO. ("GSCO") FAILED TO TIMELY REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE"), CERTAIN TRANSACTIONS IN (A) TRACE-ELIGIBLE CORPORATE DEBT SECURITIES, DURING THE PERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013 IN ALLEGED VIOLATION OF FINRA RULES 6730(A) AND 2010; AND (B) SECURITIZED PRODUCTS AND AGENCY DEBT SECURITIES, DURING THE PERIOD OF JANUARY 1, 2014 THROUGH MARCH 31, 2014, EACH IN ALLEGED VIOLATION OF FINRA RULE 6730(A), AND WITH REGARD TO THE TRACE-ELIGIBLE SECURITIZED PRODUCTS, IN ALLEGED VIOLATION OF FINRA RULE 2010; AND (II) GSCO'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR TIMELY SUBMISSION OF ACCURATE REPORTS TO TRACE, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $185,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JULY 9, 2015. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, FINE AND UNDERTAKING AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JUNE 3, 2015, AND ON JULY 9, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $185,000. IN THE UNDERTAKING, THE FIRM CONSENTED TO PROVIDE THREE REPORTS, WRITTEN AND ORAL, TO FINRA ON DATES THAT ARE NO MORE THAN 3 MONTHS, 6 MONTHS, AND 12 MONTHS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THE AWC, REGARDING THE EFFECTIVENESS OF THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TIMELY SUBMISSION OF ACCURATE REPORTS TO TRACE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT DURING THE MONTH OF JUNE 2015, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT CERTAIN INDEX PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). Status: Final Sanction Detail: ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $19,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE. Summary: ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $19,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT CERTAIN GOLDMAN, SACHS & CO. (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF JANUARY 3, 2017 THROUGH JANUARY 24, 2017 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE IN EXCESS OF APPLICABLE THRESHOLD LEVELS, IN DEEMED VIOLATION OF CHICAGO MERCANTILE EXCHANGE INC. RULE 536.F. Status: Final Sanction Detail: THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 5, 2017. Summary: THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 5, 2017.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NASDAQ PHLX LLC ("PHLX") BUSINESS CONDUCT COMMITTEE ALLEGED THAT DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JANUARY 16, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF PHLX RULES 1003 AND 707; AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF PHLX RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER 23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO AN AGGREGATE FINE IN THE AMOUNT OF $2,500,000 PAYABLE TO PHLX AND THREE OTHER SELF-REGULATORY ORGANIZATIONS, OF WHICH $250,000 WAS PAID BY A SUBMISSION OF A WIRE TO PHLX ON JULY 31, 2017. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WITH THE PHLX BUSINESS CONDUCT COMMITTEE (THE "OFFER OF SETTLEMENT"), WHICH WAS ACCEPTED BY THE PHLX BUSINESS CONDUCT COMMITTEE ON JUNE 26, 2017, AND BECAME FINAL ON JULY 14, 2017. ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $250,000. THE OFFER OF SETTLEMENT WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: BATS BZX EXCHANGE, INC.; NASDAQ ISE, LLC (F/K/A THE INTERNATIONAL SECURITIES EXCHANGE, LLC); AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: C2 OPTIONS EXCHANGE, INCORPORATED ("C2") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT GOLDMAN SACHS EXECUTION & CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), FAILED: (I) FROM ON OR ABOUT MAY 21, 2014 THROUGH ON OR ABOUT JULY 14, 2016, TO QUALIFY AND REGISTER ONE ASSOCIATED PERSON (THE "ASSOCIATED PERSON") IN THE APPROPRIATE CATEGORY OF REGISTRATION WITH C2, AND TO REGISTER THE ASSOCIATED PERSON IN THE PREREQUISITE REGISTRATION CATEGORY WITH C2; AND (II) FROM ON OR ABOUT MAY 21, 2014 THROUGH ON OR ABOUT MARCH 25, 2015, TO REGISTER THE MINIMUM NUMBER OF INDIVIDUALS REQUIRED TO BE REGISTERED AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH C2, EACH IN ALLEGED VIOLATION OF C2 RULE 3.4. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $10,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON SEPTEMBER 20, 2017. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE ON AUGUST 8, 2017. ON SEPTEMBER 13, 2017, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON SEPTEMBER 20, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $10,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT, FROM ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT JULY 14, 2016, GOLDMAN SACHS EXECUTION & CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), FAILED TO QUALIFY AND REGISTER ONE ASSOCIATED PERSON (THE "ASSOCIATED PERSON") IN THE APPROPRIATE CATEGORY OF REGISTRATION WITH CBOE, AND FAILED TO REGISTER THE ASSOCIATED PERSON IN THE PREREQUISITE REGISTRATION CATEGORY WITH CBOE, IN ALLEGED VIOLATION OF CBOE RULE 3.6A. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON SEPTEMBER 20, 2017. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE ON AUGUST 8, 2017. ON SEPTEMBER 13, 2017, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON SEPTEMBER 20, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $5,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ON BEHALF OF NYSE REGULATION ALLEGED THAT GOLDMAN SACHS EXECUTION AND CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 15C3-5 THEREUNDER IN ALLEGED VIOLATION OF NYSE ARCA EQUITIES RULE 6.18. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. Status: Final Sanction Detail: FINRA IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $3,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON MARCH 19, 2019. Summary: FINRA IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $3,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON MARCH 19, 2019.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 31, 2020, THE CME GROUP MARKET REGULATION DEPARTMENT NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT IT HAD COMPLETED ITS INVESTIGATION INTO ALLEGATIONS THAT GSCO VIOLATED EXCHANGE RULE 562. GSCO HELD A PRO-RATA SHARE OF MELLON INVESTMENT CORPORATION'S POSITION EXCESS FOR THREE BUSINESS DAYS ON SEPTEMBER 11, 2019, SEPTEMBER 12, 2019, AND SEPTEMBER 13, 2019, BEFORE IT WAS LIQUIDATED ON SEPTEMBER 16, 2019. THE CME GROUP MARKET REGULATION DEPARTMENT ALLEGES THAT GSCO FAILED TO LIQUIDATE ITS PRO-RATA SHARE IN EXCESS OF LIMITS OR OTHERWISE FAILED TO ENSURE THAT ITS CUSTOMER WAS IN COMPLIANCE WITH LIMITS WITHIN A REASONABLE PERIOD OF TIME. THE ABOVE MATTER HAS NOW BEEN REFERRED TO THE CME GROUP MARKET REGULATION'S ENFORCEMENT DIVISION. ON JUNE 15, 2020, A PANEL OF THE CBOT BUSINESS CONDUCT COMMITTEE ("PANEL") CONCLUDED THAT GSCO HAD VIOLATED CBOT RULE 562. IN ACCORDANCE WITH A SETTLEMENT OFFER THAT BECAME EFFECTIVE ON JUNE 17, 2020, THE PANEL ORDERED GSCO TO PAY A FINE IN THE AMOUNT OF $15,000. GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE FINE WAS PAID IN BY GSCO BY WIRE ON JUNE 26, 2020. Status: Final Sanction Detail: IN ACCORDANCE WITH A SETTLEMENT OFFER THAT BECAME EFFECTIVE ON JUNE 17, 2020, THE PANEL ORDERED GSCO TO PAY A FINE IN THE AMOUNT OF $15,000. GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE FINE WAS PAID IN BY GSCO BY WIRE ON JUNE 26, 2020. Summary: IN ACCORDANCE WITH A SETTLEMENT OFFER THAT BECAME EFFECTIVE ON JUNE 17, 2020, THE PANEL ORDERED GSCO TO PAY A FINE IN THE AMOUNT OF $15,000. GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE FINE WAS PAID IN BY GSCO BY WIRE ON JUNE 26, 2020.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 5, 2021, ICE CLEAR CREDIT LLC ALLEGED THAT DURING MARCH 2021, IN ONE INSTANCE, GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED ICE CLEAR CREDIT RULE 404(B) BY FAILING TO SUBMIT FORTY-FIVE SINGLE NAME PRICES ON A TIMELY BASIS. Status: Final Sanction Detail: ICE CLEAR CREDIT LLC IMPOSED A FINE OF $20,000, WHICH GSCO PAID BY INVOICE IN JUNE 2021. Summary: ICE CLEAR CREDIT LLC IMPOSED A FINE OF $20,000, WHICH GSCO PAID BY INVOICE IN JUNE 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN A NOTICE DATED MAY 26, 2021, ICE FUTURES EUROPE ("ICE") FOUND THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED ICE RULE P.3 BECAUSE A GSCO CLIENT HELD A POSITION OVER THE POSITION LIMIT IN FEBRUARY 2021 WTI CRUDE FUTURES AT THE CLOSE OF BUSINESS ON JANUARY 14, 2021, WITHOUT AN EXEMPTION. Status: Final Sanction Detail: ICE ISSUED A SUMMARY FINE OF EURO 17,500 TO GSCO, WHICH WAS PAID ON JUNE 3, 2021. Summary: ICE ISSUED A SUMMARY FINE OF EURO 17,500 TO GSCO, WHICH WAS PAID ON JUNE 3, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO") SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") THAT WAS ACCEPTED BY THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") AND BECAME FINAL ON MAY 27, 2021. THE AWC RESOLVED ALLEGED VIOLATIONS OF FINRA RULES 7230A(G)(2), 7330(G)(2), AND 2010 DURING VARIOUS TIME PERIODS BETWEEN JANUARY 2015 AND JUNE 2019. THE AWC STATES THAT GSCO FAILED TO REPORT TIMELY OR OVER-REPORTED CERTAIN TRANSACTIONS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY AND OTC REPORTING FACILITY. Status: Final Sanction Detail: ON MAY 27, 2021, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS IN THE AWC, GSCO CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $50,000. GSCO PAID THE FINE BY WIRE SUBMISSION ON JULY 7, 2021. Summary: ON MAY 27, 2021, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS IN THE AWC, GSCO CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $50,000. GSCO PAID THE FINE BY WIRE SUBMISSION ON JULY 7, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: MATTER WAS FINALIZED AND DISCLOSED IN FORM BD AMENDMENTS - SEE OCCURRENCE ID NUMBERS 2207388, 2198938, 2198016, 2198013, 2197898, 2197896, 2197884, 2197741, 2196513, 2196512, 2196511, 2196510, 2193636, 2193625, AND 2193582. PLEASE MOVE DRP TO ARCHIVE. ON DECEMBER 7, 2021, GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM") RECEIVED A NOTICE FROM FINRA'S DEPARTMENT OF ENFORCEMENT, ON BEHALF OF CBOE EXCHANGE, INC. ("CBOE") AND OTHER EXCHANGES. DURING GSCO'S 2019 CYCLE OPTIONS EXAMINATION, THEY IDENTIFIED A POTENTIAL VIOLATION RELATING TO THE FIRM'S FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM RELATED TO THE RECORDING OF TRANSMITTAL TIMES FOR OPTIONS ORDERS MANUALLY ROUTED TO FLOOR BROKERS. Status: Final Sanction Detail: MATTER WAS FINALIZED AND DISCLOSED IN FORM BD AMENDMENTS - SEE OCCURRENCE ID NUMBERS 2207388, 2198938, 2198016, 2198013, 2197898, 2197896, 2197884, 2197741, 2196513, 2196512, 2196511, 2196510, 2193636, 2193625, AND 2193582. PLEASE MOVE DRP TO ARCHIVE. Summary: MATTER WAS FINALIZED AND DISCLOSED IN FORM BD AMENDMENTS - SEE OCCURRENCE ID NUMBERS 2207388, 2198938, 2198016, 2198013, 2197898, 2197896, 2197884, 2197741, 2196513, 2196512, 2196511, 2196510, 2193636, 2193625, AND 2193582. PLEASE MOVE DRP TO ARCHIVE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 17, 2022, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") REVIEWED GOLDMAN SACHS & CO. LLC'S ("GSCO") RISK BASED EXAMINATION REPORT AND THE FIRM'S RESPONSE, AND ISSUED A CHARGE LETTER DATED MARCH 18, 2022, WHICH ALLEGES THAT GSCO VIOLATED CBOT RULE 930.E.3 IN REGARDS TO MAINTAINING SUFFICIENT WRITTEN PERFORMANCE BOND RECORDS. Status: Final Sanction Detail: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $75,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON JULY 25, 2022. Summary: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $75,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON JULY 25, 2022.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF BOX EXCHANGE LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 24, 2023, CBOE BYX EXCHANGE, INC. ("BYX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. Status: Final Sanction Detail: PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BYX IS $89,758, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. Summary: PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BYX IS $89,758, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 4, 2023, THE NASDAQ STOCK MARKET LLC ("NASDAQ") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED NASDAQ'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146502). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NASDAQ IS $381,400, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. Summary: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NASDAQ IS $381,400, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 4, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146501). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO FINRA IS $1,147,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 19, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NASDAQ PHLX LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, AND NYSE ARCA, INC. FOR SIMILAR VIOLATIONS. Summary: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO FINRA IS $1,147,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 19, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NASDAQ PHLX LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, AND NYSE ARCA, INC. FOR SIMILAR VIOLATIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 21, 2023, THE NEW YORK STOCK EXCHANGE LLC ("NYSE" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146507). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE IS $92,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NYSE AMERICAN LLC, NYSE ARCA, INC, INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. Summary: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE IS $92,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NYSE AMERICAN LLC, NYSE ARCA, INC, INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 4, 2023, INVESTORS EXCHANGE LLC ("IEX" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146512). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO IEX IS $141,100, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. Summary: PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO IEX IS $141,100, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JULY 20, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT CME'S 512 COMMITTEE FOUND THAT GSCO VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX TRADE DATES BETWEEN JUNE AND JULY 2022. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $7,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 8, 2022. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $7,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 8, 2022.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON OCTOBER 12, 2023, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO . LLC ("GSCO") VIOLATED CBOT RULE 930. E.3 FOR NOT MAINTAINING ACCURATE WRITTEN RECORDS FOR CERTAIN PERFORMANCE BOND CALLS IN 2022. Status: Final Sanction Detail: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, CME FINED THE FIRM $150,000 AND AGREED TO WAIVE THE FINE IF NO SIMILAR VIOLATION IS FOUND DURING THE NEXT RISK BASED EXAMINATION. Summary: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, CME FINED THE FIRM $150,000 AND AGREED TO WAIVE THE FINE IF NO SIMILAR VIOLATION IS FOUND DURING THE NEXT RISK BASED EXAMINATION.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GS ALLEGEDLY VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD RULES G-12 AND G-14. THE NASDR ALLEGED THAT GS FAILED TO PROVIDE ACCURATE AND/OR TIMELY INFORMATION REGARDING MUNICIPAL SECURITIES TRADES TO THE NATIONAL SECURITIES CLEARING CORPORATION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, GS SIGNED AN AWC AND CONSENTED TO A MAXIMUM OF A $1000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NASD ALLEGED THAT GS VIOLATED NASD MARKETPLACE RULE 6620 AND NASD CONDUCT RULES 2110 AND 3010. THE NASD ALLEGED THAT GS UNTIMELY FILED CERTAIN TRANSACTIONS IN OTC EQUITY SECURITIES ON FORMS T WITH THE NASD AND GS FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO A CENSURE AND A $17,500 FINE (COMPOSED OF A $10,000 FINE FOR THE FORM T VIOLATIONS, A $5,000 FINE FOR THE WRITTEN SUPERVISORY PROCEDURES VIOLATIONS RELATING TO THE REPORTING OF TRANSACTIONS VIA FORM T, AND A $2,500 FINE FOR THE BEST EXECUTION VIOLATIONS).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR FINED GS FOR ALLEGED VIOLATIONS OF NASD CONDUCT RULE 3360. GS ALLEGEDLY FAILED TO REPORT ITS SHORT INTEREST POSITION IN ONE SECURITY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO A $1,000 FINE BY SIGNING AN AWC ON JANUARY 24, 2000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE CHARGED THAT GS ALLEGEDLY VIOLATED EXCHANGE RULE 4.1 BY ENTERING AN ORDER PRIOR TO DISCLOSING THE TERMS AND CONDITIONS OF THE ORIGINAL ORDER TO THE RELEVANT TRADING CROWD, AS REQUIRED BY EXCHANGE RULE 6.9(E) Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS PAID A FINE OF $10,000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CBOE ALLEGED THAT DURING THE PERIOD NOVEMBER 2005 THROUGH MARCH 2006, SLK-HULL DERIVATIVES LLC ("SHD") VIOLATED EXCHANGE RULE 6.13(B)(I)(C)(III) BY ENTERING CERTAIN HYBRID "M" ORDERS ON THE SAME SIDE OF THE MARKET IN VIOLATION OF THE FIVE (5) SECOND TIME LIMITATION FOR SUBMITTING ORDERS ON BEHALF OF THE SAME MARKET MAKER OR ACCOUNT OF THE SAME BENEFICIAL OWNERS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHD CONSENTED TO A CENSURE AND ON AUGUST 21, 2007, PAID A MONETARY PENALTY IN THE AMOUNT OF $15,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHD CONSENTED TO A STIPULATION OF FACTS AND FINDINGS AND SANCTION REQUIRING A CENSURE AND $15,000 MONETARY PENALTY WHICH WAS ACCEPTED BY THE CBOE ON AUGUST 7, 2007. PLEASE NOTE, SHD, CRD NUMBER 46735, FILED FORM BDW ON MARCH 30, 2007 AND WAS MERGED WITH AND INTO GOLDMAN SACHS & CO. (CRD NUMBER 361).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDAQ OMX PHLX, INC. (THE "EXCHANGE") ALLEGED THAT, DURING JANUARY 1, 2003 THROUGH AUGUST 3, 2004, AND DURING NOVEMBER 1, 2005 THROUGH MARCH 26, 2007, SLK-HULL DERIVATIVES LLC ("SHD") FAILED TO EXECUTE CERTAIN INCOMING ORDERS FOR VARIOUS OPTION SERIES AT THE DISSEMINATED PRICE IN AN AMOUNT UP TO THE DISSEMINATED SIZE, IN ALLEGED VIOLATION OF EXCHANGE RULE 1082. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHD CONSENTED TO A FINE IN THE AMOUNT OF $40,000. SHD WILL SUBMIT A CHECK OR WIRE IN PAYMENT OF THE FINE AMOUNT UPON RECEIPT OF THE INVOICE FROM THE EXCHANGE. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SHD SUBMITTED AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WHICH WAS ACCEPTED BY A DECISION OF THE BUSINESS CONDUCT COMMITTEE OF THE EXCHANGE ON FEBRUARY 16, 2010.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MARCH, 2012, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVENTY-TWO SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $40,000, WHICH WAS MADE FINAL ON MAY 21, 2012. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID BY SUBMISSION OF A WIRE ON JUNE 7, 2012. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $40,000, WHICH WAS MADE FINAL ON MAY 21, 2012. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID BY SUBMISSION OF A WIRE ON JUNE 7, 2012.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT NINE (9) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON JULY 3, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2013. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON JULY 3, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF SEPTEMBER, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT EIGHTEEN (18) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON NOVEMBER 4, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON NOVEMBER 20, 2013. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON NOVEMBER 4, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON NOVEMBER 20, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF DECEMBER, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVENTY-TWO (72) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $10,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $10,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2014, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVENTY-TWO (72) SINGLE NAME AND EIGHT (8) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF OF $18,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF OF $18,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF SEPTEMBER, 2014, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT FIFTY-FOUR (54) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). Status: Final Sanction Detail: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $20,000, WHICH WAS FINALIZED BY NOTICE DATED NOVEMBER 12, 2014. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 18, 2014. Summary: ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $20,000, WHICH WAS FINALIZED BY NOTICE DATED NOVEMBER 12, 2014. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 18, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT LLC ("ICC") IMPOSED A PENALTY OF $183,000 ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR FAILURE TO SUBMIT DAILY PRICING INFORMATION OF INDEX AND SINGLE NAME PRODUCTS. Status: Final Sanction Detail: AFTER REVIEWING GSI'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY. Summary: AFTER REVIEWING GSI'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT DURING THE MONTH OF JUNE 2015, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT CERTAIN SINGLE NAME END OF DAY PRICES AND CERTAIN INDEX PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). Status: Final Sanction Detail: ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $127,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE. Summary: ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $127,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: EUREX DEUTSCHLAND INITIATED A SANCTION PROCEEDING AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") AND A GSI SALES TRADER ON 7 NOVEMBER 2019 IN RELATION TO A CROSS TRADE IN THE EUREX PRODUCT EURO BUND FUTURE. EUREX DEUTSCHLAND ALLEGED THE CROSS TRADE WAS IN VIOLATION OF PARAGRAPH 2.6 OF THE CONDITIONS FOR TRADING AT EUREX DEUTSCHLAND. Status: Final Sanction Detail: ON APRIL 23, 2020, EUREX DEUTSCHLAND ISSUED A REPRIMAND AGAINST GSI AND REQUIRED GSI TO BEAR THE COST OF THE REGULATORY PROCEEDING FOR THE AMOUNT OF EUR 2,000. GSI PAID THE EUR 2,000 ON SEPTEMBER 10, 2020. Summary: GSI RESPONDED TO EUREX DEUTSCHLAND ON 2 DECEMBER 2019 SETTING OUT THE FIRM'S POSITION THAT (A) THE TRADE IN QUESTION, WHICH HAD A LEGITIMATE ECONOMIC RATIONALE, WAS INTENDED TO HAPPEN OFF-EXCHANGE USING INTERNAL FLATTENING CONTROLS BUT INSTEAD WAS INADVERTENTLY ROUTED ONTO THE EXCHANGE, (B) THE NAMED SALES TRADER HAD NO INVOLVEMENT IN THE DECISION TO FLATTEN THE TWO POSITIONS INTERNALLY THAT RESULTED IN THE ON-EXCHANGE TRADE AND SO SHOULD BE REMOVED FROM THE SCOPE OF THE PROCEEDINGS, AND (C) THE TRADE DID NOT HAVE ANY MATERIAL IMPACT ON THE MARKET GIVEN THAT THE PRICE OF THE PRODUCT IN QUESTION MOVED BY ONLY EUR 0.01 IN THE MINUTE WHEN THE TRANSACTION TOOK PLACE (A MOVE OF JUST 0.00558%). ON APRIL 23, 2020, EUREX DEUTSCHLAND ISSUED A REPRIMAND AGAINST GSI AND REQUIRED GSI TO BEAR THE COST OF THE REGULATORY PROCEEDING FOR THE AMOUNT OF EUR 2,000 (APPROXIMATELY USD 1683.50). GSI PAID THE EUR 2,000 ON SEPTEMBER 10, 2020.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON NOVEMBER 11, 2020, BLOOMBERG SEF LLC ("BSEF") NOTIFIED GOLDMAN SACHS INTERNATIONAL ("GSI") THAT IT HAD COMPLETED ITS INQUIRY AND CONCLUDED THAT GSI VIOLATED BSEF RULE 531.A(D) BY SUBMITTING BLOCK TRADES TO BSEF MORE THAN 10 MINUTES AFTER THE TIME THE PARTICIPANTS AGREED TO THE TERMS OF THE BLOCK TRADES. AS THIS WAS GSI'S SECOND SUCH VIOLATION WITHIN A 12-MONTH PERIOD, BSEF IMPOSED A FINE OF $1,250. Status: Final Sanction Detail: THE FINE IMPOSED BY BSEF WAS IN THE AMOUNT OF $1,250, WHICH WAS PAID IN FULL BY GSI BY WIRE ON DECEMBER 21, 2020. Summary: THE FINE IMPOSED BY BSEF WAS IN THE AMOUNT OF $1,250, WHICH WAS PAID IN FULL BY GSI BY WIRE ON DECEMBER 21, 2020.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 5, 2021, ICE CLEAR CREDIT LLC ALLEGED THAT DURING MARCH 2021, IN ONE INSTANCE, GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED ICE CLEAR CREDIT RULE 404(B), BY FAILING TO SUBMIT EIGHTY-ONE SINGLE NAME PRICES ON A TIMELY BASIS. Status: Final Sanction Detail: ICE CLEAR CREDIT LLC IMPOSED A FINE OF $40,000, WHICH GSI PAID BY INVOICE IN JUNE 2021. Summary: ICE CLEAR CREDIT LLC IMPOSED A FINE OF $40,000, WHICH GSI PAID BY INVOICE IN JUNE 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: HULL TRADING COMPANY, L.L.C. IS ALLEGED TO HAVE VIOLATED ISE RULE 412 (POSITION LIMITS) Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, HULL TRADING COMPANY, L.L.C. PAID A FINE OF $5,000.00.

Regulatory · Item 11.D(5) as of Nov 19, 2024

Allegations: THE STATE OF ILLINOIS DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION, DIVISION OF BANKING (THE "DEPARTMENT"), ALLEGED THAT: (I) IN ITS APPLICATION TO RENEW ITS RESIDENTIAL MORTGAGE LICENSE FOR 2011 AND 2012, MTGLQ INVESTORS, L.P. ("MTGLQ") SUBMITTED DEFICIENT FINANCIAL STATEMENTS, AND (II) MTGLQ DID NOT RESPOND TO NOTICES FROM THE DEPARTMENT NOTIFYING MTGLQ OF THESE DEFICIENCIES AND CERTAIN ADDITIONAL DEFICIENCIES, NOR DID IT OTHERWISE REMEDY THE NOTED DEFICIENCIES. AS A RESULT THE DEPARTMENT ALLEGED THAT MTGLQ VIOLATED SECTIONS 2-2, 2-4(D) & (T), 2-6, 3-2, 3-5, AND 4-5(I)(11) & (17) OF THE ILLINOIS RESIDENTIAL MORTGAGE LICENSE ACT OF 1987 (THE "ACT") AND SECTIONS 1050.320 AND 1050.430 OF THE RULES PROMULGATED UNDER THE ACT. Status: Final Sanction Detail: ON MAY 23, 2012, THE DEPARTMENT ENTERED AN ORDER REFUSING TO RENEW LICENSE AND ASSESSING FINE (THE "ORDER"). THE DEPARTMENT REFUSED TO RENEW AND DENIED MTGLQ'S RESIDENTIAL MORTGAGE LICENSE RENEWAL FOR 2012, AND ASSESSED A $4,500 FINE AGAINST MTGLQ, WHICH WAS PAID BY SUBMISSION OF A CHECK ON OCTOBER 30, 2012. BY ORDER DATED OCTOBER 26, 2012, THE DEPARTMENT RESCINDED THE PRIOR ORDER, AND ACKNOWLEDGED THAT MTGLQ HAS COMPLETED ITS RESIDENTIAL MORTGAGE LICENSE RENEWAL APPLICATION FOR CALENDAR YEAR 2012 AND IS IN COMPLIANCE WITH THE ACT. Summary: MTGLQ HAS NOT CONDUCTED ANY ACTIVITY REQUIRING THE ILLINOIS LICENSE SINCE MAY 23, 2012 AND REQUESTED THAT THE DEPARTMENT RESCIND THE ORDER AND RENEW ITS LICENSE. BY ORDER DATED OCTOBER 26, 2012, THE DEPARTMENT RESCINDED THE PRIOR ORDER, AND ACKNOWLEDGED THAT MTGLQ HAS COMPLETED ITS RESIDENTIAL MORTGAGE LICENSE RENEWAL APPLICATION FOR CALENDAR YEAR 2012 AND IS IN COMPLIANCE WITH THE ACT.

Regulatory · Item 11.D(5) as of Nov 19, 2024

Allegations: THE STATE OF ILLINOIS DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION, DIVISION OF BANKING (THE "DEPARTMENT"), ALLEGED THAT: (I) IN ITS APPLICATION TO RENEW ITS RESIDENTIAL MORTGAGE LICENSE FOR 2011 AND 2012, MTGLQ INVESTORS, L.P. ("MTGLQ") SUBMITTED DEFICIENT FINANCIAL STATEMENTS, AND (II) MTGLQ DID NOT RESPOND TO NOTICES FROM THE DEPARTMENT NOTIFYING MTGLQ OF THESE DEFICIENCIES AND CERTAIN ADDITIONAL DEFICIENCIES, NOR DID IT OTHERWISE REMEDY THE NOTED DEFICIENCIES. AS A RESULT THE DEPARTMENT ALLEGED THAT MTGLQ VIOLATED SECTIONS 2-2, 2-4(D) & (T), 2-6, 3-2, 3-5, AND 4-5(I)(11) & (17) OF THE ILLINOIS RESIDENTIAL MORTGAGE LICENSE ACT OF 1987 (THE "ACT") AND SECTIONS 1050.320 AND 1050.430 OF THE RULES PROMULGATED UNDER THE ACT. Status: Final Sanction Detail: ON MAY 23, 2012, THE DEPARTMENT ENTERED AN ORDER REFUSING TO RENEW LICENSE AND ASSESSING FINE. THE DEPARTMENT REFUSED TO RENEW AND DENIED MTGLQ'S RESIDENTIAL MORTGAGE LICENSE RENEWAL FOR 2012, AND ASSESSED A $4,500 FINE AGAINST MTGLQ. Summary: MTGLQ HAS NOT CONDUCTED ANY ACTIVITY REQUIRING THE ILLINOIS LICENSE SINCE MAY 23, 2012 AND HAS REQUESTED THE DEPARTMENT TO RESCIND THE ORDER AND RENEW ITS LICENSE.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: MASSACHUSETTS STATE ETHICS COMMISSION ALLEGED THAT CERTAIN GIFTS AND ENTERTAINMENT BY GOLDMAN, SACHS & CO. PERSONNEL VIOLATED THE STATE'S CONFLICT OF INTEREST LAW, G.L. C. 268A, 3 (A) - THE COMMISSION FOUND NO EVIDENCE THAT THE MODEST AMOUNTS INVOLVED WERE INTENDED TO INFLUENCE ANY ACTS BY THE OFFICIALS IN QUESTION. Status: Final Sanction Detail: A DISPOSITION AGREEMENT WAS ENTERED INTO ON JUNE 19, 1997 AND A FINE OF $3,500 WAS PAID BY GS&CO. Summary: ON JUNE 19, 1997, THE MASSACHUSETTS STATE ETHICS COMMISSION AND GOLDMAN, SACHS & CO. ("GS") ENTERED INTO A DISPOSTION AGREEMENT WITH RESPECT TO THE COMMISSION'S ALLEGATIONS THAT CERTAIN GIFTS AND ENTERTAINMENT BY GS PERSONNEL VIOLATED THE STATE'S CONFLICT OF INTEREST LAW, G.L. C. 268A, 3 (A). THE COMMISSION ASSESSED A FINE OF $3,500.00, ALTHOUGH THE COMMISSION EXPRESSLY FOUND NO EVIDENCE THAT THE MODEST AMOUNTS INVOLVED WERE INTENDED TO INFLUENCE ANY ACTS BY THE OFFICIALS IN QUESTION.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") ALLEGED THAT, PRIOR TO SEPTEMBER 1, 2011, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") AND GOLDMAN SACHS BANK USA ("GS BANK") ENGAGED IN A PATTERN OF MISCONDUCT AND NEGLIGENCE RELATING TO DEFICIENT PRACTICES IN RESIDENTIAL MORTGAGE LOAN SERVICING AND FORECLOSURE PROCESSING INVOLVING LITTON LOAN SERVICING LP ("LITTON"), A FORMER SUBSIDIARY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE AMENDED CONSENT, WHICH PROVIDES FOR GS GROUP AND GS BANK TO: (I) MAKE A CASH PAYMENT THAT COLLECTIVELY TOTALS $135 MILLION INTO A QUALIFIED SETTLEMENT FUND (THE "FUND") FROM WHICH PAYMENTS WILL BE MADE PURSUANT TO A DISTRIBUTION PLAN DEVELOPED BY THE FEDERAL RESERVE AND THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (COLLECTIVELY, THE "REGULATORS") FOR DISTRIBUTION BY THE REGULATORS IN THEIR DISCRETION TO CERTAIN ELIGIBLE BORROWERS WHOSE RESIDENTIAL MORTGAGE LOAN ON THEIR PRIMARY RESIDENCE WAS SERVICED BY GS BANK, THROUGH LITTON, AND WHO WERE SUBJECT TO A FORECLOSURE ACTION OR PROCEEDING THAT WAS PENDING OR COMPLETED ANY TIME FROM JANUARY 1, 2009 TO DECEMBER 31, 2010; AND (II) COLLECTIVELY PROVIDE CERTAIN LOSS MITIGATION OR OTHER FORECLOSURE PREVENTION THAT COLLECTIVELY TOTALS $195 MILLION, WITH PREFERENCE GIVEN TO ACTIVITIES DESIGNED TO KEEP BORROWERS IN THEIR HOMES THROUGH AFFORDABLE, SUSTAINABLE AND MEANINGFUL HOME PRESERVATION ACTIONS. ON MARCH 11, 2013, GS GROUP AND GS BANK MADE A CASH PAYMENT INTO THE FUND, AS PROVIDED IN THE AMENDED CONSENT, BY SUBMISSION OF A WIRE IN THE AMOUNT OF $135 MILLION. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE AMENDED CONSENT, WHICH PROVIDES FOR THE TERMINATION OF THE INDEPENDENT FORECLOSURE REVIEW UNDER THE CONSENT AND CALLS FOR GS GROUP AND GS BANK, IN COORDINATION WITH THE 12 OTHER FINANCIAL INSTITUTIONS WITH MORTGAGE LOAN SERVICING OPERATIONS THAT HAVE ALSO AGREED TO AMEND THEIR RESPECTIVE ORDERS, TO ENSURE THAT THE FUND IS ESTABLISHED, FROM WHICH PAYMENTS WILL BE MADE PURSUANT TO A DISTRIBUTION PLAN DEVELOPED BY THE REGULATORS. THE AMENDED CONSENT PROVIDES FOR GS GROUP AND GS BANK TO: (I) MAKE A CASH PAYMENT THAT COLLECTIVELY TOTALS $135 MILLION INTO THE FUND FOR DISTRIBUTION BY THE REGULATORS IN THEIR DISCRETION TO CERTAIN ELIGIBLE BORROWERS WHOSE RESIDENTIAL MORTGAGE LOAN ON THEIR PRIMARY RESIDENCE WAS SERVICED BY GS BANK, THROUGH LITTON, AND WHO WERE SUBJECT TO A FORECLOSURE ACTION OR PROCEEDING THAT WAS PENDING OR COMPLETED ANY TIME FROM JANUARY 1, 2009 TO DECEMBER 31, 2010; (II) COLLECTIVELY PROVIDE CERTAIN LOSS MITIGATION OR OTHER FORECLOSURE PREVENTION THAT COLLECTIVELY TOTALS $195 MILLION, WITH PREFERENCE GIVEN TO ACTIVITIES DESIGNED TO KEEP BORROWERS IN THEIR HOMES THROUGH AFFORDABLE, SUSTAINABLE AND MEANINGFUL HOME PRESERVATION ACTIONS; AND (III) AS APPLICABLE, SUBMIT POLICIES AND PROCEDURES ACCEPTABLE TO THE FEDERAL RESERVE AND SUBMIT CERTAIN REPORTS TO THE FEDERAL RESERVE WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE AMENDED CONSENT. ON MARCH 11, 2013, GS GROUP AND GS BANK MADE A CASH PAYMENT INTO THE FUND, AS PROVIDED IN THE AMENDED CONSENT, BY SUBMISSION OF A WIRE IN THE AMOUNT OF $135 MILLION.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: IN A NOTICE TO GOLDMAN SACHS (INDIA) SECURITIES PRIVATE LIMITED ("GIPL"), THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT GIPL MADE CERTAIN MISLEADING STATEMENTS TO SEBI FOLLOWING THE DEFERRAL OF A QUALIFIED INSTITUTIONAL PLACEMENT OF SECURITIES IN INDIA, IN ALLEGED VIOLATION OF PARAGRAPH 20 OF THE CODE OF CONDUCT FOR MERCHANT BANKERS UNDER THE SEBI (MERCHANT BANKERS) REGULATIONS, 1992. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW, GIPL AGREED TO MAKE A MONETARY PAYMENT TO SEBI IN THE AMOUNT OF 20,80,242 INDIAN RUPEES (INR), WHICH WAS PAID BY SUBMISSION OF A BANK DEMAND DRAFT ON JUNE 19, 2018. WHILE THE ACTUAL PAYMENT WAS MADE IN INDIAN RUPEES, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF INR68.30:USD1 AS OF JUNE 19, 2018, THE EQUIVALENT U.S. DOLLAR VALUE ON JUNE 19, 2018 WAS $30,457.42, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW, GIPL SUBMITTED A SETTLEMENT APPLICATION TO SEBI WHICH WAS ACCEPTED BY SEBI ON JUNE 29, 2018, IN WHICH GIPL AGREED TO MAKE A MONETARY PAYMENT TO SEBI IN THE AMOUNT OF 20,80,242 INDIAN RUPEES (INR), WHICH WAS PAID BY SUBMISSION OF A BANK DEMAND DRAFT ON JUNE 19, 2018.

Regulatory · Item 11.D(4), 11.D(5) as of Nov 19, 2024

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "BOARD OF GOVERNORS") HAS ALLEGED THAT: (A) GOLDMAN, SACHS & CO. ("GSCO") AND THE GOLDMAN SACHS GROUP, INC., (TOGETHER WITH GSCO, THE "FIRM") FAILED TO MONITOR ELECTRONIC MAIL FOR DOCUMENTS CONTAINING CONFIDENTIAL SUPERVISORY INFORMATION; (B) FIRM EMPLOYEES, INCLUDING SENIOR MANAGERS, HAD CONFIDENTIAL SUPERVISORY INFORMATION OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS IN THEIR POSSESSION WITHOUT THE AUTHORIZATION REQUIRED BY LAW; (C) A FIRM EMPLOYEE ENGAGED IN CRIMINAL THEFT OF CONFIDENTIAL SUPERVISORY INFORMATION OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS, AND DISSEMINATED SUCH INFORMATION TO MULTIPLE EMPLOYEES WITHIN THE FIRM; (D) THE FIRM'S PERSONNEL IMPROPERLY USED CONFIDENTIAL SUPERVISORY INFORMATION, INCLUDING CONFIDENTIAL SUPERVISORY INFORMATION RELATING TO INSTITUTIONS OTHER THAN THE FIRM, OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS IN PRESENTATIONS TO ITS CLIENTS AND PROSPECTIVE CLIENTS IN AN EFFORT TO SOLICIT BUSINESS FOR THE FIRM; AND (E) THE FIRM LACKED ADEQUATE POLICIES AND PROCEDURES DESIGNED TO DETECT OR PREVENT THE UNAUTHORIZED DISSEMINATION AND USE OF CONFIDENTIAL SUPERVISORY INFORMATION BELONGING TO THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS. Status: Final Sanction Detail: THE CONSENT ORDER REQUIRED THE FIRM TO PAY A CIVIL MONETARY PENALTY TO THE BOARD OF GOVERNORS IN THE AMOUNT OF $36,300,000, WHICH THE FIRM PAID ON AUGUST 3, 2016. Summary: THE FIRM AND THE BOARD OF GOVERNORS ENTERED INTO A CONSENT ORDER TO CEASE AND DESIST AND ASSESSMENT OF CIVIL MONEY PENALTY ON AUGUST 2, 2016 (THE "CONSENT ORDER"), PURSUANT TO WHICH: (A) WITHIN 30 DAYS OF THE CONSENT ORDER, THE BOARD OF DIRECTORS OF THE FIRM SHALL APPOINT A COMMITTEE COMPRISED OF MEMBERS OF SENIOR MANAGEMENT TO MONITOR AND COORDINATE COMPLIANCE WITH THE PROVISIONS OF THE CONSENT ORDER, WHICH COMMITTEE SHALL MEET QUARTERLY, KEEP DETAILED MINUTES OF EACH MEETING, AND ANNUALLY SUBMIT TO THE BOARD OF GOVERNORS AND THE BOARD OF DIRECTORS OF THE FIRM WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE CONSENT ORDER AND THE RESULTS THEREOF; (B) WITHIN 90 DAYS OF THE CONSENT ORDER, THE FIRM SHALL: (I) SUBMIT TO THE BOARD OF GOVERNORS A WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF THE INTERNAL CONTROLS AND COMPLIANCE FUNCTIONS REGARDING THE IDENTIFICATION, MONITORING, AND CONTROL OF CONFIDENTIAL SUPERVISORY INFORMATION, WHICH PLAN SHALL BE REVIEWED FOR EFFECTIVENESS BY THE FIRM'S INTERNAL AUDIT FUNCTION; (II) SUBMIT TO THE BOARD OF GOVERNORS A WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, FOR THE TRAINING OF ALL APPROPRIATE GSCO PERSONNEL REGARDING THE RESTRICTIONS, CONTROLS AND LEGAL REQUIREMENTS GOVERNING THE USE OF CONFIDENTIAL SUPERVISORY INFORMATION; AND (III) CERTIFY TO THE BOARD OF GOVERNORS THAT ALL DOCUMENTS CONTAINING CONFIDENTIAL SUPERVISORY INFORMATION OF WHICH THE FIRM IS AWARE OR BECOMES AWARE THAT THE FIRM OBTAINED WITHOUT APPROPRIATE REGULATORY AUTHORIZATION HAVE BEEN DE-REFERENCED FROM THE FIRM'S INTERNAL SYSTEMS AND RENDERED INACCESSIBLE BY FIRM PERSONNEL, AND TO THE EXTENT SUCH CONFIDENTIAL SUPERVISORY INFORMATION MAY BE SUBSEQUENTLY BE RESTORED OR RENDERED ACCESSIBLE FOR ANY PURPOSE, THE FIRM SHALL NOTIFY THE BOARD OF GOVERNORS PRIOR TO SUCH INFORMATION BEING RESTORED OR ACCESSIBLE BY FIRM PERSONNEL; (C) THE FIRM SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUAL AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF THE FIRM OR OF ANY AFFILIATE OF THE FIRM WHO, BASED ON THE INVESTIGATIVE RECORD COMPILED BY U.S. AUTHORITIES, HAS DONE ALL OF THE FOLLOWING: (I) PARTICIPATED IN THE ILLEGAL CONDUCT DESCRIBED IN THE CONSENT ORDER; (II) BEEN SUBJECT TO FORMAL DISCIPLINARY ACTION AS A RESULT OF GSCO'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER; AND (III) HAS BEEN SEPARATED FROM OR HAS HAD HIS OR HER EMPLOYMENT TERMINATED BY THE FIRM; AND (D) THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $36,300,000 ON AUGUST 3, 2016.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON FEBRUARY 24, 2021, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY CONCLUDED THAT GOLDMAN SACHS GROUP, INC., GOLDMAN SACHS INTERNATIONAL, AND GOLDMAN SACHS & CO. LLC VIOLATED THE NOTIFICATION REQUIREMENT UNDER SECTION 3-14 OF THE NORWEGIAN SECURITIES TRADING ACT, CF. REGULATION (EU) NO 236/2012 ("SSR") ARTICLE 5, CF. ARTICLE 9, BY NOT NOTIFYING FINANSTILSYNET OF NET SHORT POSITIONS WITHIN THE TIME LIMIT LAID IN ACCORDANCE WITH SSR. Status: Final Sanction Detail: ON FEBRUARY 24, 2021, FINANSTILSYNET IMPOSED A VIOLATION PENALTY OF NOK 350,000 (APPROXIMATELY USD 41,939.27). THE FINE WAS PAID IN FULL BY WIRE SUBMISSION ON JUNE 15, 2021. Summary: ON FEBRUARY 24, 2021, FINANSTILSYNET IMPOSED A VIOLATION PENALTY OF NOK 350,000 (APPROXIMATELY USD 41,939.27). THE FINE WAS PAID IN FULL BY WIRE SUBMISSION ON JUNE 15, 2021.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN AN ORIGINATING NOTICE TO GOLDMAN, SACHS & CO. (THE "FIRM") DATED JUNE 18, 2013, THE BOURSE DE MONTRÉAL INC. (THE "BOURSE") ALLEGED THAT, DURING THE PERIOD FROM DECEMBER 1, 2005 TO JUNE 30, 2012, THE FIRM PROVIDED CERTAIN PERSONNEL ACCESS TO THE ELECTRONIC TRADING SYSTEM OF THE BOURSE WITHOUT HAVING OBTAINED THE PRIOR APPROVAL OF THE BOURSE, IN ALLEGED CONTRAVENTION OF SECTION A) OF ARTICLE 6366 OF THE RULES OF THE BOURSE. Status: Final Sanction Detail: THE FIRM AGREED TO THE PAYMENT OF A FINE IN THE AMOUNT OF CAD$65,000, AS WELL AS AN ADDITIONAL AMOUNT OF CAD$6,500 FOR COSTS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 18, 2014. WHILE THE ACTUAL PAYMENT WAS MADE IN CANADIAN DOLLARS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF CAD$1.1538:USD$1 AS OF DECEMBER 12, 2014, THE EQUIVALENT US DOLLAR VALUE ON DECEMBER 12, 2014 WAS USD$61,969.15, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: ON NOVEMBER 25, 2014, THE DISCIPLINARY COMMITTEE OF THE BOURSE (THE "COMMITTEE") INFORMED THE FIRM OF THE COMMITTEE'S APPROVAL OF AN OFFER OF SETTLEMENT (THE "OFFER OF SETTLEMENT") NEGOTIATED BETWEEN THE STAFF OF THE REGULATORY DIVISION OF THE BOURSE AND THE FIRM. THE COMMITTEE APPROVED THE OFFER OF SETTLEMENT ON NOVEMBER 14, 2014. IN THE OFFER OF SETTLEMENT, THE FIRM AGREED TO THE PAYMENT OF A FINE IN THE AMOUNT OF CAD$65,000, AS WELL AS AN ADDITIONAL AMOUNT OF CAD$6,500 FOR COSTS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 18, 2014. AS INDICATED IN THE COMMITTEE'S APPROVAL OF THE OFFER OF SETTLEMENT, UPON LEARNING OF CERTAIN UNAPPROVED ACCESS TO THE ELECTRONIC TRADING SYSTEM OF THE BOURSE, THE FIRM TOOK CORRECTIVE MEASURES, AND THE BOURSE NOTED THAT THE PROBLEM WAS CORRECTED.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE ICE FUTURES EUROPE ("THE EXCHANGE") CONDUCTED AN INVESTIGATION OF THE FIRM'S PRE- AND POST-TRADE CONTROLS. AS A RESULT OF ITS FINDINGS IN THE INVESTIGATION, THE EXCHANGE ALLEGES THAT THE TIMING AND NATURE OF CERTAIN ORDERS WAS MANIPULATIVE, VIOLATING EXCHANGE RULES A.11.1 (D), E.2.1(B), E.2.2 (A)(VI), (XIII) AND (XIV), E.2.2A AND G.20. Status: Final Sanction Detail: GSCO PAID A TOTAL SETTLEMENT AMOUNT OF £125,000, INCLUSIVE OF A DISCRETIONARY 1/3 DISCOUNT FROM £187,500. GSCO PAID THE £125,000 BY SUBMISSION OF A WIRE ON OCTOBER 2, 2019. WHILE THE ACTUAL PAYMENT WAS MADE IN POUNDS, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 POUND: 1.2313 USD AS OF OCTOBER 2, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 153,912.50 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE EXCHANGE'S ASSERTIONS WERE REFERRED TO THE AUTHORISATION, RULES AND CONDUCT (ARC) COMMITTEE. WITHOUT ADMITTING OR DENYING THE ASSERTIONS, GSCO ENTERED A SETTLEMENT AGREEMENT WITH THE EXCHANGE. ON OCTOBER 4, 2019, THE EXCHANGE ISSUED A DISCIPLINARY NOTICE: SETTLEMENT OF DISCIPLINARY PROCEEDINGS AGAINST GSCO, CONFIRMING THE TERMS OF THE SETTLEMENT WERE 1) ON THE OCCASION DESCRIBED, GSCO HAD NOT ACTED IN COMPLIANCE WITH THE EXCHANGE'S RULES, SPECIFICALLY RULES A.11.1(D), E.2.2(A)(XIII) AND (XIV), AND G.20., AND 2) GSCO PAID A TOTAL SETTLEMENT AMOUNT OF £125,000, INCLUSIVE OF A DISCRETIONARY 1/3 DISCOUNT FROM £187,500. GSCO PAID THE £125,000 BY SUBMISSION OF A WIRE ON OCTOBER 2, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON APRIL 1, 2020, THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY (FINANSINSPEKTIONEN - "SFSA") IMPOSED A FINE ON GOLDMAN SACHS & CO. LLC ("GSCO") IN THE AMOUNT OF 315,000 SWEDISH KRONA (SEK). SFSA ALLEGES A VIOLATION OF CHAPTER 4 OF THE FINANCIAL INSTRUMENTS TRADING ACT (SFS 1991:1980), IN RELATION TO A LATE DISCLOSURE OF CHANGES IN MAJOR HOLDINGS OF SHARES IN MICRONIC AB BETWEEN JUNE AND SEPTEMBER OF 2017. Status: Final Sanction Detail: GSCO PAID THE FINE OF 315,000 SEK ON JUNE 8, 2020 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 USD: 9.2138 SEK AS OF JUNE 8, 2020, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 34,187.85 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GSCO PAID THE FINE OF 315,000 SEK ON JUNE 8, 2020 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 USD: 9.2138 SEK AS OF JUNE 8, 2020, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 34,187.85 USD.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FSC ALLEGED THAT DURING THE PERIOD FEBRUARY 2007 THROUGH MAY 2007 (PRIOR TO ITS ACQUISITION BY GSAM), MIM VIOLATED ARTICLES 96 AND 97 OF THE INDIRECT INVESTMENT ASSET MANAGEMENT BUSINESS ACT AND ARTICLE 85 OF THE ENFORCEMENT DECREE OF THE INDIRECT INVESTMENT ASSET MANAGEMENT BUSINESS ACT. THE ALLEGED VIOLATIONS AROSE FROM CERTAIN ACCOUNTING ERRORS, WHICH WERE DISCOVERED AND CORRECTED BY MIM (INCLUDING REIMBURSEMENTS TO INVESTORS AND MANAGED FUNDS WHEN WARRANTED), THAT RESULTED IN THE MISCALCULATION OF NET ASSET VALUES OF CERTAIN FUNDS ADVISED BY MIM. Status: Final Sanction Detail: GSAMK WAS REQUIRED TO IMPROVE ITS INTERNAL CONTROLS RELATING TO THE CALCULATION OF NET ASSET VALUE AND TO TAKE CERTAIN ACTION (IN THE FORM OF A 3-MONTH SALARY REDUCTION) AGAINST TWO EMPLOYEES AND THE DISMISSAL OF ONE EMPLOYEE WHO HAD PREVIOUSLY RESIGNED. GSAMK WAS REQUIRED TO REPORT TO THE FINANCIAL SUPERVISORY SERVICE THE RESULTS OF ITS COMPLIANCE BY THE END OF DECEMBER 2007. Summary: GSAMK AMENDED ITS INTERNAL CONTROLS WITH REGARD TO CALCULATING NET ASSET VALUE AND IMPLEMENTED THE OTHER REQUIREMENTS OF THE INSTITUTIONAL WARNING.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON APRIL 11, 2011, THE CENTRAL BANK OF IRELAND (THE "CENTRAL BANK") PROVIDED GOLDMAN SACHS BANK (EUROPE) P.L.C. ("GSBE") A NOTICE OF COMMENCEMENT OF EXAMINATION (THE "NOTICE"), PURSUANT TO PART IIIC OF THE IRISH CENTRAL BANK ACT OF 1942 (THE "ACT"), IN CONNECTION WITH CENTRAL BANK CONCERNS THAT GSBE MAY HAVE COMMITTED CERTAIN PRESCRIBED CONTRAVENTIONS FOR THE PURPOSE OF SECTION 33AO(1) OF THE ACT. THE PRESCRIBED CONTRAVENTIONS CITED BY THE CENTRAL BANK ARE THAT FROM IN OR AROUND DECEMBER 2008 TO OCTOBER 2010, GSBE FAILED: (I) TO HAVE OR TO IMPLEMENT, ANY, OR ANY EFFECTIVE, PROCESSES TO IDENTIFY, MANAGE, MONITOR OR REPORT THE COUNTERPARTY RISKS IT WAS OR MIGHT HAVE BEEN EXPOSED TO, IN ALLEGED CONTRAVENTION OF REGULATION 16(3)(B) OF THE EUROPEAN COMMUNITIES (LICENSING AND SUPERVISION OF CREDIT INSTITUTIONS) REGULATIONS 1992 (THE "REGULATIONS"), AND (II) TO HAVE OR MAINTAIN ANY OR ADEQUATE INTERNAL CONTROL MECHANISM TO IDENTIFY THAT THE CAPITAL ADEQUACY TRACKING SYSTEM-COUNTERPARTY RISK REQUIREMENT APPLICATION WAS INCORRECTLY CALCULATING THE REGULATORY CAPITAL REQUIREMENTS, IN ALLEGED CONTRAVENTION OF REGULATION 16(3)(C) OF THE REGULATIONS. Status: Final Sanction Detail: GSBE AGREED TO THE PAYMENT OF A MONETARY PENALTY TO THE CENTRAL BANK IN THE AMOUNT OF 160,000.00 EUROS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 14, 2011. WHILE THE ACTUAL PAYMENT WAS MADE IN EUROS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF 1EURO:US$1.3710 AS OF SEPTEMBER 14, 2011, THE EQUIVALENT US DOLLAR VALUE ON SEPTEMBER 14, 2011 WAS US$219,360.00, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: ON SEPTEMBER 8, 2011, GSBE ENTERED INTO A SETTLEMENT AGREEMENT (THE "SETTLEMENT AGREEMENT") WITH THE CENTRAL BANK IN RELATION TO BREACHES OF THE REGULATIONS, RELATING TO GSBE'S FAILURE, DURING THE PERIOD FROM JULY 16, 2008 TO DECEMBER 17, 2010, TO COMPLY WITH: (I) REGULATION 16(3)(B) OF THE REGULATIONS, IN THAT GSBE'S PROCESSES FAILED TO MANAGE, MONITOR AND REPORT ACCURATELY ITS REGULATORY COUNTERPARTY RISK CAPITAL REQUIREMENT, AND (II) REGULATION 16(3)(C) OF THE REGULATIONS, IN THAT GSBE'S INTERNAL CONTROL MECHANISM FAILED TO IDENTIFY THAT ITS REGULATORY COUNTERPARTY RISK CAPITAL REQUIREMENT WAS INCORRECTLY CALCULATED. GSBE AGREED TO A REPRIMAND AND TO THE PAYMENT OF A MONETARY PENALTY TO THE CENTRAL BANK IN THE AMOUNT OF 160,000.00 EUROS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 14, 2011. THE SETTLEMENT AGREEMENT SPECIFICALLY STATES THAT THE ERROR AT ISSUE DID NOT RESULT IN ANY BREACH OF THE CAPITAL ADEQUACY RATIOS AND NO COUNTERPARTIES WERE IMPACTED AND THAT, IN DECIDING THE APPROPRIATE PENALTY TO IMPOSE, THE CENTRAL BANK TOOK INTO ACCOUNT: (I) THE REGULATORY CAPITAL MAINTAINED BY GSBE BETWEEN JULY 16, 2008 TO DECEMBER 17, 2010 WAS AT ALL TIMES IN EXCESS OF ITS CAPITAL REQUIREMENTS, (II) GSBE SELF REPORTED THE ISSUE TO THE CENTRAL BANK AND HAS TAKEN APPROPRIATE REMEDIAL STEPS TO RECTIFY THE BREACHES AND (III) THE COOPERATION OF GSBE DURING THE INVESTIGATION AND IN SETTLING AT AN EARLY STAGE IN THE ADMINISTRATIVE SANCTIONS PROCEDURE. THE CENTRAL BANK CONFIRMS THAT THE MATTER IS CLOSED.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN AN ORIGINATING NOTICE TO GOLDMAN SACHS INTERNATIONAL ("GSI") DATED JUNE 28, 2011, AND RECEIVED BY GSI ON JULY 1, 2011, THE BOURSE DE MONTRÉAL INC. (THE "BOURSE") ALLEGED THAT, DURING THE PERIOD FROM MAY 27, 2008 TO NOVEMBER 2, 2010, GSI PROVIDED CERTAIN PERSONNEL ACCESS TO THE ELECTRONIC TRADING SYSTEM OF THE BOURSE WITHOUT HAVING OBTAINED THE PRIOR APPROVAL OF THE BOURSE, IN ALLEGED CONTRAVENTION OF SECTION A) OF ARTICLE 6366 OF THE RULES OF THE BOURSE. Status: Final Sanction Detail: GSI AGREED TO PAY A FINE IN THE AMOUNT OF CAD$50,000, AS WELL AS AN ADDITIONAL AMOUNT OF CAD$2,500 FOR COSTS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 22, 2011. WHILE THE ACTUAL PAYMENT WAS MADE IN CANADIAN DOLLARS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF CAD$1.0327:USD$1 AS OF SEPTEMBER 22, 2011, THE EQUIVALENT US DOLLAR VALUE ON SEPTEMBER 22, 2011 WAS USD$50,837.61, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: BY WAY OF AN OFFER OF SETTLEMENT APPROVED ON AUGUST 30, 2011 BY THE SPECIAL COMMITTEE - REGULATORY DIVISION OF THE BOURSE, GSI AGREED TO PAY A FINE IN THE AMOUNT OF CAD$50,000, AS WELL AS AN ADDITIONAL AMOUNT OF CAD$2,500 FOR COSTS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 22, 2011. AS INDICATED IN A CIRCULAR PUBLISHED BY THE BOURSE ON SEPTEMBER 7, 2011: (I) GSI DID NOT HAVE ANY PRIOR DISCIPLINARY RECORD WITH THE BOURSE, AND PROVIDED THE BOURSE WITH FULL COOPERATION THROUGHOUT ITS INQUIRIES AND (II) GSI'S ACTIONS DID NOT RESULT IN ANY HARM OR FINANCIAL LOSS TO CUSTOMERS OR TO OTHER APPROVED PARTICIPANTS, NOR DID IT GIVE RISE TO A FINANCIAL GAIN TO GSI OR ITS EMPLOYEES.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A CONTRAVENTION NOTICE DATED AUGUST 12, 2011 (THE "NOTICE"), THE AUSTRALIAN SECURITIES EXCHANGE ("ASX") ALLEGED THAT, DURING THE PERIOD FROM NOVEMBER 4, 2009 TO AUGUST 6, 2010 (THE "RELEVANT CONTRAVENTION PERIOD"), (I) GOLDMAN SACHS AUSTRALIA PTY LTD ("GS AUSTRALIA", FORMERLY KNOWN AS GOLDMAN SACHS & PARTNERS AUSTRALIA PTY LTD) CONTRAVENED ASX MARKET RULE 7.11.1 BY FAILING TO COMPLY WITH THE RELEVANT PROVISIONS OF THE AUSTRALIAN CORPORATIONS ACT (AND ITS ACCOMPANYING REGULATIONS) GOVERNING THE KEEPING AND TREATMENT OF MONEY PAID, OR PROPERTY GIVEN, TO GS AUSTRALIA IN CONNECTION WITH SERVICES PROVIDED TO, OR PRODUCTS HELD BY, CLIENTS OF GS AUSTRALIA, AND (II) GS AUSTRALIA CONTRAVENED ASX MARKET RULE 7.11.10 BY FAILING TO PERFORM A RECONCILIATION IN RELATION TO THE RELEVANT TRUST ACCOUNT IN THE TIME, FORM AND MANNER REQUIRED BY THE ASX. Status: Final Sanction Detail: ON DECEMBER 14, 2011, THE ASX DISCIPLINARY TRIBUNAL (THE "TRIBUNAL") IMPOSED OF A FINE OF AU$50,000, PLUS TAX, WHICH AMOUNT WILL BE PAID UPON RECEIPT OF AN INVOICE FROM ASX. WHILE THE ACTUAL PAYMENT WILL BE MADE IN AUSTRALIAN DOLLARS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF AU$1:US$0.9904 AS OF DECEMBER 14, 2011, THE EQUIVALENT US DOLLAR VALUE ON DECEMBER 14, 2011 WAS US$49,520.00, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE Summary: THE ALLEGED CONTRAVENTIONS WERE REFERRED TO THE TRIBUNAL FOR DETERMINATION. ON DECEMBER 14, 2011, THE TRIBUNAL DETERMINED THAT GS AUSTRALIA CONTRAVENED ASX MARKET RULES 7.11.1 AND 7.11.10 DURING THE RELEVANT CONTRAVENTION PERIOD IN THE MANNER ALLEGED IN THE NOTICE, AND IMPOSED OF A FINE OF AU$50,000, PLUS TAX. IN DETERMINING THE PENALTY, THE TRIBUNAL TOOK INTO ACCOUNT THAT: (I) GS AUSTRALIA HAS PREVIOUS DISCIPLINARY HISTORY, NOT WITHSTANDING THAT GS AUSTRALIA HAS NO DISCIPLINARY HISTORY REGARDING THE MATTERS RELEVANT TO THE MISCONDUCT; (II) THE RELEVANT CONDUCT HAD THE POTENTIAL TO DAMAGE THE REPUTATION AND INTEGRITY OF THE ASX AND THE MARKET AND FACILITIES IT OPERATES; (III) THE MISCONDUCT WAS SELF-REPORTED IN A TIMELY AND COMPREHENSIVE MANNER; (IV) GS AUSTRALIA FULLY CO-OPERATED WITH ASX IN RELATION TO THE CONDUCT OF ITS INVESTIGATION INTO THE CONTRAVENTIONS; (V) GS AUSTRALIA AGREED AT THE EARLIEST OPPORTUNITY NOT TO CONTEST THE CONTRAVENTIONS; (VI) THE MISCONDUCT WAS UNINTENTIONAL AND IN A NUMBER OF CASES THE CONDUCT WAS THE RESPONSIBILITY OF AN UNRELATED THIRD PARTY; (VII) AT NO STAGE WAS ANY MARKET TRANSACTION NOT ENABLED BECAUSE OF THE MISCONDUCT; (VIII) THERE WAS NO COMMERCIAL ADVANTAGE OR FINANCIAL BENEFIT OBTAINED BECAUSE OF THE MISCONDUCT; (IX) THERE WERE NO LOSSES SUFFERED BY CLIENTS, OR COMPENSATION CLAIMS OR COMPLAINTS MADE BY CLIENTS IN RELATION TO THE CONTRAVENTIONS AND (X) GS AUSTRALIA PROMPTLY IMPLEMENTED REMEDIAL MEASURES TO SEEK TO PREVENT ANY RECURRENCE OF THE CONTRAVENING CONDUCT.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS CONFEDERATION ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") WAS LATE IN PUBLISHING A DROP BELOW A NOTIFIABLE THRESHOLD IN THE FIRM'S HOLDINGS IN A QUALIFIED INTEREST IN CERTAIN SECURITIES IN THE PERIOD BETWEEN SEPTEMBER 25, 2012, AND DECEMBER 20, 2012, IN ALLEGED INFRINGEMENT OF ARTICLE 41 OF THE SWISS FEDERAL ACT ON STOCK EXCHANGES AND SECURITIES TRADING (SESTA). Status: Final Sanction Detail: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GSI CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON NOVEMBER 4, 2014. WHILE THE ACTUAL PAYMENT WAS MADE IN SWISS FRANCS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF CHF1:USD0.9596 AS OF NOVEMBER 4, 2014, THE EQUIVALENT U.S. DOLLAR VALUE ON NOVEMBER 4, 2014 WAS $20,842.02, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GSI ENTERED INTO A SETTLEMENT AGREEMENT WITH FDF ON OCTOBER 27, 2014, AND CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON NOVEMBER 4, 2014.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS FUTURES PTE LTD. (A SUBSIDIARY OF GOLDMAN SACHS & CO.) FAILED TO IMPOSE MARGINS ON ONE CUSTOMER, VIOLATING SGX-DT RULE 822-CUSTOMER MARGINS, SGX-DT RULE 415(F)-FAILURE TO PROVIDE INFORMATION IN GSFS'S MONTHLY SUBMISSION OF ITS CREDIT FACILITIES OBTAINED FROM FINANCIAL INSTITUTIONS, AND SGX-DT RULE 3500-FAILURE TO OBTAIN A DATED DISCLAIMER STATEMENT FROM ONE CUSTOMER ON SGX-DT MSCI TAIWAN STOCK INDEX FUTURES. Status: Final Sanction Detail: A 250 SINGAPORE DOLLAR FINE WAS IMPOSED FOR VIOLATION OF SGX-DT RULE 822. THERE WERE NO FINES IMPOSED FOR VIOLATIONS OF RULES SGX-DT RULE 415(F) AND SGX-DT RULE 3500. Summary: GOLDMAN SACHS FUTURES PTE LTD. (A SUBSIDIARY OF GOLDMAN SACHS & CO.) FAILED TO IMPOSE MARGINS ON ONE CUSTOMER, VIOLATING SGS-DT RULE 822-CUSTOMER MARGINS, SGX-DT RULE 415(F)-FAILURE TO PROVIDE INFORMATION IN GSFS'S MONTHLY SUBMISSION OF ITS CREDIT FACILITIES OBTAINED FROM FINANCIAL INSTITUTIONS, AND SGX-DT RULE 3500-FAILURE TO OBTAIN A DATED DISCLAIMER STATEMENT FROM ONE CUSTOMER ON SGX-DT MSCI TAIWAN STOCK INDEX FUTURES.A 250 SINGAPORE DOLLAR FINE WAS IMPOSED FOR VIOLATION OF SGX-DT RULE 822. THERE WERE NO FINES IMPOSED FOR VIOLATIONS OF RULES SGX-DT RULE 415(F) AND SGX-DT RULE 3500.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FÜR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") OF THE OWNERSHIP THRESHOLD NOTIFICATION REQUIREMENTS OF SECTIONS 21, 25 AND 25A OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG"). Status: Final Sanction Detail: BAFIN IMPOSED A MONETARY PENALTY ON GSI OF 1,107,503.50 EUROS IN THE AGGREGATE, REPRESENTING AN ADMINISTRATIVE FINE OF 1,100,000 EUROS AND PROCEDURAL EXPENSES OF 7,503.50 EUROS, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN EUROS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF EUR1:USD1.1002 AS OF DECEMBER 11, 2015, THE EQUIVALENT US DOLLAR VALUE ON DECEMBER 11, 2015 WAS $1,218,475.35, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: BAFIN IMPOSED A MONETARY PENALTY ON GSI OF 1,107,503.50 EUROS IN THE AGGREGATE, REPRESENTING AN ADMINISTRATIVE FINE OF 1,100,000 EUROS AND PROCEDURAL EXPENSES OF 7,503.50 EUROS, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A LETTER TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") DATED FEBRUARY 16, 2017, THAT WAS RECEIVED BY HAND DELIVERY ON FEBRUARY 22, 2017, FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING A DELAY OF MORE THAN THREE DAYS IN PROVIDING THE CMA WITH THE CERTAIN ACCOUNT INFORMATION REQUIRED BY VIRTUE OF CMA CIRCULAR NO. S/6/6/9214/16, DATED DECEMBER 6, 2016, IN ALLEGED VIOLATION OF SECTION (A) OF ARTICLE 3 OF THE AUTHORIZED PERSONS REGULATIONS. Status: Final Sanction Detail: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MARCH 1, 2017. WHILE THE ACTUAL PAYMENT WAS MADE IN SAUDI ARABIAN RIYALS, USING THE FOREIGN EXCHANGE SPOT RATE OF SAR1:USD0.266666 AS OF MARCH 1, 2017, THE EQUIVALENT U.S. DOLLAR VALUE ON MARCH 1, 2017 WAS US$2,666.67, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MARCH 1, 2017.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON MAY 2, 2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FÜR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") HAS ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") IN MAY 2016 OF SECTIONS 21(1) AND 25(1) OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG") AS A RESULT OF GSI'S LATE SUBMISSION OF A SHAREHOLDER VOTING RIGHTS NOTIFICATION. ON AUGUST 12, 2019 BAFIN IMPOSED AN ADMINISTRATIVE FINE ON GSI IN THE AMOUNT OF 800,000 EUROS FOR A BREACH OF SECTION 130(1) OF THE GERMAN ACT OF BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTION 25(1) OF THE GERMAN SECURITIES TRADING ACT. THIS FINE CONCLUDED CASES WA 17-WP 3121-2017/0003 AND WA 17-WP 3120-2016/0060. Status: Final Sanction Detail: THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUROS (EUR), WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN EUROS, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF EUR 1: USD 1.1025 AS OF SEPTEMBER 4, 2019, THE EQUIVALENT U.S. DOLLAR VALUE ON SEPTEMBER 4, 2019 WAS APPROXIMATELY $882,000, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON SEPTEMBER 19, 2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FÜR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") HAS ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") IN MARCH 2017 OF SECTIONS 21(1) AND 25(1) OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG") AS A RESULT OF GSI'S LATE SUBMISSION OF A SHAREHOLDER VOTING RIGHTS NOTIFICATION. ON AUGUST 12, 2019 BAFIN IMPOSED AN ADMINISTRATIVE FINE ON GSI IN THE AMOUNT OF 800,000 EUROS FOR A BREACH OF SECTION 130(1) OF THE GERMAN ACT OF BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTION 25(1) OF THE GERMAN SECURITIES TRADING ACT. THIS FINE CONCLUDED CASES WA 17-WP 3121-2017/0003 AND WA 17-WP 3120-2016/0060. Status: Final Sanction Detail: THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUROS (EUR), WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN EUROS, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF EUR 1: USD 1.1025 AS OF SEPTEMBER 4, 2019, THE EQUIVALENT U.S. DOLLAR VALUE ON SEPTEMBER 4, 2019 WAS APPROXIMATELY $882,000, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: A BREACH OF ORGANIZATIONAL DUTIES BY FORWARDING UNFLAGGED ORDERS TRANSMITTED BY ONE OF OUR CUSTOMERS VIA DIRECT ELECTRONIC ACCESS TO THE XETRA TRADING PLATFORM OF THE FRANKFURT STOCK EXCHANGE. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 3 (1) OF THE CONDITIONS FOR BUSINESS TRANSACTIONS. A FURTHER BREACH OF THE ORGANIZATIONAL DUTIES OF THE PARTY AS THE INDIRECT TRADING PARTICIPANT WERE NOT AWARE OF THE FWB'S CROSS-TRADE RULES SHOWS THAT THE PARTY DID NOT INFORM OR ONLY INADEQUATELY INFORMED ITS CUSTOMER OF THE FWB'S STOCK EXCHANGE RULES. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 37 (3) OF THE EXCHANGE RULES FOR THE FRANKFURTER WERTPAPIERBÖRSE. Status: Final Sanction Detail: THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUROS (EUR), WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN EUROS, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 EUR: 1.1149 USD AS OF MAY 31, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 3,344.70 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: A BREACH OF ORGANIZATIONAL DUTIES BY FORWARDING UNFLAGGED ORDERS TRANSMITTED BY ONE OF OUR CUSTOMERS VIA DIRECT ELECTRONIC ACCESS TO THE XETRA TRADING PLATFORM OF THE FRANKFURT STOCK EXCHANGE. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 3 (1) OF THE CONDITIONS FOR BUSINESS TRANSACTIONS. A FURTHER BREACH OF THE ORGANIZATIONAL DUTIES OF THE PARTY AS THE INDIRECT TRADING PARTICIPANT WERE NOT AWARE OF THE FWB'S CROSS-TRADE RULES SHOWS THAT THE PARTY DID NOT INFORM OR ONLY INADEQUATELY INFORMED ITS CUSTOMER OF THE FWB'S STOCK EXCHANGE RULES. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 37 (3) OF THE EXCHANGE RULES FOR THE FRANKFURTER WERTPAPIERBÖRSE. Status: Final Sanction Detail: THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUROS (EUR), WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN EUROS, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 EUR: 1.1149 USD AS OF MAY 31, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 3,344.70 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: AKK - ÁLLAMADÓSSÁG KEZELO KÖZPONT ZÁRTKÖRUEN MUKÖDO RÉSZVÉNYTÁRSASÁG ALLEGED THAT DURING THE FIRST HALF OF THE CALENDAR YEAR 2019, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. Status: Final Sanction Detail: AKK - ÁLLAMADÓSSÁG KEZELO KÖZPONT ZÁRTKÖRUEN MUKÖDO RÉSZVÉNYTÁRSASÁG ALLEGED THAT DURING THE FIRST HALF OF THE CALENDAR YEAR 2019, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. Summary: THE AKK IMPOSED A FINE ON GSI IN THE AMOUNT OF HUF 500,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 1, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON SEPTEMBER 20, 2019 THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY (FINANSINSPEKTIONEN - "SFSA") IMPOSED AN ADMINISTRATIVE FINE ON GOLDMAN SACHS GROUP, INC. ("GS GROUP") IN THE AMOUNT OF 70,000 SWEDISH KRONA (SEK) (APPROXIMATELY USD 7,200). SFSA ALLEGES A VIOLATION BY GS GROUP OF CHAPTER 6, SECTION 3 A, SUBSECTION 1 OF THE FINANCIAL INSTRUMENTS TRADING ACT DUE TO A DELAY IN NOTIFYING A RELEVANT CHANGE IN GS GROUP'S HOLDING OF SHARES AND OTHER FINANCIAL INSTRUMENTS IN FINGERPRINT CARDS AB. Status: Final Sanction Detail: GS GROUP PAID THE FINE OF 70,000 SEK ON DECEMBER 19, 2019 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, BASED ON THE FOREIGN EXCHANGE RATE OF 1 USD: 9.4211 SEK AS OF DECEMBER 19, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 7,430.13 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GS GROUP PAID THE FINE OF 70,000 SEK ON DECEMBER 19, 2019 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, BASED ON THE FOREIGN EXCHANGE RATE OF 1 USD: 9.4211 SEK AS OF DECEMBER 19, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 7,430.13 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON AUGUST 19, 2020, GOLDMAN SACHS MEXICO, S.A. DE C.V. CASA DE BOLSA ("MCBO") RECEIVED A FINE IMPOSED BY THE NATIONAL BANKING AND SECURITIES COMMISSION (COMISION NACIONAL BANCARIA Y DE VALORES - "CNBV") OF 403,000 PESOS (APPROXIMATELY 18,500 USD), FOR AN ALLEGED VIOLATION OF ARTICLE 212, PARAGRAPH ONE, SUB-SECTION I, OF THE LMV. CNBV ALLEGED MCBO FAILED TO MAINTAIN AN APPROPRIATE FINANCIAL CRIMES RISK ASSESSMENT POLICY. MCBO PAID THE FINE OF 403,000 PESOS ON SEPTEMBER 29, 2020. AN ADMINISTRATIVE AND A JUDICIAL APPEAL WERE FILED, LEADING ULTIMATELY ON MARCH 2022 TO A RESOLVE OF THIS MATTER IN FAVOR OF MCBO. THE PENALTY IMPOSED BY THE CNBV WAS ANNULLED, AND MCBO OBTAINED A REFUND IN THE UPDATED AMOUNT (BASED ON INFLATION INDEX) OF 440,842 PESOS (APPROXIMATELY 20,700 USD). Status: Final Sanction Detail: MCBO PAID THE FINE OF 403,000 PESOS ON SEPTEMBER 29, 2020. AN ADMINISTRATIVE AND A JUDICIAL APPEAL WERE FILED, LEADING ULTIMATELY ON MARCH 2022 TO A RESOLVE OF THIS MATTER IN FAVOR OF MCBO. THE PENALTY IMPOSED BY THE CNBV WAS ANNULLED, AND MCBO OBTAINED A REFUND IN THE UPDATED AMOUNT (BASED ON INFLATION INDEX) OF 440,842 PESOS (APPROXIMATELY 20,700 USD). Summary: MCBO PAID THE FINE OF 403,000 PESOS ON SEPTEMBER 29, 2020. AN ADMINISTRATIVE AND A JUDICIAL APPEAL WERE FILED, LEADING ULTIMATELY ON MARCH 2022 TO A RESOLVE OF THIS MATTER IN FAVOR OF MCBO. THE PENALTY IMPOSED BY THE CNBV WAS ANNULLED, AND MCBO OBTAINED A REFUND IN THE UPDATED AMOUNT (BASED ON INFLATION INDEX) OF 440,842 PESOS (APPROXIMATELY 20,700 USD).

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: EUREX DEUTSCHLAND INTITIATED SANCTION PROCEEDINGS AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") AND A GSI SALES TRADER ON APRIL 20, 2021 IN RELATION TO FOUR REQUESTS FOR CROSS IN THE EUREX PRODUCT ADIDAS DEC23 WITHOUT SUBSEQUENT ENTRY OR A CORRESPONDING TRADE OR ORDER. EUREX DEUTSCHLAND ALLEGES THAT SUBMISSION OF THE CROSS REQUESTS WAS IN VIOLATION OF NUMBER 2.6 OF THE EXCHANGE RULES OF EUREX DEUTSCHLAND. Status: Final Sanction Detail: EUREX DEUTSCHLAND INITITATED SANCTION PROCEEDINGS AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") ON APRIL 20, 2021 AND ISSUED A SUMMARY FINE OF EURO 1,000 (APPROXIMATELY USD 854.55) TO GSI, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 18, 2021. Summary: EUREX DEUTSCHLAND INITITATED SANCTION PROCEEDINGS AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") ON APRIL 20, 2021 AND ISSUED A SUMMARY FINE OF EURO 1,000 (APPROXIMATELY USD 854.55) TO GSI, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 18, 2021.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. ("GS BRAZIL"), GOLDMAN SACHS INTERNATIONAL ("GSI"), AND DANIEL MOTTA CAMARGO SILVA, A DIRECTOR OF THE TRADING DESK (FICC) OF GS BRAZIL, SUBMITTED A SETTLEMENT PROPOSAL THAT WAS ACCEPTED BY THE COMISSAO DE VALORES MOBILIARIOS ("CVM") BOARD OF COMMISSIONERS. THE SETTLEMENT RESOLVED ALLEGATIONS THAT BETWEEN JANUARY 1, 2018 AND DECEMBER 31, 2019, GSI AND GS BRAZIL CREATED ARTIFICIAL CONDITIONS OF DEMAND, OFFER, OR PRICE BY CROSSING IN THE BRAZILIAN EXCHANGE DI X US DOLLAR SPREAD FUTURES IN VIOLATION OF CVM INSTRUCTION N. 08/79. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS BRAZIL, GSI, AND MR. SILVA ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2021 WITH THE CVM FOR A TOTAL AMOUNT OF BRAZILIAN REAIS 7,480,000 (APPROXIMATELY USD 1,454,941.55), WHICH WAS PAID BY A WIRE SUBMISSION ON AUGUST 5, 2021. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS BRAZIL, GSI, AND MR. SILVA ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2021 WITH THE CVM FOR A TOTAL AMOUNT OF BRAZILIAN REAIS 7,480,000 (APPROXIMATELY USD 1,454,941.55), WHICH WAS PAID BY A WIRE SUBMISSION ON AUGUST 5, 2021.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON JUNE 16, 2021, THE SWISS FEDERAL DEPARTMENT OF FINANCE CONCLUDED THEIR ADMINISTRATIVE CRIMINAL INVESTIGATION AND DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED THE DISCLOSURE REQUIREMENTS OF ARTICLE 151 AND ARTICLE 134 OF THE FINANCIAL MARKET INFRASTRUCTURES ACT, BY SUBMITTING LATE NOTICES FOR TWELVE TRANSACTIONS EXECUTED DURING AN ONGOING TENDER OFFER OF A SWISS ISSUER. Status: Final Sanction Detail: THE SWISS FEDERAL DEPARTMENT OF FINANCE ISSUED A FINE OF CHF 3640 (APPROXIMATELY USD 3997.76) WHICH WAS PAID BY A SUBMISSION OF A WIRE ON NOVEMBER 10, 2021. Summary: THE SWISS FEDERAL DEPARTMENT OF FINANCE ISSUED A FINE OF CHF 3640 (APPROXIMATELY USD 3997.76) WHICH WAS PAID BY A SUBMISSION OF A WIRE ON NOVEMBER 10, 2021.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: THE CZECH NATIONAL BANK ("CNB") ISSUED AN ORDER ALLEGING THAT THE GOLDMAN SACHS GROUP, INC. (THE "FIRM") FAILED TO NOTIFY THE CNB WITHIN THE STATUTORY TIME LIMIT THAT ITS SHARES IN THE VOTING RIGHTS OF A CERTAIN ISSUER COMPANY HAD EXCEEDED 1%, IN DEEMED VIOLATION OF ARTICLE 122(1), AND IN CONJUNCTION WITH ARTICLE 122(2), OF THE CAPITAL MARKET UNDERTAKINGS ACT. Status: Final Sanction Detail: THE CNB IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF 750,000 CZECH KORUNA (CZK), TOGETHER WITH COSTS OF 1,000 CZK, WHICH WAS PAID BY WIRE ON SEPTEMBER 7, 2018. WHILE THE ACTUAL PAYMENT OF THE FINE AND COSTS WAS MADE IN CZECH KORUNA, USING THE CNB FOREIGN EXCHANGE RATE OF CZK22.124:USD1 AS OF SEPTEMBER 7, 2018, THE EQUIVALENT U.S. DOLLAR VALUE ON SEPTEMBER 7, 2018 WAS APPROXIMATELY $33,945.00, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE CNB IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF 750,000 CZECH KORUNA (CZK), TOGETHER WITH COSTS OF 1,000 CZK, WHICH WAS PAID BY WIRE ON SEPTEMBER 7, 2018.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION ALLEGED THAT THE FIRM ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION ON JULY 20, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $132,470.25 TO THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JULY 23, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION ON JULY 20, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $132,470.25 TO THE MISSOURI SECRETARY OF STATE SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JULY 23, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: THE SIMEX DETERMINED THAT GOLDMAN SACHS FUTURES PTE LTD. (A SUBSIDIARY OF GOLDMAN, SACHS & CO.) VIOLATED RULES 525 AND 527 BY FAILING TO PREPARE AND TIME STAMP A CUSTOMER ORDER AND BEING A PARTY TO A PREARRANGED TRADE. Status: Final Sanction Detail: GOLDMAN SACHS FUTURES PTE LTD.WAS FINED AND PAID 11,000 SINGAPORE DOLLARS. Summary: ON MAY 7, 1996, THE SIMEX DETERMINED THAT GOLDMAN SACHS FUTURES PTE LTD. (A SUBSIDIARY OF GOLDMAN, SACHS & CO.) VIOLATED RULES 525 AND 527 BY FAILING TO PREPARE AND TIME STAMP A CUSTOMER ORDER AND BEING A PARTY TO A PREARRANGED TRADE.GOLDMAN SACHS FUTURES PTE LTD.WAS FINED AND PAID 11,000 SINGAPORE DOLLARS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE UTAH DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE UTAH DIVISION OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GS ENTERED INTO A CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES THAT FOUND GS TO HAVE VIOLATED UTAH CODE §61-1-6(1)(G), WHICH PROHIBITS DISHONEST OR UNETHICAL BUSINESS PRACTICES, BY FAILING TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING, AND UTAH CODE § 61-1-6(1)(J) BY FAILING REASONABLY TO SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING. GS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES. GS HAS REACHED SIMILAR SETTLEMENT AGREEMENTS WITH MANY OTHER U.S. STATES AND TERRITORIES.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ALASKA DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT, DIVISION OF BANKING, SECURITIES, AND CORPORATIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE ALASKA DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT, DIVISION OF BANKING, SECURITIES, AND CORPORATIONS WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE ALASKA DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT, DIVISION OF BANKING, SECURITIES, AND CORPORATIONS THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED ALASKA CODE AS 45.55.060 (A)(7) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND AS 45.55.060 (B)(1) WHICH STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF ARIZONA CONSUMER PROTECTION & ADVOCACY, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $395,321 PAYMENT TO THE STATE OF ARIZONA CONSUMER PROTECTION & ADVOCACY SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF ARIZONA CONSUMER PROTECTION & ADVOCACY SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED A.R.S. §44-1961 (A)(13) IN FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURE AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING. ADDITIONALLY, GOLDMAN SACHS FAILED TO SUPERVISE ITS EMPLOYEES TO ENSURE ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURED AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING ARKANSAS SECURITIES DEPARTMENT, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE ARKANSAS SECURITIES DEPARTMENT WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE ARKANSAS SECURITIES DEPARTMENT THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED ARK. CODE ANN. §§ 23-42-308 (A)(2)(G) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND ARK. CODE ANN. §§ 23-42-308 (A)(2)(J) WHICH STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF CALIFORNIA - BUSINESS, TRANSPORTATION AND HOUSING AGENCY, DEPARTMENT OF CORPORATIONS CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $2,609,851 PAYMENT TO THE STATE OF CALIFORNIA - BUSINESS, TRANSPORTATION AND HOUSING AGENCY, DEPARTMENT OF CORPORATIONS WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF CALIFORNIA BUSINESS, TRANSPORTATION AND HOUSING AGENCY, DEPARTMENT OF CORPORATIONS, THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED CORPORATIONS CODE SECTION 25218 AND TITLE 10 CALIFORNIA CODE OF REGULATIONS SECTION 260.218 AND 260.218.4(A) BY: FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AND FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCED FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $331,417 PAYMENT TO THE STATE OF COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED §11-51-410(1)(G), C.R.S., AND RULE 51-4.7 THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND §11-51-410 (1)(I), C.R.S. THAT STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND SALES REPRESENTATIVES.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF CONNECTICUT DEPARTMENT OF BANKING, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $262,402 PAYMENT TO STATE OF CONNECTICUT DEPARTMENT OF BANKING WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF CONNECTICUT, DEPARTMENT OF BANKING, THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED SECTION 36B-4(B) OF THE ACT THAT PROSCRIBES ENGAGING IN DISHONEST OR UNETHICAL PRACTICES IN CONNECTION WITH THE OFFER, SALE OR PURCHASE OF A SECURITY AND SECTION 36B-31-6F(B) OF THE REGULATIONS STATING BROKER-DEALERS ARE REQUIRED TO ESTABLISH, ENFORCE, AND MAINTAIN A SYSTEM FOR SUPERVISING THEIR EMPLOYEES AND AGENTS THAT IS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF DELAWARE DEPUTY ATTORNEY GENERAL, DEPARTMENT OF JUSTICE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO STATE OF DELAWARE DEPARTMENT OF JUSTICE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF DELAWARE DEPARTMENT OF JUSTICE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED 6 DEL.C. §7316 (A)(7) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND 6 DEL. C. §7316(A)(10) THAT STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE REASONABLY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE GOVERNMENT OF THE DISTRICT OF COLUMBIA, DEPARTMENT OF INSURANCE AND SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE GOVERNMENT OF THE DISTRICT OF COLUMBIA, DEPARTMENT OF INSURANCE AND SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE GOVERNMENT OF THE DISTRICT OF COLUMBIA, DEPARTMENT OF INSURANCE AND SECURITIES REGULATION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED D.C. OFFICIAL CODE §31-5602.07(A)(9) BY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING. GOLDMAN SACHS ALSO VIOLATED D.C. OFFICIAL CODE §31-5602.07(A)(12) BY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $1,231,461 PAYMENT TO THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED SECTION 517.161 (1)(A), FLA. STAT., AND 3E-600.013 (1)(P)1., FLA. ADMIN. CODE THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND THE REQUIREMENT THAT BROKER-DEALERS SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF GEORGIA SECRETARY OF STATE COMMISSIONER OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $630,775 PAYMENT TO THE STATE OF GEORGIA SECRETARY OF STATE COMMISSIONER OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF GEORGIA, SECRETARY OF STATE, COMMISSIONER OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED O.C.G.A. §§ 10-5-4 (A)(8) AND 10-5-12 (A)(1) AND RULE 590-4-2-.14(1) THAT STATES ANALYSTS WHO ISSUE RESEARCH BE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND IB. ADDITIONALLY, O.C.G.A. §§ 10-5-4 (A)(11) AND 10-5-12(A)(1) AND RULE 590-4-2-.08 (1) THAT STATES ANALYSTS WHO ISSUED RESEARCH WERE REASONABLY SUPERVISED.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, SECURITIES ENFORCEMENT ATTORNEY, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, SECURITIES ENFORCEMENT ATTORNEY WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE HAWAII DEPARTMENT OF COMMERCE AND AFFAIRS THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED H.R.S. §485-15(7) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND H.R.S. §485-15(10) THAT STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF IDAHO DEPARTMENT OF FINANCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF IDAHO DEPARTMENT OF FINANCE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF IDAHO DEPARTMENT OF FINANCE THAT HAS FOUND GOLDMAN SACHS TO HAVE VIOLATED IDAHO CODE 30-1413(7) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND IDAPA 12.01.08.119(01) THAT REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $956,921 PAYMENT TO THE STATE OF ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT, WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF ILLINOIS SECURITIES DEPARTMENT THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED SECTION 8.E(1)(B) THAT PROSCRIBES THE USE OF UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND SECTION 8.E(1)(E)(IV) THAT REQUIRES DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF THEIR EMPLOYEES.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF INDIANA SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $468,508 PAYMENT TO THE STATE OF INDIANA SECURITIES DIVISION, WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF INDIANA SECURITIES DIVISION, THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED IND. CODE § 23-2-1-11(A)(6); 710 IND. ADMIN. CODE 1-17-1(W) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND IND. CODE § 23-2-1-11(A)(14); 710 IND. ADMIN. CODE 1-17-1(V) THAT REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF IOWA SECURITIES BUREAU, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF IOWA SECURITIES BUREAU WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE IOWA SECURITIES BUREAU THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED SECTION 502.304(1)(G), CODE OF IOWA (2003) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND SECTION 502.304(1)(J), CODE OF IOWA (2003) THAT REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF KANSAS OFFICE OF THE SECURITIES COMMISSIONER, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF KANSAS OFFICE OF THE SECURITIES COMMISSIONER WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE KANSAS OFFICE OF THE SECURITIES COMMISSIONER THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED K.S.A. 17-1254(M)(7) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND K.S.A. 17-1254(M)(12) THAT REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMONWEALTH OF KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $311,423 PAYMENT TO THE COMMONWEALTH OF KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED KRS 292.330(13)(A)7 THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND KRS 292.330(13)(A)9A THAT REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF MAINE DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION OFFICE OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF MAINE DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION OFFICE OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF MAINE OFFICE OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED 32 M.R.S.A. § 10313(1)(G) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND 32 M.R.S.A. §10313(1)(J) THAT REQUIRES BROKER-DEALERS TO SUPERVISE REASONABLY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MARYLAND SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $408,100 PAYMENT TO MARYLAND SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE MARYLAND SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED MARYLAND SECURITIES ACT, SECTION 11-412(A)(7) THAT SUBJECT BROKER-DEALERS TO SANCTION FOR ENGAGING IN DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND MARYLAND SECURITIES ACT 11-412(A)(10) THAT STATES BROKER-DEALERS ARE ALSO SUBJECT TO SANCTION FOR FAILURE TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMONWEALTH OF MASSACHUSETTS, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $489,205 PAYMENT TO THE COMMONWEALTH OF MASSACHUSETTS, SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS HAS ENTERED INTO A CONSENT ORDER WITH THE COMMON-WEALTH OF MASSACHUSETTS, SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED M.G.L. C. 110A, §204(A)(2)(G) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND M.G.L. C. 110A, §204(A)(2)(J) THAT STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF MICHIGAN, OFFICE OF FINANCIAL AND INSURANCE SERVICES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $765,768 PAYMENT TO THE STATE OF MICHIGAN, OFFICE OF FINANCIAL AND INSURANCE SERVICES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS HAS ENTERED INTO A CONSENT ORDER WITH THE STATE OF MICHIGAN, OFFICE OF FINANCIAL AND INSURANCE SERVICES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED MCL 451.604(A)(1)(G) THAT PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND MCL 451.604(A)(2) THAT STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MINNESOTA DEPARTMENT OF COMMERCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $379,051 PAYMENT TO THE MINNESOTA DEPARTMENT OF COMMERCE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE MINN. DEPARTMENT OF COMMERCE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED MINN. STAT. §80A.07, SUBD. 1(7) (2002), WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND MINN. STAT. §80A.07, SUBD. 1(10) (2002) AND MINN. R. CH. 2875.0910(3) (2001) WHICH STATE BROKER DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MISSOURI OFFICE OF SECRETARY OF STATE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $431,117 PAYMENT TO THE MISSOURI OFFICE OF SECRETARY OF STATE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE MISSOURI OFFICE OF SEC. OF STATE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED §409.204(A)(2)(G) RSMO BY THE COMMISSIONER OF SECURITIES BY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OFFICE OF THE MISSISSIPPI SECRETARY OF STATE/ BUSINESS REGULATION AND ENFORCEMENT DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE OFFICE OF THE MISSISSIPPI SECRETARY OF STATE/ BUSINESS REGULATION AND ENFORCEMENT DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: GOLDMAN SACHS WILL CEASE AND DESIST FROM VIOLATING THE MISSISSIPPI SECURITIES ACT IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THIS ORDER AND WILL COMPLY WITH THE ACT IN CONNECTION WITH THE RESEARCH PRACTICES REFERENCED IN THIS ORDER AND WILL COMPLY WITH THE UNDERTAKINGS OF ADDENDUM A, INCORPORATED HEREIN BY REFERENCE.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OFFICE OF THE MONTANA STATE AUDITOR, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE OFFICE OF THE MONTANA STATE AUDITOR WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE MONTANA STATE AUDITOR THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE SEC. ACT OF MONTANA § 30-10-101 ET SEQ., MCA, AND § 30-10-201(13)(G), MCA, WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; AND §30-10-201(13)(K), MCA WHICH STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NEBRASKA/ DEPARTMENT OF BANKING & FINANCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE OFFICE OF THE STATE OF NEBRASKA/ DEPARTMENT OF BANKING & FINANCE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF NEBRASKA/ DEPARTMENT OF BANKING & FINANCE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE NEB. REV. STAT. § 8-1103(9)(A)(VII) THAT GOLDMAN SACHS FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING STATE OF NEVADA/ OFFICE OF THE SECRETARY OF STATE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE OFFICE OF STATE OF NEVADA/ OFFICE OF THE SECRETARY OF STATE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF NEVADA/ OFFICE OF THE SECRETARY OF STATE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED NRS 90.420(1)(H) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND NRS 90.420(1)(K) WHICH STATES THAT BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF THEIR EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NEW HAMPSHIRE/DEPARTMENT OF STATE/BUREAU OF SECURITIES REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF NEW HAMPSHIRE/DEPARTMENT OF STATE/BUREAU OF SECURITIES REGULATION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF NEW HAMPSHIRE/ DEPARTMENT OF STATE/ BUREAU OF SECURITIES REGULATION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE NEW HAMPSHIRE SECURITIES ACT UNDER N.H. REV. STAT. §§ 421-B:10(I)(B)(7) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND 421-B:10(I)(B)(10) WHICH STATES BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF THEIR EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NEW JERSEY/ DEPARTMENT OF LAW AND PUBLIC SAFETY/ DIVISION OF CONSUMER AFFAIRS/ BUREAU OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $648,335 PAYMENT TO THE OFFICE OF THE STATE OF NEW JERSEY/ DEPARTMENT OF LAW AND PUBLIC SAFETY/ DIVISION OF CONSUMER AFFAIRS/ BUREAU OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF NEW JERSEY/ DEPARTMENT OF LAW AND PUBLIC SAFETY/ DIVISION OF CONSUMER AFFAIRS/ BUREAU OF SECURITIES REGULATION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED N.J.S.A. 49:3-58(A)(2)(VII) TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AND N.J.S.A. 49:3-58(A)(2)(XI) THAT GOLDMAN SACHS FAILED REASONABLY TO SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEW MEXICO REGULATION & LICENSING DEPARTMENT/ SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE NEW MEXICO REGULATION & LICENSING DEPARTMENT/ SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE NEW MEXICO REGULATION & LICENSING DEPARTMENT/ SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE FAILED TO ENSURE AND FAILED REASONABLY TO SUPERVISE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING UNDER SECTION 58-13B-16.A(2)(H).

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NEW YORK/ OFFICE OF THE ATTORNEY GENERAL, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $1,462,158 PAYMENT TO THE STATE OF NEW YORK/ OFFICE OF THE ATTORNEY GENERAL WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER (ASSURANCE OF DISCONTINUANCE) WITH THE STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL RELATING TO THE VIOLATION OF THE MARTIN ACT IN CONNECTION WITH THE COMPANY'S RESEARCH PRACTICES AND SHALL COMPLY, INTER ALIA, WITH THE PROVISIONS OF EXHIBIT 1 AND EXHIBIT 2, AS ATTACHED WITH THE CONSENT ORDER.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NORTH CAROLINA/ DEPARTMENT OF THE SECRETARY OF STATE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $620,209 PAYMENT TO THE STATE OF NORTH CAROLINA/ DEPARTMENT OF THE SECRETARY OF STATE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF NORTH CAROLINA/ DEPARTMENT OF THE SECRETARY OF STATE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE NORTH CAROLINA SECURITIES ACT UNDER N.C.G.S. §78A-39(A)(2)(G) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NORTH DAKOTA SECURITIES DEPARTMENT, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE NORTH DAKOTA SECURITIES DEPARTMENT WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE NORTH DAKOTA SECURITIES DEPARTMENT THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE SECURITIES ACT UNDER SECTION 10-04-11(1)(C) N.D.C.C. WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; SECTION 10-04-11(1)(M) N.D.C.C. WHICH STATES BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OHIO DEPARTMENT OF COMMERCE/ DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $874,773 PAYMENT TO THE OHIO DEPARTMENT OF COMMERCE/ DIVISION OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE OHIO DEPARTMENT OF COMMERCE/ DIVISION OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED OHIO REVISED CODE CHAPTER 1707 AND THE RULES PROMULGATED THERE UNDER THAT GOLDMAN SACHS FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF OKLAHOMA DEPARTMENT OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $265,877 PAYMENT TO THE STATE OF OKLAHOMA DEPARTMENT OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF OKLAHOMA DEPARTMENT OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE OKLAHOMA SECURITIES ACT AND THE RULES OF THE OKLAHOMA SECURITIES COMMISSION AND THE ADMINISTRATOR OF THE DEPARTMENT OF SECURITIES (THE "RULES") WHICH PROSCRIBE THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS PURSUANT TO PARAGRAPH (8) OF SUBSECTION (A) OF SECTION 204 OF THE ACT AND 660:10-5-42 OF THE RULES. PARAGRAPH (12) OF SUBSECTION (A) OF SECTION 204 OF THE ACT AND 660:10-5-42 OF THE RULES ALSO REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OREGON/DEPARTMENT OF CONSUMER AND BUSINESS SERVICES/ DIVISION OF FINANCE AND CORPORATE SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $263,622 PAYMENT TO THE OREGON/ DEPARTMENT OF CONSUMER AND BUSINESS SERVICES/ DIVISION OF FINANCE AND CORPORATE SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE OREGON/ DEPARTMENT OF CONSUMER AND BUSINESS SERVICES/ DIVISION OF FINANCE AND CORPORATE SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE PROVISIONS OF ORS CHAPTER 59 UNDER ORS 59.205 (2) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; AND OAR DIVISION 441-205-210(1) IN WHICH BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMONWEALTH OF PENNSYLVANIA/ PENNSYLVANIA SECURITIES COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $946,269 PAYMENT TO THE COMMONWEALTH OF PENNSYLVANIA/ PENNSYLVANIA SECURITIES COMMISSION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE PENNSYLVANIA SECURITIES COMMISSION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED PROCEEDINGS UNDER SECTION 305(A)(X) OF THE 1972 ACT, 70 P.S. § 1-305 (A)(IX) WHICH PROHIBITS THE USE OF DISHONEST OR UNETHICAL PRACTICES; AND THAT THERE WOULD BE A BASIS FOR THE COMMISSION TO SUSPEND, REVOKE OR CONDITION THE BROKER-DEALER REGISTRATION OF GOLDMAN SACHS IN THE COMMONWEALTH OF PENNSYLVANIA.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMONWEALTH OF PUERTO RICO/ OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $293,457 PAYMENT TO THE COMMONWEALTH OF PUERTO RICO/ OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF PUERTO RICO/ OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE ACT NO. 60, (SECTION 204(A)(2)(G)) AND REGULATION 6078 (SECTION 26.1) WHICH PROSCRIBE THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; AND ACT NO. 60, (SECTION 204(A)(2)(J)) AND REGULATION 6078 (SECTIONS 25.4.4 AND 28.2) WHICH STATES BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS/ DEPARTMENT OF BUSINESS REGULATION/ SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS/ DEPARTMENT OF BUSINESS REGULATION/ SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS/ DEPARTMENT OF BUSINESS REGULATION/ SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990 ("RISUSA") § 7-11-212(B)(8) WHICH PROHIBITS THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; AND THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990 ("RISUSA") § 7-11-212(B)(11) STATING A BROKER-DEALER IS ALSO REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SOUTH DAKOTA/ DEPARTMENT OF REVENUE AND REGULATION/ DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE SOUTH DAKOTA/DEPARTMENT OF REVENUE AND REGULATION/ DIVISION OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE SOUTH DAKOTA/ DEPARTMENT OF REVENUE AND REGULATION/ DIVISION OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE UNIFORM SECURITIES ACT, CHAPTER 47-31A, UNDER §47-31A-204(A)(2)(G) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS; AND §47-31A-204(A)(2)(G) IN WHICH BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF TENNESSEE/ DEPARTMENT OF COMMERCE AND INSURANCE/ OFFICE OF LEGAL COUNSEL, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $438,366 PAYMENT TO THE STATE OF TENNESSEE/ DEPARTMENT OF COMMERCE AND INSURANCE/ OFFICE OF LEGAL COUNSEL WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF TENNESSEE/ DEPARTMENT OF COMMERCE AND INSURANCE/ OFFICE OF LEGAL COUNSEL THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED TENNESSEE CODE ANNOTATED § 48-2-112 (A)(2)(G), FAILING TO ENSURE THAT ANALYST WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE TEXAS STATE SECURITIES BOARD, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $1,606,657 PAYMENT TO THE TEXAS STATE SECURITIES BOARD WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE TEXAS STATE SECURITIES BOARD THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED SECTION 14.A(3) OF THE TEXAS SECURITIES ACT WHICH IS TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION THAT FOUND GOLDMAN SACHS TO HAVE FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING UNDER §4221A(A)(8) OF THE SECURITIES ACT.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMONWEALTH OF VIRGINIA/ STATE CORPORATION COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY Status: Final Sanction Detail: THE $545,408 PAYMENT TO THE COMMONWEALTH OF VIRGINIA/ STATE CORPORATION COMMISSION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF VIRGINIA/ STATE CORPORATION COMMISSION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE ACT WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS UNDER SECURITIES VAC 5-20-280 E 12 AND 21 VAC 5-20-260 WHICH REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS. NASD CONDUCT RULE 2110 REQUIRES BROKER-DEALERS TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF WASHINGTON/ DEPARTMENT OF FINANCIAL INSTITUTIONS/SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $454,149 PAYMENT TO THE STATE OF WASHINGTON/ DEPARTMENT OF FINANCIAL INSTITUTIONS/SECURITIES DIVISION WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF WASHINGTON/ DEPARTMENT OF FINANCIAL INSTITUTIONS/SECURITIES DIVISION THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED RCW 21.29.119(1)(G) IN WHICH GOLDMAN SACHS FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF WEST VIRGINIA/ OFFICE OF THE STATE AUDITOR, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF WEST VIRGINIA/ OFFICE OF THE STATE AUDITOR WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF WEST VIRGINIA/ OFFICE OF THE STATE AUDITOR THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE WEST VIRGINIA SECURITIES ACT WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS UNDER WEST VIRGINIA CODE § 32-2-204(A)(2)(G) AND WEST VIRGINIA CODE § 32-2-204(A)(2)(J), BROKER-DEALERS ALSO ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF WISCONSIN/ DEPARTMENT OF FINANCIAL INSTITUTIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $413,277 PAYMENT TO THE STATE OF WISCONSIN/ DEPARTMENT OF FINANCIAL INSTITUTIONS WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF WISCONSIN/ DEPARTMENT OF FINANCIAL INSTITUTIONS THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE WISCONSIN UNIFORM SECURITIES LAW, CH. 551, WISCONSIN STATUTES, UNDER SEC. 551.34(1)(G), WISCONSIN STATUTES WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND 551.34(1)(J), WIS. STATS WHICH REQUIRES BROKER-DEALERS TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF WYOMING/ SECRETARY OF STATE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE STATE OF WYOMING/ SECRETARY OF STATE WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE STATE OF WYOMING/ SECRETARY OF STATE THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE WYOMING SECURITIES ACT UNDER WYO. STAT. §17-4-106(A)(II)(G) WHICH PROSCRIBES THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND WYO. STAT. §17-4-106 (B)(II)(A) IN WHICH BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES/AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE UTAH DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $250,000 PAYMENT TO THE UTAH DIVISION OF SECURITIES WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS THAT INCLUDED $25,000,000 AS DISGORGEMENT, $25,000,000 AS PENALTIES, $50,000,000 TO FUND INDEPENDENT, THIRD PARTY RESEARCH AND $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED UTAH CODE 61-1-6(1)(G), WHICH PROHIBITS DISHONEST OR UNETHICAL BUSINESS PRACTICES, BY FAILING TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING, AND UTAH CODE 61-1-6(1)(J) BY FAILING REASONABLY TO SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED. GOLDMAN SACHS EXPECTS TO ENTER INTO SUBSTANTIALLY SIMILAR SETTLEMENT AGREEMENTS WITH THE REMAINING STATES AND TERRITORIES.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ALABAMA SECURITIES COMMISSION AND OFFICE OF THE ATTORNEY GENERAL, STATE OF ALABAMA, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $342,654 PAYMENT TO THE ALABAMA SECURITIES COMMISSION AND OFFICE OF THE ATTORNEY GENERAL, STATE OF ALABAMA WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION AND OFFICE OF THE ATTORNEY GENERAL THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED CODE OF ALABAMA 1975 8-6-3(J)(7) WHICH PROHIBITS THE USE OF DISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS AND CODE OF ALABAMA 1975 8-6-3(J)(10) WHICH STATES BROKER-DEALERS ARE REQUIRED TO SUPERVISE ADEQUATELY THE CONDUCT OF ITS EMPLOYEES AND AGENTS.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. FROM MARCH 2014 THROUGH JULY 2021, THE CFPB IDENTIFIED MULTIPLE INSTANCES OF GREENSKY ENGAGING IN UNFAIR ACTS AND PRACTICES WITH REGARD TO LOANS TO CONSUMERS WHO DID NOT AUTHORIZE THEM AND BY STRUCTURING ITS LOAN ORIGINATION AND SERVICING ACTIVITIES IN A MANNER THAT ENABLED UNAUTHORIZED LOANS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OF FACT OR CONCLUSIONS, GREENSKY AGREED TO THE ISSUANCE OF THE CONSENT ORDER WHICH WILL TERMINATE FIVE YEARS AFTER THE EFFECTIVE DATE OF JULY 12, 2021, BARRING ANY FURTHER VIOLATIONS. GREENSKY IS TO PAY REDRESS TO CONSUMERS IDENTIFIED BY THE CONSENT ORDER AS BEING IMPACTED BY THE VIOLATIONS IN A TOTAL AMOUNT TO NOT BE LESS THAN $750,000 AND TO NOT EXCEED $3,000,000, AND LOAN CANCELLATIONS IN AN AMOUNT NO MORE THAN $6,000,000. IN ADDITION, A CIVIL PENALTY OF $2,5000,000 WAS ORDERED TO BE PAID TO THE CFPB. GREENSKY WAS ORDERED TO IMPLEMENT ADDITIONAL COMPLIANCE MEASURES TO PREVENT FURTHER VIOLATIONS INCLUDING THE ESTABLISHMENT OF A COMPLIANCE COMMITTEE TO BE RESPONSIBLE FOR MONITORING AND COORDINATING GREENSKY'S ADHERENCE TO THE PROVISIONS OF THE CONSENT ORDER FOR THE EFFECTIVE TIME PERIOD. Summary: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OF FACT OR CONCLUSIONS, GREENSKY AGREED TO THE ISSUANCE OF THE CONSENT ORDER WHICH WILL TERMINATE FIVE YEARS AFTER THE EFFECTIVE DATE OF JULY 12, 2021, BARRING ANY FURTHER VIOLATIONS. GREENSKY IS TO PAY REDRESS TO CONSUMERS IDENTIFIED BY THE CONSENT ORDER AS BEING IMPACTED BY THE VIOLATIONS IN A TOTAL AMOUNT TO NOT BE LESS THAN $750,000 AND TO NOT EXCEED $3,000,000, AND LOAN CANCELLATIONS IN AN AMOUNT NO MORE THAN $6,000,000. IN ADDITION, A CIVIL PENALTY OF $2,5000,000 WAS ORDERED TO BE PAID TO THE CFPB. GREENSKY WAS ORDERED TO IMPLEMENT ADDITIONAL COMPLIANCE MEASURES TO PREVENT FURTHER VIOLATIONS INCLUDING THE ESTABLISHMENT OF A COMPLIANCE COMMITTEE TO BE RESPONSIBLE FOR MONITORING AND COORDINATING GREENSKY'S ADHERENCE TO THE PROVISIONS OF THE CONSENT ORDER FOR THE EFFECTIVE TIME PERIOD.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4), 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE, THE NASD AND THE SEC CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: $25,000,000 AS DISGORGEMENT $25,000,000 AS PENALTIES $50,000,000 TO FUND INDEPENDENT, THIRD PARTY RESEARCH $10,000,000 FOR INVESTOR EDUCATION Summary: WITHOUT ADMITTING OR DENYING LIABILITY, TEN INVESTMENT BANKING FIRMS ANNOUNCED THAT THEY HAD ENTERED INTO GLOBAL SETTLEMENTS WITH THE SEC, THE NYSE, THE NASD, THE NEW YORK ATTORNEY GENERAL AND OTHER STATES TO RESOLVE THE INVESTIGATIONS RELATING TO EQUITY RESEARCH ANALYST CONFLICTS OF INTEREST. UNDER THE NYSE STIPULATION AND CONSENT AND THE NASD AWC, GOLDMAN SACHS WAS CHARGED WITH VIOLATING (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY ENGAGING IN ACTS AND PRACTICES DURING THE PERIOD JULY 1, 1999 THROUGH JUNE 30, 2001 THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY PUBLISHING IN CERTAIN INSTANCES RESEARCH THAT WAS EXAGGERATED, UNWARRANTED OR LACKING IN REASONABLE BASIS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES OVER RESEARCH ANALYSTS TO PREVENT OR MANAGE CONFLICTS OF INTEREST. AS PART OF THE SETTLEMENTS, GOLDMAN SACHS WAS CENSURED BY THE NYSE AND THE NASD AND AGREED TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 12. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF “HOT” IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4), 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE, THE NASD AND THE SEC CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: $25,000,000 AS DISGORGEMENT $25,000,000 AS PENALTIES $50,000,000 TO FUND INDEPENDENT, THIRD PARTY RESEARCH $10,000,000 FOR INVESTOR EDUCATION Summary: WITHOUT ADMITTING OR DENYING LIABILITY, TEN INVESTMENT BANKING FIRMS ANNOUNCED THAT THEY HAD ENTERED INTO GLOBAL SETTLEMENTS WITH THE SEC, THE NYSE, THE NASD, THE NEW YORK ATTORNEY GENERAL AND OTHER STATES TO RESOLVE THE INVESTIGATIONS RELATING TO EQUITY RESEARCH ANALYST CONFLICTS OF INTEREST. UNDER THE NYSE STIPULATION AND CONSENT AND THE NASD AWC, GOLDMAN SACHS WAS CHARGED WITH VIOLATING (I) NYSE RULES 401 AND 476 AND NASD CONDUCT RULE 2110 BY ENGAGING IN ACTS AND PRACTICES DURING THE PERIOD JULY 1, 1999 THROUGH JUNE 30, 2001 THAT CREATED AND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS; (II) NYSE RULE 472 AND NASD CONDUCT RULE 2210 BY PUBLISHING IN CERTAIN INSTANCES RESEARCH THAT WAS EXAGGERATED, UNWARRANTED OR LACKING IN REASONABLE BASIS; AND (III) NYSE RULE 342 AND NASD CONDUCT RULE 3010 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY PROCEDURES OVER RESEARCH ANALYSTS TO PREVENT OR MANAGE CONFLICTS OF INTEREST. AS PART OF THE SETTLEMENTS, GOLDMAN SACHS WAS CENSURED BY THE NYSE AND THE NASD AND AGREED TO PAY A TOTAL OF $110,000,000 AS OUTLINED IN RESPONSE 12. GOLDMAN SACHS ALSO AGREED TO ADOPT A SET OF INDUSTRY-WIDE REFORMS OF ITS RESEARCH AND INVESTMENT BANKING BUSINESSES DESIGNED TO ELIMINATE THE CONFLICTS OF INTEREST THAT WERE FOUND TO HAVE EXISTED AND TO ADOPT CERTAIN RESTRICTIONS ON THE ALLOCATIONS OF “HOT” IPO SHARES TO EXECUTIVES AND DIRECTORS OF PUBLIC COMPANIES.

Regulatory as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SEC, NASD AND NYSE ALLEGED THAT FIVE BROKER DEALERS INCLUDING GOLDMAN SACHS VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 HEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE E-MAIL COMMUNICATIONS FOR 3 YEARS AND/OR TO PRESERVE E-MAIL COMMUNICATIONS FOR THE FIRST 2 YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF E-MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD). Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, 5 BROKER-DEALERS INCLUDING GOLDMAN SACHS CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE AND DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF E-MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND RULES OF THE NASD AND NYSE AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") AND THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED THAT FIVE BROKER DEALERS,INCLUDING GOLDMAN SACHS, VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THREE YEARS AND/OR TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF ELECTRONIC MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD) Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIVE BROKER DEALERS, INCLUDING GOLDMAN SACHS, CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE-AND-DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND THE RULES OF THE NASD AND NYSE, AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS & PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory as of Nov 19, 2024

Allegations: SCOTT SEVERANCE ("SEVERANCE") ALLEGED IN AN ACTION BEFORE THE CFTC THAT HE WAS FRAUDULENTLY INDUCED TO OPEN AN ACCOUNT WITH FIRST OPTIONS OF CHICAGO, INC. ("FOC") BY AN FOC EMPLOYEE AND A FLOOR BROKER, AND THAT FOC AND THE FLOOR BROKER ALLEGEDLY ENGAGED IN UNAUTHORIZED TRADING IN THE ACCOUNT IN CONNECTION WITH ITS LIQUIDATION, IN VIOLATION OF CFTC REGULATION 166.2, COMMODITIES EXCHANGE ACT SECTIONS 4B AND 2(A)(1)(B), AND CFTC RULE 1.33(B)(1). Status: Final Sanction Detail: FOC PAID MONEY DAMAGES TO SEVERANCE IN THE AMOUNT OF $28,600.00 Summary: ON SEPTEMBER 25, 2002, SEVERANCE FILED A COMPLAINT WITH THE CFTC. THE CFTC ADMINISTRATIVE LAW JUDGE ("ALJ") IMPOSED JOINT AND SEVERAL LIABILITY FOR MONEY DAMAGES AGAINST FOC, ITS EMPLOYEE, AND THE FLOOR BROKER, FINDING AMONG OTHER THINGS THAT FOC HAD VIOLATED COMMODITIES EXCHANGE ACT SECTIONS 4B, 4O(1)(A) AND (B), CFTC REGULATION 166.2 AND 166.3, CFTC RULE 1.33(B)(1) AND WAS VICARIOUSLY LIABLE PURSUANT TO SECTION 2(A)(1)(B). ON APPEAL THE CFTC UPHELD THE ALJ'S DECISION AGAINST FOC AND THE FLOOR BROKER, BUT DISMISSED THE COMPLAINT AS TO THE FOC EMPLOYEE. ON SEPTEMBER 27, 2005, FOC PAID THE MONEY DAMAGES TO SEVERANCE IN THE AMOUNT OF $28,600.

Regulatory as of Nov 19, 2024

Allegations: THE SEC ALLEGED THAT FROM JANUARY 1977 THROUGH MARCH 1978, FIRST OPTIONS OF CHICAGO, INC. ("FOC") EXTENDED CREDIT TO ACCOUNTS THAT EXCEEDED THE EQUITY IN THE ACCOUNTS AND FAILED TO PROMPTLY LIQUIDATE EXISTING POSITIONS IN SAID ACCOUNTS, IN VIOLATION OF SECTIONS 7(A), 7(B), 7(C) AND 15(C)(3) OF THE SECURITIES EXCHANGE ACT, AND SECTIONS 3 AND 4 OF FRB REGULATION T. Status: Final Sanction Detail: AN UNDERTAKING TO MAINTAIN AND IMPLEMENT PROCEDURES AND COMPLY WITH THE SECURITIES AND EXCHANGE ACT. Summary: FOC UNDERTOOK TO (1) MAINTAIN AND IMPLEMENT PROCEDURES FOR COMPLIANCE WITH REGULATION T, (2) COMPLY WITH SECTIONS 7(C)(2), 15(C)(3) AND 17(A)(3) OF THE EXCHANGE ACT AND RULES 17A-3, 15C3-1(C)(2)(X)(F) AND (G) THEREUNDER, AND (3) ADOPT, MAINTAIN AND IMPLEMENT PROCEDURES TO ASSURE THAT THESE UNDERTAKINGS ARE CARRIED OUT.

Regulatory as of Nov 19, 2024

Allegations: IN NOVEMBER 2002, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") AND THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED THAT FIVE BROKER DEALERS, INCLUDING GOLDMAN SACHS, VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, NYSE RULES 440 AND 342 AND NASD RULES 3010 AND 3110 BY ALLEGEDLY FAILING TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THREE YEARS AND/OR TO PRESERVE ELECTRONIC MAIL COMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE, AND BY ALLEGEDLY HAVING INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES IN RELATION TO THE RETENTION OF ELECTRONIC MAIL COMMUNICATIONS. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000.00 ($550,000.00 EACH TO THE SEC, NYSE AND NASD) Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIVE BROKER DEALERS, INCLUDING GOLDMAN SACHS, CONSENTED TO CENSURE BY THE SEC, NASD AND NYSE AND TO THE IMPOSITION OF A CEASE-AND-DESIST ORDER BY THE SEC AND GOLDMAN SACHS PAID A TOTAL FINE OF $1,650,000 ($550,000 EACH TO THE SEC, NASD AND NYSE). GOLDMAN SACHS ALSO UNDERTOOK TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS AND THE RULES OF THE NASD AND NYSE, AND TO CONFIRM WITHIN A SPECIFIED PERIOD OF TIME THAT IT HAS ESTABLISHED SYSTEMS & PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULES.

Regulatory as of Nov 19, 2024

Allegations: GOLDMAN SACHS ALLEGEDLY VIOLATED (I) SECTION 15(C)(1) AND RULE 15C1-2 OF THE EXCHANGE ACT AS A RESULT OF CERTAIN TRADING IN U.S. TREASURY BONDS ON OCTOBER 31, 2001; AND (II) SECTION 15(F) OF THE EXCHANGE ACT BY FAILING TO MAINTAIN POLICIES AND PROCEDURES SPECIFICALLY ADDRESSED TO THE POSSIBLE MISUSE OF NON-PUBLIC INFORMATION OBTAINED FROM OUTSIDE CONSULTANTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS CONSENTED TO THE ENTRY OF AN ORDER THAT, AMONG OTHER THINGS, (I) CENSURED GOLDMAN SACHS; (II) DIRECTED GOLDMAN SACHS TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTION 15(C)(1)(A) & (C) AND 15(F) AND RULE 15C1-2 OF THE EXCHANGE ACT; (III) ORDERED GOLDMAN SACHS TO PAY DISGORGEMENT AND PREJUDGMENT INTEREST IN THE AMOUNT OF $1,742,642, AND A CIVIL MONETARY PENALTY OF $5 MILLION; AND (IV) DIRECTED GOLDMAN SACHS TO CONDUCT A REVIEW ITS POLICIES AND PROCEDURES ADOPT, IMPLEMENT AND MAINTAIN POLICIES AND PROCEDURES CONSISTENT WITH THE ORDER AND THAT REVIEW. GOLDMAN SACHS ALSO UNDERTOOK TO PAY $2,562,740 IN DISGORGEMENT AND INTEREST RELATING TO CERTAIN TRADING IN U.S. TREASURY BOND FUTURES. Summary: ON SEPTEMBER 4, 2003, THE SEC ENTERED ITS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TO SECTIONS 15(B)(4) & 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AS TO GOLDMAN, SACHS & CO., AS DESCRIBED ABOVE.

Regulatory as of Nov 19, 2024

Allegations: ON NOVEMBER 26, 2019, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ISSUED AN ORDER REQUIRING GOLDMAN SACHS & CO. LLC ("GOLDMAN") TO PAY A $1,000,000 CIVIL MONETARY PENALTY AND TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF CERTAIN CFTC REGULATIONS. DURING AN INVESTIGATION BY THE CFTC'S DIVISION OF ENFORCEMENT ("DIVISION"), THE DIVISION REQUESTED THAT GOLDMAN PRODUCE CERTAIN AUDIO RECORDINGS FROM JANUARY 2014. GOLDMAN WAS UNABLE TO PRODUCE MANY OF THE RECORDINGS REQUESTED DUE TO A MALFUNCTION WHICH OCCURRED DURING THE COURSE OF A SYSTEM UPGRADE WHICH AFFECTED RECORDINGS OF THE PHONE LINES OF A TRADING AND SALES DESK IN ONE OF GOLDMAN'S OFFICES FOR TWENTY CALENDAR DAYS IN JANUARY AND FEBRUARY 2014. GOLDMAN'S INABILITY TO PRODUCE THESE RECORDINGS IMPEDED THE DIVISION'S ONGOING INVESTIGATION, BECAUSE THE DIVISION WAS UNABLE TO OBTAIN THE INFORMATION THAT SHOULD HAVE BEEN CAPTURED IN MANY OF THE RECORDINGS THROUGH ANY OTHER MEANS. BASED ON THE FOREGOING, THE CFTC FOUND THAT GOLDMAN VIOLATED REGULATIONS 23.202(A)(1), (B)(1), AND 23.203(B)(2), 17 C.F.R. §§ 23.202(A)(1), (B)(1) (2018), 23.203(B)(2) (2017). Status: Final Sanction Detail: ON NOVEMBER 26, 2019, THE CFTC ISSUED AN ORDER AGAINST GOLDMAN. THE ORDER REQUIRES GOLDMAN TO PAY A $1,000,000 CIVIL MONETARY PENALTY AND TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF CFTC REGULATIONS 23.202(A)(1), (B)(1), AND 1.31(B)(2), 17 C.F.R. §§ 23.202(A)(1), (B)(1), 1.31(B)(2) (2018). IN ADDITION, AS PART OF THE SETTLEMENT, GOLDMAN REPRESENTED TO THE CFTC THAT IT HAD MADE CERTAIN CHANGES IN ITS SURVEILLANCE PROGRAMS. THE FINE WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 20, 2019. Summary: GOLDMAN SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE CFTC ACCEPTED. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, GOLDMAN CONSENTED TO THE ENTRY OF THE ORDER BY THE CFTC, PURSUANT TO WHICH GOLDMAN: (A) SHALL CEASE AND DESIST FROM VIOLATING REGULATIONS 23.202(A)(1), (B)(1), AND 1.31(B)(2), 17 C.F.R. §§ 23.202(A)(1), (B)(1), 1.31(B)(2) (2018); AND (B) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT $1,000,000. IN ADDITION, AS PART OF THE SETTLEMENT, GOLDMAN REPRESENTED TO THE CFTC THAT IT HAD MADE CERTAIN CHANGES IN ITS SURVEILLANCE PROGRAMS. THE FINE WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 20, 2019.

Regulatory as of Nov 19, 2024

Allegations: ON NOVEMBER 22, 2022, GOLDMAN SACHS ASSET MANAGEMENT, L.P. ("GSAMLP") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") REGARDING GSAMLP'S POLICIES AND PROCEDURES WITH RESPECT TO ENVIRONMENTAL, SOCIAL AND GOVERNANCE INVESTMENTS. THE SEC FOUND THAT GSAMLP DID NOT ADOPT WRITTEN POLICIES AND PROCEDURES GOVERNING THE EVALUATION OF ESG FACTORS UNTIL SOMETIME AFTER TWO ESG MUTUAL FUNDS WERE INTRODUCED AND A SOCIALLY-RESPONSIBLE SEPARATE ACCOUNT STRATEGY WAS REBRANDED AS ESG, AND THAT, ONCE SUCH POLICIES AND PROCEDURES WERE ADOPTED, THEY WERE NOT CONSISTENTLY FOLLOWED PRIOR TO FEBRUARY 2020. Status: Final Summary: GSAMLP WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. GSAMLP AGREED TO PAY A PENALTY OF $4 MILLION.

Regulatory as of Nov 19, 2024

Allegations: THIS REGULATORY ACTION WAS IN CONNECTION WITH AN INDUSTRY-WIDE INVESTIGATION BY THE SEC RELATING TO THE PRICING OF GOVERNMENT SECURITIES IN ADVANCE REFUNDING TRANSACTIONS. GOLDMAN, SACHS & CO. WAS FOUND TO HAVE VIOLATED SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933 IN CONNECTION WITH PRICING OF GOVERNMENT SECURITIES AND WAS REQUIRED TO CEASE AND DESIST FROM VIOLATING SUCH PROVISIONS. Status: Final Sanction Detail: REQUIRED GOLDMAN SACHS TO CEASE AND DESIST FROM VIOLATING PROVISIONS AND ORDERED GOLDMAN SACHS TO MAKE PAYMENTS TOTALING APPROXIMATELY $5.1 MILLION TO THE U.S. TREASURY AND $104,000 TO TWO MUNICIPALITIES. Summary: GOLDMAN, SACHS & CO. WAS ORDERED TO MAKE PAYMENTS TOTALING APPROXIMATELY $5.1 MILLION TO THE U.S. TREASURY AND $104,000 TO TWO MUNICIPALITIES - PAYMENT WAS MADE IN APRIL 2000. UNDER THE SETTLEMENT, THE LAWSUIT WAS DISMISSED WITH PREJUDICE, AND THE INTERNAL REVENUE SERVICE AGREED NOT TO CHALLENGE THE TAX-FREE NATURE OF THE REFUNDINGS BY VIRTUE OF THE PRICING OF SUCH SECURITIES.

Regulatory as of Nov 19, 2024

Allegations: AS PART OF AN INDUSTRY-WIDE INVESTIGATION RELATING TO THE PRICING OF GOVERNMENT SECURITIES IN ADVANCED REFUNDING TRANSACTIONS, GS JOINED IN A GLOBAL SETTLEMENT PURSUANT TO WHICH GS, WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO AN SEC ADMINISTRATIVE ORDER WHICH FOUND, INTER ALIA, THAT GS VIOLATED SECTIONS 17(A)(2)AND(3)OF THE SECURITIES EXCHANGE ACT OF 1933. Status: Final Sanction Detail: IN CONNECTION WITH THE GLOBAL SETTLEMENT OF AN INDUSTRY-WIDE INVESTIGATION RELATING TO THE PRICING OF GOVERNMENT SECURITIES IN ADVANCE REFUNDINGS, GOLDMAN, SACHS & CO.("GS") WAS ORDERED TO MAKE PAYMENTS TOTALING APPROXIMATELY $5.1 MILLION TO THE U.S. TREASURY AND $104,000 TO TWO MUNICIPALITIES. (SEE SEA REL. NO. 42640) Summary: ON APRIL 6, 2000, GS JOINED IN A GLOBAL SETTLEMENT RESOLVING (I) AN INDUSTRY-WIDE INVESTIGATION BY THE SEC RELATING TO THE PRICING OF GOVERNMENT SECURITIES IN ADVANCE REFUNDING TRANSACTIONS, AND (II) A RELATED QUI TAM LAWSUIT PURPORTEDLY BROUGHT ON BEHALF OF THE U.S. ENTITLED UNITED STATES EX REL. LISSACK V. GOLDMAN, SACHS & CO., ET AL., 95 CIV. 1363 (S.D.N.Y.)(BSJ).

Regulatory as of Nov 19, 2024

Allegations: ON MARCH 13, 2023, ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT A GOLDMAN SACHS & CO. LLC ("GSCO") MARGIN CALL PAYMENT WAS RECEIVED SIX MINUTES AFTER THE REQUIRED DEADLINE RESULTING IN A TECHNICAL DEFAULT IN VIOLATION OF ICE CLEAR CREDIT RULE 401(I). Status: Pending Summary: GSCO IS IN THE PROCESS OF RESPONDING TO THE ALLEGATIONS AND DETAILING THE CIRCUMSTANCES RELATING TO THE SUBJECT MARGIN PAYMENT. THE MATTER IS PENDING SUBJECT TO REVIEW BY ICC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO.("GS")ALLEGEDLY VIOLATED CBOT REGULATIONS 444.03 AND 545.02 ON A SINGLE OCCASION BY NETTING DOWN U.S. TREASURY BOND FUTURES AND TO ACCURATELY REPORT TO THE CBOT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS PAID A FINE OF $15,000.00. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS PAID A FINE OF $15,000.00. Summary: ON 01/10/2003, GS SENT A CHECK IN THE AMOUNT OF $15,000.00 TO THE CBOT.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT ON 18 OCCASIONS BETWEEN MARCH 1, 2002 AND JULY 17, 2002, GOLDMAN SACHS EFFECTED TRANSACTIONS IN OTC EQUITY OPTIONS FOR CUSTOMER ACCOUNTS THAT EXCEEDED NASD EQUITY OPTION POSITION LIMITS, AND THAT EACH TRANSACTION VIOLATED NASD CONDUCT RULES 2110 AND 2860(B)(3). Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $10,000. Summary: GOLDMAN SACHS ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WITH NASD. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS AGREED TO A CENSURE BY NASD AND TO PAYMENT OF A $10,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT ON FIVE PAIRS OF TRADES EXECUTED ON GOLDMAN, SACHS & CO.'S ("GS") HIGH YIELD AND DISTRESSED BOND DESKS BETWEEN JULY 2000 AND AUGUST 2001, GS VIOLATED NASD RULES RELATING TO MARKUPS/MARKDOWNS AND RECORD-KEEPING AND THAT EACH TRANSACTION VIOLATED NASD CONDUCT RULES 2110, 2440, IM-2440, 3010, 3110 AND 6240, SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-4. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THESE STATEMENTS OR ALLEGATIONS, THE COMPANY CONSENTED TO A CENSURE; TO AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FOR TRADING IN DISTRESSED AND HIGH-YIELD BONDS AS TO FAIR PRICING AND BOOKS AND RECORDS; TO MAKE RESTITUTION PAYMENTS TOTALING $343,575 IN CONNECTION WITH THE FIVE TRADES MENTIONED ABOVE; TO FINES OF $1,656,425 FOR THE MARKUP/MARKDOWNS AND FIPS REPORTING VIOLATIONS RELATING TO THE FIVE TRADES $1,500,000 FOR THE BOOKS AND RECORDS VIOLATIONS, AND $1,500,000 FOR THE SUPERVISORY VIOLATIONS. Summary: ON JULY 15, 2004 THE NASD OFFICE OF DISCIPLINARY AFFAIRS AND NATIONAL ADJUDICATORY COUNCIL ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") THAT WAS EXECUTED BY THE COMPANY ON JULY 13, 2004. IN THE AWC, THE NASD'S DEPARTMENT OF MARKET REGULATION (WITHOUT MAKING ANY LEGAL OR FACTUAL FINDINGS) STATED OR ALLEGED THAT THE COMPANY HAD VIOLATED NASD RULES RELATING TO MARKUP/MARKDOWNS IN CONNECTION WITH FIVE TRADES OCCURRING BETWEEN JULY 2000 AND AUGUST 2001 BY THE COMPANY'S HIGH-YIELD AND DISTRESSED BOND DESKS; THAT THE COMPANY VIOLATED RECORD-KEEPING RULES IN THAT THOSE DESKS FAILED IN SOME INSTANCES TO CREATE CERTAIN REQUIRED RECORDS AND IN SOME INSTANCES INACCURATELY RECORDED TIMES OF TRADE EXECUTION; AND THAT IN CERTAIN RESPECTS THE COMPANY'S SUPERVISORY SYSTEM FOR HIGH-YIELD AND DISTRESSED BOND TRADING WAS INADEQUATE IN ITS SCOPE AND FLAWED IN ITS EXECUTION.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE ISE ALLEGED THAT IN 43 INSTANCES BETWEEN NOVEMBER 2002 THROUGH APRIL 2003, GOLDMAN SACHS ("GS"), AS ELECTRONIC ACCESS MEMBER ("EAM"), RECEIVED CUSTOMER ORDERS AND WITHIN 30 SECONDS OF ENTERING THE ORDERS INTO THE ISE TRADING SYSTEM, GS ENTERED PROPRIETARY ORDERS THAT EXECUTED AGAINST THE CUSTOMER ORDERS, IN VIOLATION OF ISE RULE 717(D). THE ISE ALLEGED THAT ON ONE OCCASION IN DECEMBER 2002, GS, AS EAM, RECEIVED A CUSTOMER ORDER WHICH WAS EXECUTED AGAINST AN EXISTING PRINCIPAL ORDER WITHOUT FIRST POSTING THE ORDER ON THE EXCHANGE FOR 30 SECONDS, IN VIOLATION OF ISE RULE 717(D). THE ISE ALSO ALLEGED THAT GS FAILED TO MENTION SATISFACTORY WRITTEN SUPERVISORY PROCEDURES TO ENSURE COMPLIANCE WITH ISE RULES REGARDING PROPER FACILITATION OF CUSTOMER ORDERS BY GS, IN VIOLATION OF ISE RULE 401. Status: Final Sanction Detail: GS PAID A TOTAL FINE OF $15,000. Summary: GS ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITH ISE. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE BY ISE AND TO PAYMENT OF A $15,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NYSE ALLEGED THAT, DURING THE PERIOD JANUARY THROUGH MAY 2001, GOLDMAN, SACHS & CO. (GS) FAILED TO SUPERVISE AND CONTROL THE ACTIVITIES OF A FORMER REGISTERED REPRESENTATIVE ("RR") WHO FAILED TO TIMELY SUPPLY ACCOUNTS NUMBERS, OR OTHER INDICATIONS OF BENEFICIAL OWNERSHIP OF TRADES, AND DELAY ALLOCATION OF EXECUTED TRADES, WHICH LED TO MORE FAVORABLE TRADES IN THE RR'S PERSONAL ACCOUNT FOR A POTENTIAL GAIN OF $600,000, AND WAS TO THE DETRIMENT OF GS CUSTOMERS, GS IS ALSO ALLEGED TO HAVE FAILED TO ENSURE THAT ITS EMPLOYEES MADE AND PRESERVED BOOKS AND RECORDS CONCERNING ACCOUNT DESIGNATIONS AND EXECUTION OF CUSTOMER ORDERS. THE ALLEGED CONDUCT IS IN VIOLATION OF NYSE RULES 342, 342.16, 440 SECURITIES AND EXCHANGE COMMISSION REGULATIONS 240.17A-3(A)(6) AND (7). Status: Final Sanction Detail: GS PAID A TOTAL FINE OF $175,000. Summary: GS SUBMITTED A CONSENT TO PENALTY TO NYSE, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS OFFERED TO BE CENSURED AND PAID A $175,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: PHLX ALLEGED THAT FROM JANUARY 2003 THROUGH JUNE 2003, ON SIX SEPARATE OCCASIONS, GOLDMAN, SACHS & CO. ENTERED ORDERS TO TRADE ALL OF THE SEPARATE COMPONENTS OF THE EXCHANGE OIL SERVICE SECTOR INDEX OR SEMICONDUCTOR SECTOR INDEX ("INDICES") FOR ITS PRINCIPAL FACILITATION ACCOUNT PRIOR TO FACILITATING THE EXECUTION AT THE PHLX OF CUSTOMER ORDERS TO TRADE OPTIONS ON THE INDICES, IN VIOLATIONS OF PHLX RULE 1064. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. WAS CENSURED AND PAID A FINE OF $100,000. Summary: GOLDMAN, SACHS & CO. SUBMITTED AN OFFER OF SETTLEMENT TO PHLX, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $100,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CBOT ALLEGED THAT GOLDMAN, SACHS & CO. FAILED TO MAKE ALL TRADE DATA SUBMISSIONS IN A CORRECT MANNER IN VIOLATION OF REGULATION 332.08. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. PAID A FINE OF $1,000. Summary: GOLDMAN, SACHS & CO. SUBMITTED AN OFFER OF SETTLEMENT TO THE CBOT, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $1000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME ALLEGED THAT ON SEPTEMBER 8, 2004, GOLDMAN, SACHS & CO.'S FLOOR ORDER PICK UP EXCEPTION RATE OF 13.40%, EXCEEDED THE ACCEPTABLE RATE, IN VIOLATION OF RULE 536. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. PAID A FINE OF $1000.00 Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $1,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO.'S ("GS") SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS RELATING TO (I) THE PROPER MARKING OF ORDER TICKETS FOR PROPRIETY ORDERS AND COMPLIANCE WITH THE "TICK TEST" AND (II) TRADING IN FRONT OF CUSTOMER ORDERS, IN VIOLATION OF NASD CONDUCT RULES 2110 AND 3010. Status: Final Sanction Detail: GS PAID A FINE OF $5000.00 Summary: THE NASD ALLEGATIONS RESULTED FROM A TRADING AND MARKET MARKING SURVEILLANCE EXAMINATION CONDUCTED BY THE NASD DEPARTMENT OF MARKET REGULATION DURING NOVEMBER 18-22, 2002. GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO THE NASD, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO PAY A $5,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: PHLX ALLEGED THAT ON APRIL 15, 2004, GOLDMAN, SACH & CO. ("GS") FAILED TO MAINTAIN REQUIRED POSITION LIMITS IN VIOLATION OF PHLX RULE 1001. Status: Final Sanction Detail: GS PAID A FINE OF $2500.00 Summary: GS SUBMITTED ON OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS, WHICH WERE ACCEPTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO CENSURE AND PAYMENT OF A $2,500 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOT ALLEGED THAT ON DECEMBER 20 THROUGH DECEMBER 22, 2004, GOLDMAN, SACHS & CO. MADE DATA ENTRY ERRORS ON 11 TRADES, IN VIOLATION OF REGULATION 332.08. Status: Final Sanction Detail: GOLDMAN, SACHS & CO. PAID A MONETARY FINE OF $1,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $1000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: AS PART OF AN INDUSTRY-WIDE SETTLEMENT OF REPORTING ISSUES, ON MARCH 4, 2005, THE NASD ALLEGED THAT ON OR ABOUT JANUARY 2003 THROUGH MAY 2004, GOLDMAN, SACHS & CO. ("GS") FAILED TO TIMELY REPORT 10% OF ITS MUNICIPAL SECURITIES INTER-DEALER TRANSACTIONS, AND THAT GS FAILED TO REPORT THE TIME OF TRADE EXECUTION AND/OR REPORTED INVALID TIME OF TRADES 49% OF THE TIME. NASD ALLEGED THAT ON OR ABOUT FEBRUARY 2003 THROUGH OCTOBER 2003, GS FAILED TO REPORT 79% OF THE TIME MUNICIPAL SECURITIES INTER-DEALER TRADE EXECUTIONS, TO THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB"). THE NASD ALLEGED THAT SUCH REPORTING ISSUES VIOLATED MSRB RULE G-14. ON OR ABOUT JANUARY 2003 THROUGH MAY 2004, GS FAILED TO MONITOR ITS TRADES TO ENSURE COMPLIANCE WITH MSRB RULE G-14, IN VIOLATION OF MSRB RULE G-27. Status: Final Sanction Detail: GS PAID A TOTAL FINE OF $140,000 AND WAS CENSURED. Summary: ON MAY 6, 2005, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, GS CONSENTED TO A CENSURE AND TO PAY A $140,000 FINE. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY NASD ON MAY 13, 2005.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT, IN CONNECTION WITH CERTAIN SHORT TRANSACTIONS ON OR ABOUT AUGUST 23 AND 24, 2004, GOLDMAN, SACHS & CO. ("GS"): (1) FAILED TO ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE RELEVANT SECURITIES COULD BE BORROWED OR OTHERWISE PROVIDED FOR DELIVERY OF THE SECURITIES BY SETTLEMENT DATE, (2) FAILED TO REPORT CERTAIN SHORT SALES TO THE NASDAQ MARKET CENTER WITH A SHORT SALE MODIFIER, AND (3) FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, IN VIOLATION OF NASD CONDUCT RULE 3370, NASD MARKETPLACE RULE 6130, AND NASD CONDUCT RULES 2110 AND 3010. Status: Final Sanction Detail: GS PAID A FINE OF $5,000 FOR THE SHORT SALE VIOLATIONS, $5,000 FOR THE VIOLATION OF NASD RULE 6130, AND $5,000 FOR SUPERVISION DEFICIENCIES. Summary: ON AUGUST 26, 2005, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, GS CONSENTED TO A CENSURE AND TO PAY A $15,000 TOTAL FINE. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY NASD ON OCTOBER 13, 2005.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NYSE ALLEGED AS PART OF AN INDUSTRY-WIDE SETTLEMENT THAT, PRIOR TO 2003, GOLDMAN, SACHS & CO. ("GS") FAILED TO MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATING TO ITS BLUE SHEET SUBMISSIONS, FAILED TO ESTABLISH A FOLLOW UP SYSTEM TO CONFIRM INFORMATION CONTAINED IN ITS BLUE SHEET SUBMISSIONS, AND SUBMITTED INACCURATE INFORMATION IN ITS BLUE SHEET SUBMISSIONS IN VIOLATION OF NYSE RULES 410A, 401, 342 AND 342.33. Status: Final Sanction Detail: GS PAID A MONETARY FINE OF $150,000. Summary: ON JANUARY 3, 2006, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS PARTICIPATED IN THE INDUSTRY-WIDE SETTLEMENT, CONSENTING TO A CENSURE, AND A $150,000 FINE, AND AGREED TO CONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTS IN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01 AND TO NOTIFY THE NYSE WHEN THE VALIDATION IS COMPLETE IN WRITING.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JANUARY 3, 2006, CBOT ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") EXECUTED CERTAIN EXCHANGE FOR PHYSICAL ("EFP") TRANSACTIONS IN ALLEGED VIOLATION OF CBOT REGULATION 444.01 GOVERNING TRANSFER TRADES AND EXECUTED CERTAIN EFP TRANSACTIONS FOR THE PURPOSE OF OFFSETTING EXISTING POSITIONS IN THE DELIVERY MONTH OR WITHIN TWO BUSINESS DAYS PRIOR TO FIRST DELIVERY DAY WHERE NO CHANGE OF OWNERSHIP WAS INVOLVED AND WHERE THE DATE OF EXECUTION OF THE POSITION BEING TRANSFERRED WAS NOT THE SAME AS THE TRANSFER DATE IN ALLEGED VIOLATION OF CBOT REGULATION 444.03. Status: Final Sanction Detail: GS PAID A MONETARY FINE OF $130,000. Summary: GS SUBMITTED AN OFFER OF SETTLEMENT TO THE CBOT, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO PAY A $130,000 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT FROM NOVEMBER 1, 2003 THROUGH JANUARY 15, 2004, WITH RESPECT TO CERTAIN SHORT SALE ORDERS IN A COMMON STOCK, GOLDMAN, SACHS & CO. ("GS&CO.") FAILED TO MAKE AND/OR ANNOTATE AN AFFIRMATIVE DETERMINATION THAT IT WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT IT COULD BORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE, AND WITH RESPECT TO CERTAIN SHORT SALES IN THE COMMON STOCK EFFECTED FOR THE FIRM'S PROPRIETARY ACCOUNT(S), GS&CO. FAILED TO MAKE AND/OR ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM COULD BORROW THE SECURITY OR OTHERWISE PROVIDE FOR DELIVERY BY SETTLEMENT DATE IN VIOLATION OF NASD CONDUCT RULE 3370; WITH RESPECT TO CERTAIN SHORT SALE TRANSACTIONS IN THE STOCK, GS& CO. FAILED TO REPORT EACH TRANSACTION TO NASDAQ MARKET CENTER WITH A SHORT SALE MODIFIER, AND INCORRECTLY REPORTED CERTAIN SHORT SALE TRANSACTIONS IN THE STOCK TO THE NASDAQ MARKET CENTER AS SHORT SALE EXEMPT IN VIOLATION OF NASD MARKET PLACE RULE 6130(D)(6). Status: Final Sanction Detail: GS&CO. CONSENTED TO A CENSURE AND PAID A FINE OF $20,000. Summary: ON MARCH 29, 2006, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS&CO. CONSENTED TO A CENSURE AND A $20,000 FINE. THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BY NASD ON MAY 11, 2006.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT, DURING THE PERIOD FROM JUNE 1, 2004 THROUGH JUNE 30, 2005, GS EXECUTED CERTAIN TRADES IN MUNICIPAL SECURITIES BELOW THE MINIMUM DENOMINATION (AND, IN SOME OF THOSE TRADES, DID NOT PROVIDE THE CUSTOMERS WITH WRITTEN DISCLOSURE THAT THEY WERE BUYING SECURITIES BELOW THE MINIMUM DENOMINATION) IN VIOLATION OF MSRB RULE G-15(F); AND THAT THE FIRM'S SUPERVISORY SYSTEMS AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE MINIMUM DENOMINATION RESTRICTIONS OF RULE G-15(F) IN VIOLATION OF MSRB RULE G-27. Status: Final Sanction Detail: GS CONSENTED TO A CENSURE AND ON AUGUST 3, 2006, PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $50,000. Summary: GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY THE NASD ON JULY 28, 2006. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND PAYMENT OF A $50,000 CIVIL MONEY PENALTY.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT (I) ON AUGUST 3 & 4, 2005, GS VIOLATED SEC RULE 200(G) AND NASD MARKETPLACE RULE 6130 BY FAILING TO PROPERLY MARK ORDER TICKETS IN CONNECTION WITH SEVERAL PROPRIETARY SHORT SALES, AND (II) GS TRANSMITTED TO OATS CERTAIN REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA IN VIOLATION OF NASD MARKETPLACE RULE 6955. Status: Final Sanction Detail: GS CONSENTED TO A CENSURE AND ON AUGUST 18, 2006, PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $20,000. Summary: GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY THE NASD ON JULY 20, 2006. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND PAYMENT OF A $20,000 CIVIL MONEY PENALTY.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT FROM JUNE 14, 2004 THROUGH APRIL 24, 2005, GS FAILED TO REPORT OR INCORRECTLY REPORTED CERTAIN OF THE FIRM'S INTER-DEALER TRANSACTIONS IN PARS TO THE MSRB IN VIOLATION OF MSRB RULE G-14; THAT GS FAILED TO SUBMIT TO A REGISTERED CLEARING AGENCY INFORMATION AND/OR INSTRUCTIONS REQUIRED TO ALLOW FOR AUTOMATED COMPARISON OF CERTAIN OF THE FIRM'S INTER-DEALER TRANSACTIONS IN VIOLATION OF MSRB G-12(F)(I); AND THAT THE FIRM'S SUPERVISORY SYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH MSRB RULES G-14 AND G-12(F)(I) IN CONNECTION WITH REPORTING INTER-DEALER PARS TRANSACTIONS, IN VIOLATION OF MSRB RULE G-27. Status: Final Sanction Detail: ON JANUARY 19, 2007, GS PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $85,000. Summary: GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY THE NASD ON JANUARY 3, 2007. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND PAYMENT OF $85,000 CIVIL MONEY PENALTY, AND MADE THE REQUIRED UNDERTAKINGS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE ALLEGED THAT ON JULY 18, 2006, THE FIRM CONTROLLED AGGREGATE LONG CALL, SHORT PUT POSITIONS IN THE MVR OPTION CLASS OF 36,190 OPTION CONTRACTS, WHICH EXCEEDED THE APPLICABLE POSITION LIMIT BY 4,690 OPTION CONTRACTS IN VIOLATION OF CBOE RULE 4.11. Status: Final Sanction Detail: UNDER THE CBOE'S MINOR RULE VIOLATION FINE SYSTEM, THE FIRM WAS ASSESSED A $5,000 SUMMARY FINE EFFECTIVE AUGUST 21, 2006, WHICH THE CBOE THEREAFTER DEBITS FROM THE FIRM'S ACCOUNT WITH THE APPROPRIATE CLEARING MEMBER. THE FINE WAS PAID ON SEPTEMBER 8, 2006. Summary: THE FIRM DECLINED TO CONTEST THE VIOLATION AND UNDER THE CBOE'S MINOR RULE VIOLATION FINE SYSTEM THE FIRM WAS ASSESSED A $5,000 SUMMARY FINE EFFECTIVE AUGUST 21, 2006, WHICH THE CBOE THEREAFTER DEBITS FROM THE FIRM'S ACCOUNT WITH THE APPROPRIATE CLEARING MEMBER. THE FINE WAS PAID ON SEPTEMBER 8, 2006.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE ALLEGED THAT ON OCTOBER 31, 2006, THE FIRM CONTROLLED AGGREGATE LONG CALL, SHORT PUT POSITIONS IN THE SPY OPTION CLASS OF 344,193 OPTION CONTRACTS. AFTER APPLYING THE FIRM'S SHORT UNDERLYING POSITION OF SPY SHARES AS A HEDGE, THE FIRM STILL EXCEEDED THE APPLICABLE POSITION LIMIT BY 1,839 OPTION CONTRACTS IN VIOLATION OF CBOE RULE 4.11. Status: Final Sanction Detail: UNDER THE CBOE'S MINOR RULE VIOLATION FINE SYSTEM, THE FIRM WAS ASSESSED A $5,000 SUMMARY FINE EFFECTIVE FEBRUARY 16, 2007, WHICH THE CBOE THEREAFTER DEBITS FROM THE FIRM'S ACCOUNT WITH THE APPROPRIATE CLEARING MEMBER. THE FINE WAS PAID ON MARCH 7, 2007. Summary: THE FIRM DECLINED TO CONTEST THE VIOLATION AND UNDER THE CBOE'S MINOR RULE VIOLATION FINE SYSTEM, THE FIRM WAS ASSESSED A $5,000 SUMMARY FINE EFFECTIVE FEBRUARY 16, 2007, WHICH THE CBOE THEREAFTER DEBITS FROM THE FIRM'S ACCOUNT WITH THE APPROPRIATE CLEARING MEMBER. THE FINE WAS PAID ON MARCH 7, 2007.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GS VIOLATED THE FOLLOWING NASD RULES: CONDUCT RULE 2860(B)(3) BY EXCEEDING OPTION CONTRACT POSITION LIMITS ON FOUR (4) OCCASIONS; CONDUCT RULE 2860(B)(5) BY FAILING TO TIMELY REPORT LARGE OPTION POSITIONS WITH NASD ON SEVEN (7) TRADING DAYS; MARKETPLACE RULE 5430 FOR IMPROPERLY DOUBLE REPORTING TRADES FROM OCTOBER 5, 2005 TO JANUARY 4, 2006; AND MARKETPLACE RULE 6130(B) BY FAILING TO ACCEPT OR DECLINE WITHIN TWENTY MINUTES 1,812 TRANSACTIONS IN THE TRADE REPORTING FACILITY AND THE OVER-THE-COUNTER REPORTING FACILITY FROM MAY 1, 2006 THROUGH AUGUST 31, 2006. Status: Final Sanction Detail: ON JULY 26, 2007, GS PAID A CIVIL PENALTY IN THE AMOUNT OF $40,000. Summary: GS SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY THE NASD ON JULY 11, 2007. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND PAYMENT OF A $40,000 CIVIL MONEY PENALTY.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN CONNECTION WITH AN INDUSTRY-WIDE SETTLEMENT RELATING TO PROSPECTUS DELIVERY ISSUES, THE NYSE ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") FAILED TO (I) SEND PRODUCT DESCRIPTIONS TO CERTAIN CUSTOMERS THAT PURCHASED EXCHANGE TRADED FUNDS IN VIOLATION OF NYSE RULES 1100(B) AND 342(A) (FAILURE TO SUPERVISE), AND (II) DELIVER PROSPECTUSES IN CONNECTION WITH CERTAIN CUSTOMER PURCHASES OF ASSET-BACKED SECURITIES, CERTAIN GSAM FUNDS, AND CERTAIN CORPORATE DEBT AND EQUITY SECURITIES IN VIOLATION OF NYSE RULES 401(A) AND 342(A). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATION, GS CONSENTED TO A CENSURE, AN UNDERTAKING AS DESCRIBED IN (B) AND ON OCTOBER 02, 2007, PAID A MONETARY PENALTY IN THE AMOUNT OF $375,000. Summary: THE MATTER HAS BEEN RESOLVED PURSUANT TO AN INDUSTRY-WIDE SETTLEMENT. SEE RESPONSE TO ITEM 12.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON NOVEMBER 26, 2007, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN, SACHS & CO., ("GS") ACCEPTED A STIPULATION AND CONSENT FROM THE CBOE FUTURES EXCHANGE ("CFE"). THE CFE ALLEGED THAT ON SEVERAL TRADE DATES DURING THE PERIOD FROM FEBRUARY 27, 2007 THROUGH MAY 15, 2007, GS REPORTED INACCURACIES OF CLEARED VIX FUTURES POSITIONS TO THE OPTIONS CLEARING CORPORATION AS COMPARED WITH LARGE TRADER POSITIONS IN VIOLATION OF CFE RULE 410 AND CFTC REGULATION 1.46. GS CONSENTED TO A CENSURE AND PAID A FINE OF $10,000. THE FINE WAS PAID ON FEBRUARY 28, 2008. Status: Final Sanction Detail: GS CONSENTED TO A CENSURE AND ON FEBRUARY 28, 2008, PAID A FINE IN THE AMOUNT OF $10,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO A CENSURE AND PAYMENT OF $10,000 FINE THAT WAS ACCEPTED BY THE CBOE FUTURES EXCHANGE ON NOVEMBER 26, 2007.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE DIVISION OF ENFORCEMENT ALLEGED THAT CERTAIN OF THE FIRM'S TRADERS INADVERTENTLY MISLABELED CERTAIN PROPRIETARY ORDERS SENT TO THE NYSE FOR EXECUTION AND THAT CERTAIN OTHER PROPRIETARY ORDERS BY CERTAIN FIRM TRADERS SENT TO THE NYSE FOR EXECUTION WERE INADVERTENTLY MISLABELED DUE TO A COMPUTER PROGRAMMING PROBLEM, THEREBY NOT IDENTIFYING SUCH ORDERS AS "G" ORDERS, IN ALLEGED VIOLATION OF SECTION 11(A)(1) OF THE EXCHANGE ACT AND RULE 11A1-1(T) THERE UNDER AND NYSE RULES 90 AND 410(B). THE NYSE ENFORCEMENT STAFF ALSO ALLEGED THAT (I) THE FIRM FAILED TO SUBMIT ACCURATE ACCOUNT TYPE INDICATORS FOR COMPARISON AND/OR SETTLEMENT IN VIOLATION OF NYSE RULE 132.30 AND (II) FAILED TO SUPERVISE CERTAIN ASPECTS OF THE PROPRIETARY TRADING ACTIVITIES OF EMPLOYEES INVOLVED SO AS TO PREVENT MISLABELING OF ORDERS IN LISTED EQUITY SECURITIES. Status: Final Sanction Detail: ON APRIL 8, 2008, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ON APRIL 8, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINRA ALLEGED THAT, ON CERTAIN OCCASIONS, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) FAILED TO REPORT TO THE NASDAQ MARKET CENTER THE CORRECT SYMBOL INDICATING THE ORDER TYPE OF CERTAIN TRANSACTIONS AND TO REPORT CERTAIN SHORT SALE TRANSACTIONS WITH A SHORT SALE MODIFIER IN ALLEGED VIOLATION OF NASD MARKETPLACE RULE 6130; (II) SUBMITTED TO THE ORDER AUDIT TRAIL SYSTEM ("OATS") CERTAIN ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER SUBMITTED BY THE DESTINATION MEMBER FIRM DUE TO DATA FORMATTING IRREGULARITIES IN ALLEGED VIOLATION OF NASD MARKETPLACE RULE 6955 AND (III) FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THE CORRECT CONTRA PARTY'S IDENTIFIER FOR CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES AND TO REPORT CERTAIN TRANSACTIONS TO TRACE IN A TIMELY MANNER IN ALLEGED VIOLATION OF NASD MARKETPLACE RULES 6230 (C)(6) AND 2110, RESPECTIVELY. Status: Final Sanction Detail: ON APRIL 28, 2008, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $55,000. Summary: ON APRIL 16, 2008, FINRA ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") THAT WAS EXECUTED BY THE FIRM ON MARCH 25, 2008. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ON APRIL 28, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $55,000

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE NYSE'S DIVISION OF ENFORCEMENT ALLEGED THAT, ON CERTAIN OCCASIONS, GOLDMAN, SACHS & CO. (THE "FIRM") VIOLATED (I) NYSE RULE 123(E) AND NYSE RULE 123(F) BY FAILING TO PROVIDE CERTAIN REQUIRED DATA NEEDED TO LINK THE ENTRY OF ORDERS WITH REPORTS OF EXECUTION IN THE FRONT END SYSTEMIC CAPTURE SYSTEM; AND (II) VIOLATED NYSE RULE 342 IN THAT THE FIRM FAILED TO IMPLEMENT CERTAIN CONTROLS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW IN ORDER TO FULLY REMEDIATE THE FIRM'S ORDER MANAGEMENT SYSTEM TO MEET NYSE TECHNICAL SPECIFICATIONS IN A TIMELY MANNER AND THEREBY PREVENT THE ALLEGED VIOLATIONS OF NYSE RULE S 123(E) AND 123(F). Status: Final Sanction Detail: ON APRIL 8, 2008, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $100,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ON APRIL 8, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $100,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINRA ALLEGED THAT ON JULY 31, 2007, GOLDMAN, SACHS & CO. ("GOLDMAN SACHS") 1) INACCURATELY REPORTED TO THE TRADE REPORTING FACILITY CERTAIN "RISKLESS" PRINCIPAL TRANSACTIONS IN CERTAIN DESIGNATED SECURITIES AS "PRINCIPAL" TRANSACTIONS IN ALLEGED VIOLATION OF NASD MARKETPLACE RULE 4632(D) AND 2) TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM ("OATS") CERTAIN REPORTS THAT CONTAINED INACCURATE OR INCOMPLETE DATA IN ALLEGED VIOLATION OF NASD RULE 6955. Status: Final Sanction Detail: GOLDMAN SACHS CONSENTED TO A CENSURE AND ON OCTOBER 9, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $12,500. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA AND ON OCTOBER 9, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $12,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDAQ ALLEGED THAT ON JULY 31, 2007, GOLDMAN, SACHS & CO. ("GOLDMAN SACHS") ENTERED CERTAIN ORDERS INTO THE NASDAQ MARKET CENTER AND FAILED TO APPROPRIATELY INDENTIFY WHETHER SUCH ORDERS WERE BUYS, SHORT SALES OR LONG SALES IN ALLEGED VIOLATION OF NASDAQ MARKETPLACE RULE 4755. Status: Final Sanction Detail: GOLDMAN SACHS CONSENTED TO A MONETARY PENALTY IN THE AMOUNT OF $5,000 WHICH WAS PAID ON OCTOBER 8, 2008. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS ENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY NASDAQ AND ON OCTOBER 8, 2008, PAID A MONETARY PENALTY IN THE AMOUNT OF $5,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINRA DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD FROM JANUARY 1, 2007 THROUGH JUNE 30, 2007, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT THE CONTRA-PARTY IDENTIFIER FOR CERTAIN INTER-DEALER TRANSACTIONS EFFECTED IN CERTAIN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM ("RTRS") IN ALLEGED VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULE G-14. Status: Final Sanction Detail: THE FIRM CONSENTED TO A MONETARY PENALTY IN THE AMOUNT OF $17,500 WHICH WAS PAID ON JANUARY 15, 2009. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON DECEMBER 23, 2008 AND ON JANUARY 15, 2009, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $17,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF MARKET REGULATION AND THE NYSE DIVISION OF ENFORCEMENT ALLEGED THAT, DURING THE PERIOD FROM SEPTEMBER 1, 2003 TO SEPTEMBER 30, 2004, A FIRM TRADING DESK VIOLATED FIRM GUIDELINES AND CERTAIN FINRA AND NYSE RULES IN CONNECTION WITH IMPLEMENTING A TRADING STRATEGY, AND THAT THE FIRM ALSO FAILED TO REASONABLY SUPERVISE CERTAIN ACTIVITIES OF ITS TRADING DESK. SPECIFICALLY, NYSE AND FINRA ALLEGED THAT THE FIRM'S TRADING DESK FAILED TO MAINTAIN ITS INDEPENDENCE IN THE CONDUCT OF CERTAIN OVER-THE-COUNTER STOCK TRANSACTIONS IN WHICH A FOREIGN AFFILIATE WAS THE COUNTERPARTY. NYSE AND FINRA ALLEGED THAT THE ACTIVITIES VIOLATED RULES RELATING TO TRADE REPORTING, SHORT SALES, MAINTENANCE OF PROPER BOOKS AND RECORDS AND SUPERVISORY OBLIGATIONS, INCLUDING NASD MARKETPLACE RULES 6420(A), 6420(B) AND 5430(A), 6130(D)(6), SEC RULES 17A-3 AND 17A-4 AND NASD CONDUCT RULES 2110, 3010(A) AND (B) AND 3110, NYSE RULES 342, 410B AND 440, AS WELL AS §§10(A) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 10A-1 (A) & (C) AND 17A-3 & 4 THEREUNDER. Status: Final Sanction Detail: THE FIRM CONSENTED TO A JOINT MONETARY PENALTY IN THE AMOUNT OF $600,000, PAID AS $300,000 TO EACH OF FINRA AND NYSE, WHICH WAS PAID ON DECEMBER 15, 2008. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED JOINTLY INTO AN AWC WITH FINRA AND A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH NYSE, AND ON DECEMBER 15, 2008, THE FIRM PAID A JOINT MONETARY PENALTY IN THE AMOUNT OF $600,000, PAID AS $300,000 TO EACH OF FINRA AND NYSE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINRA DEPARTMENT OF ENFORCEMENT ("DOE"), ON BEHALF OF NYSE REGULATION, INC., ALLEGED THAT BETWEEN OCTOBER 2000 AND SEPTEMBER 2005, GOLDMAN, SACHS & CO. (THE "FIRM") HAD DEFICIENCIES IN ITS REPORTING PROCESSES AND PROCEDURES THAT CAUSED IT TO INACCURATELY AND/OR UNTIMELY FILE CERTAIN REQUIRED REPORTS WITH THE NYSE, INCLUDING FORMS 121, FORMS SS20, NYSE RULE 410B REPORTS, DAILY PROGRAM TRADE REPORTS, AND NYSE RULE 421 SHORT INTEREST REPORTS. ADDITIONALLY, DOE ALLEGED THAT FROM OCTOBER 2000 UNTIL AUGUST 2004, THE FIRM FAILED TO PROVIDE FOR APPROPRIATE SUPERVISORY PROCEDURES AND CONTROL, INCLUDING A SEPARATE SYSTEM OF REASONABLE FOLLOW-UP AND REVIEW, TO CONFIRM THAT THE REPORTS WERE ACCURATELY AND TIMELY SUBMITTED. DOE ALSO ALLEGED THAT THE FIRM FAILED TO MAKE TIMELY NOTIFICATIONS OF ITS PARTICIPATION IN PUBLIC OFFERINGS PURSUANT TO NYSE RULE 460.30. THE ALLEGED REPORTING VIOLATIONS ALSO RESULTED IN ALLEGED INACCURATE BOOKS AND RECORDS IN VIOLATION OF §17 OF THE EXCHANGE ACT, RULES 17A-3 AND 17A-4 AND NYSE RULE 440. ADDITIONALLY, DURING THE TIME PERIOD JANUARY 2005 THROUGH MARCH 2006, DOE ALLEGED THAT THE FIRM SUBMITTED NUMEROUS INACCURATE ACCOUNT TYPE INDICATORS TO THE NYSE'S ON-LINE COMPARISON SYSTEM IN VIOLATION OF NYSE RULE 132.30. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ON MAY 14, 2009, PAID A MONETARY PENALTY IN THE AMOUNT OF $160,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH FINRA DEPARTMENT OF ENFORCEMENT ON BEHALF OF NYSE REGULATION, INC., WHICH WAS APPROVED BY THE NYSE HEARING BOARD ON MARCH 20, 2009 AND BECAME FINAL ON APRIL 14, 2009. ON MAY 14, 2009, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $160,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINRA DEPARTMENT OF MARKET REGULATION ALLEGED THAT 1) DURING THE PERIOD FROM JUNE 1, 2007 THROUGH AUGUST 31, 2007, GOLDMAN, SACHS & CO. (THE "FIRM") REPORTED TO THE OTC REPORTING FACILITY CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES THAT THE FIRM SHOULD NOT HAVE REPORTED, IN ALLEGED VIOLATION OF NASD RULE 6620(G) AND 2) DURING THE PERIOD FROM FEBRUARY 1, 2007 THROUGH APRIL 24, 2008, THE FIRM IMPROPERLY DOUBLE-REPORTED CERTAIN LAST SALE REPORTS IN NATIONAL MARKET SECURITIES TO THE NASD/NASDAQ TRADE REPORTING FACILITY, IN ALLEGED VIOLATION OF NASD RULE 4632(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A MONETARY PENALTY IN THE AMOUNT OF $45,000 WHICH WAS PAID ON JUNE 5, 2009. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON MAY 19, 2009 AND ON JUNE 5, 2009, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $45,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD FROM JULY 1, 2006 THROUGH DECEMBER 31, 2006, GOLDMAN, SACHS & CO. (THE "FIRM") EFFECTED TRANSACTIONS IN CERTAIN SECURITIES WITH RESPECT TO WHICH A TRADING HALT WAS IN EFFECT IN ALLEGED VIOLATION OF NASD RULES 2110 AND 3340. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A MONETARY PENALTY IN THE AMOUNT OF $10,000 WHICH WAS PAID ON OCTOBER 23, 2009. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED IN TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON OCTOBER 1, 2009 AND ON OCTOBER 23, 2009, THE FIRM PAID A MONETARY PENALTY IN THE AMOUNT OF $10,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) DURING THE PERIOD FROM JANUARY 1, 2008 THROUGH APRIL 30, 2008, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN A TIMELY MANNER THAT REQUIRED SPECIFIED MODIFIERS AND FAILED TO REPORT THE CORRECT TIME OF EXECUTION OF CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES, IN ALLEGED VIOLATION OF NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") RULES 6130(G) AND 6130(D), RESPECTIVELY, AND (II) DURING THE PERIOD FROM APRIL 1, 2008 THROUGH JUNE 30, 2008, FAILED TO TIMELY REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF NASD RULES 6230(A) AND 2110. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $40,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 13, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MARCH 15, 2010, AND ON APRIL 13, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $40,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD FROM JANUARY 1, 2009 THROUGH MARCH 31, 2009, WITH RESPECT TO 12 TRANSACTIONS, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD) RULE 2320. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $7,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 19, 2010. THE FIRM PROVIDED RESTITUTION TO THE RELEVANT MARKET PARTICIPANT IN THE AMOUNT OF $2,633.75, REPRESENTING $2,504.75 PLUS APPLICABLE INTEREST, BY MAILING OF A CHECK ON MAY 25, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON APRIL 30, 2010. ON MAY 19, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $7,500. PER THE TERMS OF THE AWC, THE FIRM PROVIDED RESTITUTION TO THE RELEVANT MARKET PARTICIPANT IN THE AMOUNT OF $2,633.75, REPRESENTING $2,504.75 PLUS APPLICABLE INTEREST, BY MAILING OF A CHECK ON MAY 25, 2010.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE INTERNATIONAL SECURITIES EXCHANGE, LLC ("ISE") ALLEGED THAT, DURING THE PERIOD FROM MAY 2009 THROUGH AUGUST 2009, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT LARGE OPTION POSITION REPORTS WITH REGARD TO CERTAIN ACCOUNTS THAT MET THE REPORTING REQUIREMENT THRESHOLD IN ALLEGED VIOLATION OF ISE RULE 415. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $17,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 4, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY ISE ON MAY 20, 2010 AND ON JUNE 4, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $17,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) DURING CERTAIN PERIODS FROM APRIL 2006 THROUGH JANUARY 2007, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT SHORT INTEREST POSITIONS IN CERTAIN FOREIGN AND REPORTABLE SECURITIES, AND ON JULY 31, 2008, AUGUST 15, 2008 AND AUGUST 29, 2008, REPORTED SHORT INTEREST POSITIONS IN CERTAIN SECURITIES WHEN THE ACTUAL SHORT INTEREST POSITION IN THE SECURITIES WAS ZERO SHARES, IN ALLEGED VIOLATION OF NASD RULE 3360; (II) DURING THE PERIOD FROM JUNE 15, 2007 TO DECEMBER 31, 2007, INADVERTENTLY FAILED TO REMOVE ITS 'EXCUSED WITHDRAWAL' STATUS AS A NASDAQ MARKET MAKER IN THREE SECURITIES AND CONSEQUENTLY, ON CERTAIN OCCASIONS INVOLVING SUCH SECURITIES, ACCEPTED A SHORT SALE ORDER IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR EFFECTED A SHORT SALE ORDER IN AN EQUITY SECURITY FOR ITS OWN ACCOUNT, IN MISTAKEN RELIANCE ON THE MARKET MAKER EXEMPTION CONTAINED IN SEC RULE 203(B)(2)(III), IN ALLEGED VIOLATION OF SEC RULE 203(B)(1) OF REGULATION SHO; (III) DURING THE PERIOD FROM JUNE 15, 2007 TO DECEMBER 31, 2007, THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE ADEQUATE WRITTEN SUPERVISORY PROCEDURES SPECIFICALLY CONCERNING SEC RULE 203(B)(3), AND THE FIRM FAILED TO PROVIDE ADEQUATE DOCUMENTATION THAT IT PERFORMED CERTAIN REVIEWS SET FORTH IN ITS WRITTEN SUPERVISORY PROCEDURES CONCERNING SEC RULE 200(G) AND NASD RULE 6130(D)(6), IN ALLEGED VIOLATION OF NASD RULES 2110 AND 3010; AND (IV) DURING THE PERIOD FROM JANUARY 1, 2008 THROUGH APRIL 30, 2008, THE FIRM FAILED TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES IN A TIMELY MANNER THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDER ENTRY IDENTIFIER (OEID), IN ALLEGED VIOLATION OF NASD RULE 6130(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $120,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 14, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON MAY 27, 2010, AND ON JUNE 14, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $120,000. ACCORDING TO THE TERMS OF THE AWC, THE FIRM AGREED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING SEC RULE 203(B)(3).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD FROM FEBRUARY 2, 2009 THROUGH MAY 14, 2009, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) SUBMITTED CERTAIN ELECTRONIC BLUE SHEETS THAT DID NOT INCLUDE THE TICKER SYMBOL, IN ALLEGED VIOLATION OF FINRA RULES 8211 AND 8213 AND (II) THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT INCLUDE ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING THE VALIDATION OF DATA ON BLUE SHEET SUBMISSIONS, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $22,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 17, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON JUNE 4, 2010, AND ON JUNE 17, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $22,500. ACCORDING TO THE TERMS OF THE AWC, THE FIRM AGREED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES CONCERNING THE VALIDATION OF DATA ON BLUE SHEET SUBMISSIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD FROM MAY 1, 2006 THROUGH APRIL 30, 2009, GOLDMAN, SACHS & CO. (THE "FIRM") REPORTED TO THE OTC REPORTING FACILITY CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES WHICH IT SHOULD HAVE NOT REPORTED, IN ALLEGED VIOLATION OF NASD RULE 6620(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $15,000 WHICH WAS PAID BY SUBMISSION OF A CHECK ON AUGUST 3, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JULY 15, 2010, AND ON AUGUST 3, 2010, THE FIRM SUBMITTED A CHECK IN PAYMENT OF A FINE IN THE AMOUNT OF $15,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIODS FROM JANUARY 1 TO MARCH 31, 2009 AND OCTOBER 1 TO DECEMBER 31, 2009, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT THE CORRECT TIME OF EXECUTION TO THE REAL-TIME TRANSACTION REPORTING SYSTEM ("RTRS") FOR CERTAIN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES AND FAILED TO REPORT INFORMATION REGARDING CERTAIN PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN A TIMELY MANNER AS PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL, IN ALLEGED VIOLATION OF MSRB RULE G-14. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $25,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 15, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON AUGUST 24, 2010 AND ON SEPTEMBER 15, 2010, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $25,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: BOSTON OPTIONS EXCHANGE ("BOX") REGULATION, LLC ALLEGED THAT: (I) DURING THE PERIOD BETWEEN JANUARY 1, 2009 AND JANUARY 31, 2010, GOLDMAN, SACHS & CO. (THE "FIRM"), ON CERTAIN OCCASIONS, TRADED AGAINST A DIRECTED ORDER THAT THE FIRM HAD PREVIOUSLY RECEIVED AND REJECTED WITHOUT FIRST EXPOSING IT TO THE BOX BOOK FOR AT LEAST THREE SECONDS, IN ALLEGED VIOLATION OF BOX TRADING RULES CHAPTER VI, MARKET MAKERS, SECTION 5, OBLIGATIONS OF MARKET MAKERS (C)(III), AND (II) THAT THE FIRM FAILED TO MAINTAIN AN ADEQUATE SYSTEM OF SUPERVISION, INCLUDING ADEQUATE WRITTEN SUPERVISORY PROCEDURES AND EFFECTIVE MONITORING REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH BOX RULES RELATING TO THE OBLIGATIONS OF A BOX MARKET MAKER WHEN HANDLING DIRECTED ORDERS, IN ALLEGED VIOLATION OF BOX TRADING RULE CHAPTER V, DOING BUSINESS ON BOX, SECTION 1, ACCESS TO AND CONDUCT ON THE BOX MARKET, (B)(IV) BOX CONDUCT. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $15,000 WHICH WAS PAID BY SUBMISSION OF A CHECK ON NOVEMBER 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY BOX ON OCTOBER 25, 2010, AND ON NOVEMBER 1, 2010, THE FIRM SUBMITTED A CHECK IN PAYMENT OF A FINE IN THE AMOUNT OF $15,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT, BETWEEN NOVEMBER 2009 AND MAY 2010, GOLDMAN, SACHS & CO. (THE "FIRM") (I) FAILED IN TWO INSTANCES TO UPDATE THE UNIFORM APPLICATIONS FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER ("FORMS U4") FOR TWO REGISTERED REPRESENTATIVES WHO RECEIVED WELLS NOTICES, AS REQUIRED BY FINRA BY-LAWS, ARTICLE V, SECTION 2(C), AND (II) DID NOT HAVE IN PLACE AN EFFECTIVE PROCEDURE TO ENSURE THAT THE COMPLIANCE GROUP RESPONSIBLE FOR FILING AMENDMENTS TO FORMS U4 WAS PROMPTLY NOTIFIED ABOUT WELLS NOTICES REGARDING REGISTERED PERSONS, IN ALLEGED VIOLATION OF NASD CONDUCT RULE 3010 AND FINRA RULE 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, AND SOLELY FOR PURPOSES OF A FINRA PROCEEDING, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, WHICH WAS ACCEPTED BY FINRA ON NOVEMBER 9, 2010, THAT INCLUDED (1) A CENSURE, (2) A FINE IN THE AMOUNT OF $650,000 WHICH WAS PAID ON NOVEMBER 18, 2010 AND (3) AN UNDERTAKING REQUIRING A CERTIFICATION BY THE FIRM WITHIN 90 CALENDAR DAYS THAT (I) IT COMPLETED A REVIEW OF ITS SUPERVISORY PROCEDURES AND SYSTEMS CONCERNING FORM U4 AMENDMENTS AND COMPLIANCE WITH FINRA BY-LAWS, ARTICLE V, SECTION 2(C) AND (II) IT IMPLEMENTED ANY NECESSARY REVISIONS. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, AND SOLELY FOR PURPOSES OF A FINRA PROCEEDING, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED BY FINRA ON NOVEMBER 9, 2010 THAT INCLUDED (1) A CENSURE, (2) A FINE IN THE AMOUNT OF $650,000 WHICH WAS PAID ON NOVEMBER 18, 2010 AND (3) AN UNDERTAKING REQUIRING A CERTIFICATION BY THE FIRM WITHIN 90 CALENDAR DAYS THAT (I) IT COMPLETED A REVIEW OF ITS SUPERVISORY PROCEDURES AND SYSTEMS CONCERNING FORM U4 AMENDMENTS AND COMPLIANCE WITH FINRA BY-LAWS, ARTICLE V, SECTION 2(C) AND (II) IT IMPLEMENTED ANY NECESSARY REVISIONS.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT ON JULY 29, 2010, GOLDMAN, SACHS & CO. (THE "FIRM") EFFECTED, DIRECTLY OR INDIRECTLY, ONE TRANSACTION IN A SECURITY WHILE A TRADING PAUSE WAS IN EFFECT, IN ALLEGED VIOLATION OF FINRA RULE 5260. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 20, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 5, 2011 AND ON APRIL 20, 2011, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $5,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN A NOTICE OF SUMMARY FINE DATED OCTOBER 13, 2011, ICE FUTURES U.S., INC. ("ICE") COMPLIANCE DEPARTMENT INFORMED GOLDMAN, SACHS & CO. (THE "FIRM") THAT, AFTER COMPLETING A REVIEW OF AUDIT TRAIL DATA CORRESPONDING TO ORDERS THAT WERE ROUTED TO THE ICE ELECTRONIC TRADE SYSTEM ("ETS") THROUGH A THIRD-PARTY FRONT-END EMPLOYED BY A CLIENT OF THE FIRM, ICE COMPLIANCE DEPARTMENT CONCLUDED THAT THE FIRM FAILED TO PROVIDE COMPLETE ELECTRONIC AUDIT TRAIL DATA CORRESPONDING TO 18 ORDERS THAT WERE ENTERED ONTO THE ETS IN OCTOBER 2010, IN ALLEGED VIOLATION OF ICE RULE 27.12A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 21, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 21, 2011.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT DURING THE PERIOD OF APRIL 1, 2007 THROUGH SEPTEMBER 30, 2010, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO COMPLY WITH MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-32 AND G-36, IN CERTAIN RESPECTS. MORE SPECIFICALLY, FINRA DEPARTMENT OF ENFORCEMENT ALLEGED THAT THE FIRM FILED 72 OUT OF 934 FILINGS LATE, RESULTING IN AN OVERALL FAILURE RATE DURING THE REVIEW PERIOD OF 7.7 PERCENT, IN ALLEGED VIOLATION OF MSRB RULES G-36 AND G-32. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $7,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON JANUARY 4, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 19, 2011 AND ON JANUARY 4, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $7,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN A ROUTINE EXAMINATION OF GOLDMAN, SACHS & CO. (THE "FIRM"), CME GROUP MARKET REGULATION ("CME") MADE FINDINGS THAT, FROM SEPTEMBER 29, 2011 THROUGH NOVEMBER 25, 2011, CERTAIN FIRM TRADING DOCUMENTS CONTAINED AT LEAST ONE DATA ENTRY ERROR, IN ALLEGED VIOLATION OF CHICAGO MERCANTILE EXCHANGE INC. RULE 536.F. Status: Final Sanction Detail: THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON FEBRUARY 7, 2012. Summary: ON FEBRUARY 8, 2012, CME FINED THE FIRM $5,000 FOR ALLEGED VIOLATIONS OF RULE 536.F, AND ON FEBRUARY 7, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE LEGAL SECTION OF THE MARKET REGULATION DEPARTMENT AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, ON BEHALF OF NYSE REGULATION, INC., ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") IN ITS CAPACITY AS A NYSE SUPPLEMENTAL LIQUIDITY PROVIDER (SLP) DURING THE PERIOD BETWEEN JANUARY 2009 AND AT LEAST SEPTEMBER 2011, FAILED TO MAINTAIN SUPERVISORY PROCEDURES, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WERE REASONABLY DESIGNED TO DETECT AND PREVENT POTENTIALLY VIOLATIVE WASH TRADING ACTIVITY, IN ALLEGED VIOLATION OF NYSE RULE 342. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $85,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 16, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A STIPULATION OF FACTS AND CONSENT TO PENALTY WITH NYSE REGULATION, INC., WHICH WAS APPROVED BY THE NYSE HEARING BOARD ON APRIL 4, 2012 AND BECAME FINAL ON APRIL 29, 2012. ON APRIL 16, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $85,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") HAS ALLEGED THAT A FORMALIZED BUSINESS PROCESS AT GOLDMAN, SACHS & CO. (THE "FIRM") KNOWN AS TRADING HUDDLES AS WELL ITS ASYMMETRIC SERVICE INITIATIVE ("ASI") CREATED A SUBSTANTIAL RISK THAT MATERIAL NON-PUBLIC INFORMATION CONCERNING RESEARCH ANALYSTS' PUBLISHED RESEARCH COULD BE DISCLOSED TO CERTAIN PRIORITY CLIENTS. FINRA FURTHER ALLEGED THAT THE FIRM VIOLATED (I) NASD RULES 3010 AND 2110 AND FINRA RULE 2010 BY INSTITUTIONALIZING TRADING HUDDLES AND ASI WITHOUT ESTABLISHING ADEQUATE POLICIES, PROCEDURES AND CONTROLS; (II) NASD RULES 3010 AND 2110 AND FINRA RULE 2010 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE REASONABLE SYSTEMS AND PROCEDURES TO SUPERVISE RESEARCH ANALYST COMMUNICATIONS TO PREVENT AND DETECT THE PREVIEWING OF MATERIAL NON-PUBLIC CHANGES TO AN ANALYST'S PUBLISHED RESEARCH BY EQUITY RESEARCH ANALYSTS AND TO MONITOR FOR POSSIBLE TRADING IN ADVANCE OF PUBLISHED RESEARCH OR CONVICTION LIST CHANGES; AND (III) FINRA RULES 5280 AND 2010 BY FAILING TO ESTABLISH AND MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT TRADING AHEAD OF RESEARCH REPORTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $22 MILLION WHICH WAS PAID ON APRIL 19, 2012, OF WHICH $11 MILLION WAS PAID ACCORDING TO AN ADMINISTRATIVE ORDER ISSUED BY THE U.S. SECURITIES AND EXCHANGE COMMISSION RELATING TO ITS INVESTIGATION OF THE FIRM'S TRADING HUDDLES. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ON APRIL 12, 2012 (THE "AWC") WITH FINRA PURSUANT TO WHICH THE FIRM CONSENTED TO (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $22 MILLION, WHICH WAS PAID ON APRIL 19, 2012, OF WHICH $11 MILLION WAS PAID ACCORDING TO AN ADMINISTRATIVE ORDER ISSUED BY THE U.S. SECURITIES AND EXCHANGE COMMISSION RELATING TO ITS INVESTIGATION OF THE FIRM'S TRADING HUDDLES; AND (III) UNDERTAKE A COMPREHENSIVE REVIEW OF THE FIRM'S SUPERVISORY AND COMPLIANCE POLICIES AND PROCEDURES CONCERNING THE ALLEGEDLY VIOLATIVE CONDUCT ADDRESSED IN THE AWC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE APPROXIMATE PERIOD FROM IN OR ABOUT JANUARY 2004 THROUGH IN OR ABOUT MAY 2010, MISMARKED CERTAIN OPTIONS ORDERS WITH AN IMPROPER ORIGIN CODE RESULTING IN THE EXECUTION OF ORDERS AND CROSSES, SOME OF WHICH MAY HAVE BEEN AFFORDED PRIORITY TO WHICH THEY WERE NOT ENTITLED, IN ALLEGED VIOLATION OF CBOE RULES 4.1, 4.2, 4.22, 6.51, 6.74, 15.1 AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO MAINTAIN SUPERVISORY SYSTEMS AND CONTROLS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CBOE RULES RELATING TO ORDER ENTRY, IN ALLEGED VIOLATION OF CBOE RULE 4.2. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO CBOE AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $3,750,000 WAS PAID TO CBOE BY SUBMISSION OF A WIRE ON SEPTEMBER 27, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A LETTER OF CONSENT WHICH WAS APPROVED BY THE CBOE BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 20, 2012 AND ON SEPTEMBER 27, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $3,750,000. THE LETTER OF CONSENT IS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES (I) BATS EXCHANGE, INC. (BATS); (II) BOSTON OPTIONS EXCHANGE REGULATION, LLC (BOXR); (III) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); (IV) THE NASDAQ OPTIONS MARKET (NOM); (V) NASDAQ OMX PHLX, INC. (PHLX): (VI) NYSE AMEX LLC (AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: INTERNATIONAL SECURITIES EXCHANGE, LLC ("ISE") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD BETWEEN JANUARY 2004 AND MAY 2010, IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF ISE RULES 400, 712(A), AND 1400(A), AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, IN ALLEGED VIOLATION OF ISE RULE 401. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO ISE AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $1,074,788 WAS PAID BY SUBMISSION OF A WIRE TO ISE ON OCTOBER 19, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS APPROVED BY ISE BUSINESS CONDUCT COMMITTEE AND A SUMMARY OF WHICH WAS PUBLISHED BY ISE ON SEPTEMBER 20, 2012, AND ON OCTOBER 19, 2012, THE FIRM SUBMITTED A WIRE TO ISE IN PAYMENT OF THE FINE IN THE AMOUNT OF $1,074,788. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) BATS EXCHANGE, INC. (BATS); (III) BOX OPTIONS EXCHANGE, LLC (BOX); (IV) THE NASDAQ OPTIONS MARKET (NOM); (V) NASDAQ OMX PHLX, INC. (PHLX); (VI) NYSE AMEX LLC (AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDAQ OMX PHLX, LLC. ("PHLX") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"), DURING THE PERIOD BETWEEN JANUARY 2004 AND MAY 2010 (THE "RELEVANT PERIOD"): (I) IMPROPERLY MARKED CERTAIN OPTIONS ORDERS ON THE EXCHANGE AS "CUSTOMER" THROUGH VARIOUS PROPRIETARY ORDER ENTRY SYSTEMS EMPLOYED BY THE FIRM TO SEND OPTIONS ORDERS TO THE EXCHANGE, IN ALLEGED VIOLATION OF PHLX RULES 707, 760 AND 785, AND SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 PROMULGATED THEREUNDER AND (II) FAILED TO REMEDIATE CERTAIN CODING DEFICIENCIES UNTIL AFTER THE RELEVANT PERIOD, AND TO HAVE SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE EXCHANGE'S ORIGIN CODE REQUIREMENTS, EACH IN ALLEGED VIOLATION OF PHLX RULE 748(G). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $6,750,000 IN THE AGGREGATE, PAYABLE TO PHLX AND SEVEN OTHER OPTION EXCHANGES, OF WHICH $448,459 WAS PAID BY SUBMISSION OF A CHECK TO PHLX ON OCTOBER 22, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE AND CENSURE AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WITH THE PHLX BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 25, 2012, AND ON OCTOBER 22, 2012, THE FIRM SUBMITTED A CHECK TO PHLX IN PAYMENT OF THE FINE IN THE AMOUNT OF $448,459. THE OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING OPTIONS EXCHANGES: (I) THE CHICAGO BOARD OPTIONS EXCHANGE, INC. (CBOE); (II) BATS EXCHANGE, INC. (BATS); (III) BOSTON OPTIONS EXCHANGE LLC (BOX); (IV) THE NASDAQ OPTIONS MARKET (NOM); (V) INTERNATIONAL SECURITIES EXCHANGE, LLC (ISE); (VI) NYSE AMEX LLC (NYSE AMEX); AND (VII) NYSE ARCA, INC. (ARCA).

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT DURING THE PERIOD OF JANUARY 19, 2010 THROUGH MARCH 18, 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO REPORT AND/OR INACCURATELY REPORTED, IN CERTAIN INSTANCES, THE CONTRA PARTY FOR CERTAIN REPORTABLE OPTIONS POSITIONS, IN ALLEGED VIOLATION OF FINRA RULE 2360(B)(5). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $50,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 11, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON NOVEMBER 21, 2012, AND ON DECEMBER 11, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $50,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT DURING THE PERIODS OF JULY 1 TO SEPTEMBER 30, 2009, AND APRIL 1 TO JUNE 30, 2010, GOLDMAN, SACHS & CO. (THE "FIRM") IMPROPERLY TRANSMITTED CERTAIN EXECUTION OR COMBINED ORDER/EXECUTION REPORTS WITH A REPORTING EXCEPTION CODE (REC) OF "P" TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REQUIRED TO BE MATCHED TO A RELATED TRADE REPORT IN A FINRA TRADE REPORTING SYSTEM, IN ALLEGED VIOLATION OF FINRA RULE 7450. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $15,000 WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 24, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 12, 2012, AND ON DECEMBER 24, 2012, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $15,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT DURING THE PERIOD BETWEEN FEBRUARY 2006 AND DECEMBER 2010, GOLDMAN, SACHS & CO. (THE "FIRM") UNFAIRLY REQUESTED AND RECEIVED REIMBURSEMENTS FOR CERTAIN CALIFORNIA PUBLIC SECURITIES ASSOCIATION (CAL PSA) UNDERWRITING ASSESSMENTS, IN ALLEGED VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULE G-17, AND FAILED TO ADOPT, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH MSRB RULE G-17, IN ALLEGED VIOLATION OF MSRB RULE G-27. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $568,000, WHICH WAS PAID BY SUBMISSION OF A CHECK ON JANUARY 10, 2013, AND TO PAY RESTITUTION IN THE AMOUNT OF $115,997.50 AND SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE DOCUMENTED EFFORTS TO EFFECT RESTITUTION TO THE APPLICABLE ISSUERS IN CALIFORNIA TO WHICH THE FIRM HAS NOT YET PROVIDED RESTITUTION. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON DECEMBER 27, 2012, AND ON JANUARY 10, 2013, THE FIRM SUBMITTED A CHECK IN PAYMENT OF THE FINE IN THE AMOUNT OF $568,000. THE FIRM CONSENTED TO PAY RESTITUTION IN THE AMOUNT OF $115,997.50 AND TO SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE DOCUMENTED EFFORTS TO EFFECT RESTITUTION TO THE APPLICABLE ISSUERS IN CALIFORNIA TO WHICH THE FIRM HAS NOT YET PROVIDED RESTITUTION, AND WITHIN 180 DAYS OF THE ISSUANCE OF THE AWC, TO CERTIFY WITH FINRA THAT IT HAS COMPLETED A REVIEW OF RELEVANT WRITTEN SUPERVISORY PROCEDURES AND SYSTEMS AND IMPLEMENTED NECESSARY REVISIONS TO SUCH PROCEDURES AND SYSTEMS IN ORDER TO ENSURE THAT THE PROCEDURES AND SYSTEMS ARE IN COMPLIANCE WITH MSRB RULE G-27.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CHICAGO BOARD OF TRADE ("CBT") ALLEGED THAT DURING A REVIEW OF GOLDMAN, SACHS & CO. (THE "FIRM") POSITION REPORTING DURING DECEMBER 2012, THE FIRM FAILED TO ACCURATELY SUBMIT CERTAIN LONG POSITIONS ELIGIBLE FOR DELIVERY, IN ALLEGED VIOLATION OF CBT RULE 807. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CBT IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON FEBRUARY 13, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CBT IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON FEBRUARY 13, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD OF SEPTEMBER 16-17, 2009, TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) 13 REPORTS THAT CONTAINED CERTAIN INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA, IN ALLEGED VIOLATION OF FINRA RULE 7450, AND (II) DURING THE PERIOD OF JULY 13-14, 2010, ERRONEOUSLY SUBMITTED A DUPLICATE NON-TAPE REPORT WITH THE .RX MODIFIER TO THE FINRA/NASDAQ TRADE REPORTING FACILITY, IN ALLEGED VIOLATION OF FINRA RULE 7230A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $20,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 4, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MARCH 15, 2013, AND ON APRIL 4, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) DURING THE PERIOD OF JULY 1 TO SEPTEMBER 30, 2010, TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR CERTAIN S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C), AND (II) DURING THE PERIOD OF APRIL 1 TO JUNE 30, 2011, TO REPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION FOR CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES, AND TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)8 AND SEC RULE 17A-3, RESPECTIVELY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $39,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 4, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MARCH 15, 2013, AND ON APRIL 4, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $39,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION, ON BEHALF OF THE NASDAQ STOCK MARKET LLC ("NASDAQ"), ALLEGED THAT DURING THE PERIOD OF SEPTEMBER 16-17, 2009, GOLDMAN, SACHS & CO. (THE "FIRM") ENTERED 10 ORDERS INTO THE NASDAQ/SINGLEBOOK SYSTEM THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE, OR LONG SALE, IN ALLEGED VIOLATION OF NASDAQ RULE 4755, AND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF NASDAQ, IN ALLEGED VIOLATION OF NASDAQ RULES 3010 AND 2110. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $17,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 11, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, FINE AND UNDERTAKING AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS ACCEPTED BY FINRA ON BEHALF OF NASDAQ ON MARCH 12, 2013, AND ON APRIL 11, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $17,500. IN THE UNDERTAKING, THE FIRM CONSENTED TO REVISE AND IMPLEMENT APPLICABLE WRITTEN SUPERVISORY PROCEDURES AND, WITHIN 90 BUSINESS DAYS OF THE ACCEPTANCE OF THE AWC, TO PROVIDE A REPRESENTATION TO FINRA THAT THE APPLICABLE WRITTEN SUPERVISORY PROCEDURES HAVE BEEN REVISED AND IMPLEMENTED.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CHICAGO MERCANTILE EXCHANGE INC. ("CME") MARKET REGULATION DEPARTMENT ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF AUGUST 1, 2012 THROUGH OCTOBER 5, 2012 REFLECTED AN UNACCEPTABLE COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE, IN ALLEGED VIOLATION OF CME RULE 536.F. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MARCH 19, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MARCH 19, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) FROM MAY 1 TO AUGUST 31, 2010, TO REPORT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY BY 8:00 P.M. EASTERN TIME CERTAIN TRANSACTIONS THAT REQUIRED A .RO, .RA OR .RX MODIFIER, IN ALLEGED VIOLATION OF FINRA RULE 7230A(G); (II) FROM SEPTEMBER 1 TO DECEMBER 31, 2010, TO TRANSMIT TO THE OTC REPORTING FACILITY WITHIN 30 SECONDS AFTER EXECUTION CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES, IN ALLEGED VIOLATION OF FINRA RULES 6622(A) AND 2010, AND TO REPORT TO THE OTC REPORTING FACILITY THE CORRECT TIME OF EXECUTION FOR CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 7330(D)(4); AND (III) FROM JANUARY 1 TO APRIL 30, 2011, TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULES 7230A(B) AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $47,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 18, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 2, 2013, AND ON APRIL 18, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $47,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") NETTED DOWN 25 JANUARY 2013 COMEX COPPER FUTURES CONTRACTS ON JANUARY 9, 2013, IN ALLEGED VIOLATION OF CME RULE 854.B. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $1,000, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MAY 9, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $1,000, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MAY 9, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("BCC") PANEL (THE "PANEL") ALLEGED THAT: (I) IN DECEMBER 2008, CME GROUP INC. MARKET REGULATION DEPARTMENT ("MARKET REGULATION") WAS IN REGULAR CONTACT WITH GOLDMAN, SACHS & CO. (THE "FIRM") REGARDING A LARGE POSITION HELD BY THE FIRM IN A TREASURY FUTURES CONTRACT WHICH WAS SET TO EXPIRE (THE "CONTRACT"), AND THAT THE FIRM DID NOT ADEQUATELY RELAY CERTAIN MARKET REGULATION CONCERNS TO CERTAIN FIRM TRADERS; AND (II) DURING THE FINAL MINUTE PRIOR TO EXPIRATION OF THE CONTRACT, A FIRM TRADER EXECUTED A MARKET ORDER, AND THEN SUBMITTED A LIMIT ORDER, WHICH WAS ONLY PARTIALLY FILLED AS A RESULT OF ILLIQUIDITY IN THE MARKET, AND THAT DURING THE COURSE OF THESE ORDERS AND SUBSEQUENT FILLS, THE MARKET TRADED UP RESULTING IN THE FINAL PRICE OF THE CONTRACT SETTLING ABOVE WHAT WAS INDICATED BY THE DECEMBER-MARCH CALENDAR SPREAD, IN ALLEGED VIOLATION OF CBOT RULE 432.W. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $875,000 WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON JUNE 12, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON JUNE 29, 2013, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON MAY 31, 2013. ON JUNE 12, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $875,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT (I) DURING THE PERIOD OF JANUARY 1, 2011 THROUGH MARCH 31, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THE CORRECT TIME OF TRADE EXECUTION FOR CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)(8); (II) REPORTED TO TRACE CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS NOT REQUIRED TO REPORT, IN ALLEGED VIOLATION OF FINRA RULE 6730; (III) FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS, IN ALLEGED VIOLATION OF SEC RULE 17A-3 AND NASD RULE 3110; AND (IV) FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)(6). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $25,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 7, 2013. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 22, 2013, AND ON NOVEMBER 7, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $25,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION, ON BEHALF OF THE NEW YORK STOCK EXCHANGE LLC ("NYSE"), ALLEGED THAT, DURING THE PERIOD BETWEEN APRIL 1, 2009 AND SEPTEMBER 15, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) SUBMITTED CERTAIN TRADES WITH INACCURATE ACCOUNT TYPE INDICATORS (ATIS) TO THE NYSE FOR COMPARISON AND/OR SETTLEMENT, IN ALLEGED VIOLATION OF NYSE RULE 132(A); AND (II) FAILED TO IMPLEMENT ADEQUATE SYSTEMS AND CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE 132, IN ALLEGED VIOLATION OF NYSE RULE 342. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $77,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 5, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON BEHALF OF THE NYSE ON APRIL 16, 2014, AND ON MAY 5, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $77,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF JULY 2010 THROUGH JUNE 2011: (I) CERTAIN SYSTEMS OF GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ROUTE INTERMARKET SWEEP ORDERS (ISOS) TO BATS Y, EDGE A, AND EDGE X, IN ALLEGED VIOLATION OF SEC RULE 611(A)(2); AND THAT (II) THE FIRM FAILED TO IMPLEMENT REASONABLE PROCEDURES, INCLUDING APPROPRIATE TESTING, TO ENSURE THAT THE ORDER ROUTING LOGIC IN CERTAIN TRADING SYSTEMS WAS UPDATED TO ACCOUNT FOR ALL CURRENT MARKET VENUES TO WHICH THE FIRM ROUTED ORDERS TO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $15,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 28, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 14, 2014, AND ON APRIL 28, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $15,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO MAINTAIN A COMPLETE AUDIT TRAIL FOR A MINIMUM OF 5 YEARS, IN ALLEGED VIOLATION OF CME RULE 536.B.2. Status: Final Sanction Detail: THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 19, 2014. Summary: THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 19, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") SUBMITTED A POSITION ADJUSTMENT DECREASING OPEN INTEREST IN THE JUNE 2013 10-YR USD INTEREST RATE SWAP CONTRACT THAT RESULTED IN AN OFFSET OF CONTRACTS REPRESENTING MORE THAN ONE PERCENT OF THE REPORTED OPEN INTEREST, IN ALLEGED VIOLATION OF CBT RULE 854. Status: Final Sanction Detail: THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 27, 2014. Summary: THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 27, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) BETWEEN 2004 AND 2012, SUBMITTED TO FINRA, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), AND OTHER REGULATORS, BLUE SHEETS THAT INACCURATELY REPORTED CERTAIN SHORT-SALE TRANSACTIONS AS LONG-SALE TRANSACTIONS, AND BETWEEN NOVEMBER 2012 AND JANUARY 2013, FAILED TO INCLUDE CERTAIN TRANSACTIONS IN ITS BLUE SHEETS SUBMISSIONS TO FINRA, EACH IN ALLEGED VIOLATION OF SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 17A-4(J) AND 17A-25 THEREUNDER; NASD RULES 8211, 8213, AND 2110 (FOR INACCURATE BLUE SHEETS SUBMITTED BEFORE DECEMBER 15, 2008); AND FINRA RULES 8211, 8213, AND 2010; AND (II) BETWEEN 2004 AND 2013, DID NOT HAVE IN PLACE AN ADEQUATE AUDIT SYSTEM PROVIDING FOR ACCOUNTABILITY OF ITS BLUE SHEET SUBMISSIONS, IN ALLEGED VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(F)(3)(V) THEREUNDER; NASD RULE 2110 AND FINRA RULE 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,000,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JUNE 18, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON JUNE 4, 2014, AND ON JUNE 18, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $1,000,000. THE FIRM FURTHER AGREED THAT IT HAS CONDUCTED A REVIEW OF ITS POLICIES, SYSTEMS AND PROCEDURES RELATING TO THE DEFICIENCIES ALLEGED IN THIS AWC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF JANUARY 1, 2012 THROUGH APRIL 30, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULES 7230A(B) AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $20,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JULY 29, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JULY 16, 2014, AND ON JULY 29, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF OCTOBER 1, 2011 THROUGH MARCH 31, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO TIMELY REPORT CERTAIN NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6760(C). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $7,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 13, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON AUGUST 1, 2014, AND ON AUGUST 13, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $7,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, FOR THE PERIOD BETWEEN APRIL 1, 2012 AND JUNE 30, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") IMPROPERLY SUBMITTED CERTAIN EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT THE FIRM WAS NOT REQUIRED TO REPORT, IN ALLEGED VIOLATION OF FINRA RULE 7450. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 16, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 6, 2014, AND ON OCTOBER 16, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $5,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (A) BASED UPON CERTAIN ITEMS FROM THE 2011 TRADING AND MARKET MAKING SURVEILLANCE EXAMINATION OF THE FIRM WHICH EXAMINED TRADE DATES OCTOBER 5, 2011 AND OCTOBER 6, 2011, FAILED TO (I) REPORT CERTAIN APPARENT CUSTOMER ORDER EVENTS TO THE ORDER AUDIT TRAIL SYSTEM ("OATS"); (II) PROVIDE A RECORD OF CERTAIN ORDER ROUTE REPORTS SUBMITTED TO OATS; AND (III) ACCURATELY APPEND THE SHORT SALE INDICATOR TO CERTAIN FINRA/NASDAQ TRADE REPORTING FACILITY (TRF) REPORTS, IN ALLEGED VIOLATION OF FINRA RULES 7450, 7440 AND 6182, RESPECTIVELY; AND (IV) DOCUMENT "STOPPED STOCK" INFORMATION ON CERTAIN CUSTOMER ORDER MEMORANDA, PROVIDE CERTAIN COMPLETE AND/OR ACCURATE CUSTOMER ORDER MEMORANDA, AND ACCURATELY MARK CERTAIN SELL TRANSACTIONS ON THE FIRM'S TRADING LEDGER, IN ALLEGED VIOLATION OF SECTION 17 OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED, AND RULE 17(A)-3 THEREUNDER, AS WELL AS NASD RULE 3110; AND (B) BASED UPON CERTAIN ITEMS FROM THE 2012 TRADING AND MARKET MAKING SURVEILLANCE EXAMINATION OF THE FIRM WHICH EXAMINED TRADE DATES OCTOBER 11, 2012 AND OCTOBER 12, 2012, (I) INCORRECTLY REPORTED THE NUMBER OF SHARES EXECUTED AT THE MARKET CENTER AS AWAY EXECUTED SHARES IN CERTAIN INSTANCES IN THE FIRM'S RULE 605 OF REGULATION NMS REPORT, AND (II) TRANSMITTED CERTAIN REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TO OATS, IN ALLEGED VIOLATION OF RULE 605 OF REGULATION NMS AND FINRA RULE 7450, RESPECTIVELY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $55,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 13, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 24, 2014, AND ON NOVEMBER 13, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $55,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM: (I) ON SEVERAL OCCASIONS BETWEEN DECEMBER 30, 2009, AND NOVEMBER 27, 2012, EXECUTED MULTIPLE BLOCK TRADES FOR CUSTOMERS IN VARIOUS CBOT INTEREST RATE FUTURES CONTRACTS THAT WERE NOT REPORTED TO CBOT WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, REPORTED TO CBOT INACCURATE EXECUTION TIMES OF CERTAIN BLOCK TRADES, FAILED TO MAINTAIN ACCURATE RECORDS WITH RESPECT TO CERTAIN BLOCK TRADE EXECUTIONS, AND DID NOT ACCURATELY REFLECT THE TIME OF EXECUTION ON CERTAIN ORDER TICKETS, IN ALLEGED VIOLATION OF CBOT RULES 526.F AND 536.A; AND (II) ON JANUARY 6, 2010, AND ON AUGUST 1, 2013, THE FIRM CONSUMMATED A BLOCK TRADE WITH A CUSTOMER AND, AFTER REALIZING THE TRADE WAS NOT REPORTED TO CBOT WITHIN THE REQUISITE TIME LIMIT, CANCELED THE BLOCK TRADE AND EXECUTED AN IDENTICAL TRADE WITH THE SAME CUSTOMER, IN ALLEGED VIOLATION OF CBOT RULE 526.F. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $90,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON NOVEMBER 7, 2014. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $90,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A PANEL OF THE CHICAGO MERCANTILE EXCHANGE ("CME") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM: (I) ON THREE OCCASIONS BETWEEN NOVEMBER 28, 2011, AND JUNE 26, 2013, EXECUTED CERTAIN BLOCK TRADES FOR CUSTOMERS IN CME CONTRACTS THAT WERE NOT REPORTED TO CME WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, IN VIOLATION OF CME RULE 526.F, AND ON TWO ADDITIONAL OCCASIONS, EXECUTED BLOCK ELIGIBLE SPREAD TRADES WHERE EACH LEG OF THE SPREAD WAS NOT EXECUTED AT THE SAME PRICE, IN ALLEGED VIOLATION OF CME RULE 526.D; (II) ON JUNE 26, 2013, CONSUMMATED A BLOCK TRADE TO SELL CURRENCY FUTURES TO A CUSTOMER AND, AFTER REALIZING THE TRADE WAS NOT REPORTED TO CME WITHIN THE REQUISITE TIME LIMIT, CANCELED THE BLOCK TRADE AND EXECUTED AN IDENTICAL TRADE WITH THE SAME CUSTOMER, IN ALLEGED VIOLATION OF CME RULE 526.F; AND (III) ON ONE OF THE ABOVE OCCASIONS, FAILED TO MAINTAIN ACCURATE RECORDS WITH RESPECT TO THE BLOCK TRADE EXECUTIONS IN THAT AN ORDER TICKET WAS MISSING, AND ON AT LEAST ONE OF THE ABOVE OCCASIONS, REPORTED TO CME AN INACCURATE EXECUTION TIME OF THE BLOCK TRADE, IN ALLEGED VIOLATION OF CME RULES 536.A AND 526.F. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $70,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON NOVEMBER 7, 2014. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $70,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A PANEL OF THE NEW YORK MERCANTILE EXCHANGE ("NYMEX") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM, ON JANUARY 18, 2013, AND JANUARY 23, 2013: (I) EXECUTED CERTAIN BLOCK TRADES IN COMMODITIES FUTURES CONTRACTS THAT WERE NOT REPORTED TO NYMEX WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION; (II) REPORTED INACCURATE EXECUTION TIMES FOR THESE BLOCK TRADES; AND (III) EXECUTED THE TRADES AS SPREAD TRANSACTIONS BUT MISREPORTED THEM AS OUTRIGHT TRANSACTIONS, EACH IN ALLEGED VIOLATION OF NYMEX RULE 526.F. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $40,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON NOVEMBER 7, 2014. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $40,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A PANEL OF THE CHICAGO MERCANTILE EXCHANGE ("CME") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT ON ONE OR MORE OCCASIONS FROM 2010 THROUGH 2013, THE FIRM FAILED TO PROPERLY REGISTER CERTAIN TAG50 USER IDS AND ALLOWED CERTAIN ORDERS TO BE ENTERED ON GLOBEX USING INCORRECT TAG50 USER IDS, IN ALLEGED VIOLATION OF CME RULE 576. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $2,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON NOVEMBER 7, 2014. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $2,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT ON ONE OR MORE OCCASIONS FROM 2010 THROUGH 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO PROPERLY REGISTER CERTAIN TAG50 USER IDS AND ALLOWED CERTAIN ORDERS TO BE ENTERED ON GLOBEX USING INCORRECT TAG50 USER IDS, IN ALLEGED VIOLATION OF CBOT RULE 576. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON NOVEMBER 7, 2014. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $1,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE FUTURES U.S., INC. ("IFUS") COMPLIANCE DEPARTMENT ISSUED A NOTICE OF SUMMARY FINE, DATED NOVEMBER 19, 2014, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT: (I) ON FEBRUARY 11, 2013 AND MARCH 11, 2013, THE FIRM FAILED TO ENTER CERTAIN CROSSING ORDERS ("CO") FOR CERTAIN OPPOSING ORDERS SUBMITTED SIMULTANEOUSLY BY A COMMON ACCOUNT MANAGER ON BEHALF OF ACCOUNTS WITH SEPARATE BENEFICIAL OWNERS; AND (II) SPECIFICALLY, ON EACH DATE, THE FIRM ENTERED CERTAIN OPPOSING ORDERS WITHOUT THE USE OF IFUS CO FUNCTIONALITY, RESULTING IN CERTAIN FUTURES SPREADS TRANSACTING AGAINST ONE ANOTHER, IN VIOLATION OF IFUS RULE 4.02(I)(2). Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $15,000, WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 28, 2014. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $15,000, WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 28, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") ALLEGED THAT, DURING THE APPROXIMATE PERIOD FROM IN OR ABOUT JANUARY 2009 THROUGH IN OR ABOUT FEBRUARY 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) ON CERTAIN OCCASIONS, TO GRANT PRIORITY TO THE HIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WAS AVAILABLE, AND TO USE DUE DILIGENCE TO EXECUTE CERTAIN ORDERS AT THE BEST PRICES AVAILABLE, IN ALLEGED VIOLATION OF CBOE RULES 6.45A, 6.45B AND 6.73; AND (II) TO ASSURE COMPLIANCE WITH SUCH RULES, IN ALLEGED VIOLATION OF CBOE RULE 4.2. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $20,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 9, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF CONSENT WHICH WAS APPROVED BY THE CBOE BUSINESS CONDUCT COMMITTEE ON DECEMBER 1, 2014, AND ON DECEMBER 9, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $20,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT DURING THE PERIOD OF AUGUST 2003 THROUGH DECEMBER 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO: (I) HAVE ADEQUATE PROCEDURES, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO IDENTIFY MATERIAL CHANGES IN ACCESS AND MANAGEMENT OF CERTAIN ACCOUNTS THAT WERE GRANTED AN EXEMPTION FROM AGGREGATING OPTIONS POSITIONS BY THE INTERMARKET SURVEILLANCE GROUP (ISG) IN ORDER TO ASSURE THAT PROPER NOTICE WAS GIVEN TO CERTAIN OPTIONS EXCHANGES (THE "EXCHANGES"); AND (II) PROVIDE NOTICE TO THE EXCHANGES OF ANY SUCH CHANGES, IN ALLEGED VIOLATION OF NASD RULES 3010 AND 2110 (FOR CONDUCT PRIOR TO DECEMBER 15, 2008) AND FINRA RULE 2010 (FOR CONDUCT ON AND AFTER DECEMBER 15, 2008). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $18,750, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JANUARY 9, 2015. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 23, 2014, AND ON JANUARY 9, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $18,750.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE FUTURES EXCHANGE, LLC ("CFE") ALLEGED THAT GOLDMAN, SACHS & CO. FAILED TO DESIGNATE ONE CFE OFF EXCHANGE TRADE ON AN ACCOUNT STATEMENT AS A BLOCK TRADE, AND TO PROVIDE AN ORDER TICKET FOR ANOTHER BLOCK TRADE, EACH IN ALLEGED VIOLATION OF CFE RULE 415(E). Status: Final Sanction Detail: THE CFE IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $2,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON APRIL 9, 2015. Summary: THE CFE IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $2,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON APRIL 9, 2015.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE FUTURES U.S., INC. ("IFUS") COMPLIANCE DEPARTMENT ISSUED A NOTICE OF SUMMARY FINE, DATED MAY 26, 2015, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 4.07 ON MARCH 9, 2015 BY FAILING TO REPORT A BLOCK TRADE IN A TIMELY MANNER. Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON JUNE 9, 2015. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON JUNE 9, 2015.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO APPROPRIATELY REGISTER WITH THE CBOE: (I) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT OCTOBER 10, 2014, FIVE (5) ASSOCIATED PERSONS AS A PROPRIETARY TRADER (PT), AND (II) BY NOVEMBER 5, 2011, ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER (CT), EACH IN ALLEGED VIOLATION OF CBOE RULE 3.6A. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $15,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON JULY 30, 2015. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE. ON JULY 16, 2015, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON JULY 30, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $15,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: C2 OPTIONS EXCHANGE, INCORPORATED ("C2") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT, FROM ON OR ABOUT MARCH 27, 2013 THROUGH ON OR ABOUT JULY 11, 2014, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO APPROPRIATELY REGISTER ITS FINANCIAL AND OPERATIONS PRINCIPAL AS A FINANCIAL AND OPERATIONS PRINCIPAL (FN) WITH C2, IN ALLEGED VIOLATION OF C2 RULE 3.4. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $2,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON JULY 30, 2015. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE. ON JULY 16, 2015, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON JULY 30, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $2,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBT ALLEGED THAT GOLDMAN, SACHS & CO. VIOLATED CBT RULES AND REGULATIONS WITH RESPECT TO SEGREGATED AND SECURED ACCOUNTS MAINTAINED WITH THIRD PARTY BANKS FOR THE CUSTODY OF CUSTOMER FUTURES MARGIN. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $10,000.00 FINE. Summary: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GOLDMAN, SACHS & CO. CONSENTED TO PAY A $10,000.00 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN, SACHS & CO. AND NUMEROUS OTHER MUNICIPAL DEALERS ALLEGEDLY VIOLATED MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULE G-36 BY FAILING TO SUBMIT REQUIRED ADVANCED REFUNDING DOCUMENTATION TO THE MSRB AND FAILING TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TO THE MSRB DURING THE APPROXIMATE PERIOD 9/95-9/96. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GOLDMAN, SACHS & CO. CONSENTED TO A $25,000.00 FINE AND A CENSURE. Summary: WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, GOLDMAN, SACHS & CO. CONSENTED TO A $25,000.00 FINE AND A CENSURE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDR ALLEGED THAT GS VIOLATED RULE 11AC1-1(C) OF THE SECURITIES AND EXCHANGE ACT OF 1934, NASD MARKETPLACE RULE 4613(B) AND NASD CONDUCT RULES 2110 AND 3320. THE NASDR ALLEGED THAT GS FAILED TO EXECUTE CERTAIN ORDERS AT GS PUBLISHED BID OR OFFER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND A $6,250.00 FINE. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS AGREED TO A CENSURE AND A $6,250.00 FINE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED RULE 11 AC1-1(C) OF THE SECURITIES EXCHANGE ACT OF 1934, PART V, SECTION 2(B) OF SCHEDULE D AND ARTICLE III, SECTIONS 1 AND 6 OF NASD RULES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00. Summary: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00. Summary: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED SEC RULE 10B-6A Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00. Summary: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $1000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED MARKETPLACE RULE 4613(E). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $2000.00. Summary: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $2000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED NASD CONDUCT RULE 2110 AND IM-2110-2 AND SEC RULE 10B - 10(A)(2). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $2000.00. Summary: WITHOUT ADMITTING OR DENYING ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $2000.00.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASD ALLEGED THAT GOLDMAN, SACHS & CO. ("GS") VIOLATED ARTICLE III, SECTION 1 AND 42 OF THE NASD RULES OF FAIR PRACTICE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $ 1,000. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS SIGNED THE AWC AND PAID A FINE OF $ 1,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICC") ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2015, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT ONE (1) INDEX END OF DAY PRICE IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). Status: Final Sanction Detail: ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $1,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE. Summary: ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $1,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE FUTURES U.S., INC. ("IFUS") MARKET REGULATION DEPARTMENT ISSUED A SUMMARY FINE, DATED DECEMBER 14, 2015, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 4.02(G)(2) IN ONE INSTANCE ON DECEMBER 12, 2014 BY FAILING TO UTILIZE IFUS'S CROSSING ORDER FUNCTIONALITY. Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 24, 2015. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 24, 2015.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE FUTURES U.S., INC. ("IFUS") MARKET REGULATION DEPARTMENT ISSUED A SUMMARY FINE, DATED MARCH 17, 2016, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 6.10 BY FAILING TO ENSURE THAT THE PROPER CUSTOMER TYPE INDICATOR (CTI) CODE WAS AFFIXED TO CERTAIN ORDERS ENTERED BETWEEN MAY AND AUGUST 2015. Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $2,000, WAS PAID BY SUBMISSION OF A WIRE ON MARCH 31, 2016. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $2,000, WAS PAID BY SUBMISSION OF A WIRE ON MARCH 31, 2016.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT FOR THE PERIOD SEPTEMBER 1, 2013 THROUGH DECEMBER 31, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULE 7230A(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $20,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 29, 2016. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 5, 2016, AND ON APRIL 29, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) FOR TRADE DATES AUGUST 15 AND 16, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT, OR INACCURATELY SUBMITTED, CERTAIN INFORMATION TO THE ORDER AUDIT TRAIL SYSTEM (OATS), IN ALLEGED VIOLATION OF FINRA RULE 7450; (II) DURING THE PERIOD FROM MAY 17, 2011 THROUGH FEBRUARY 28, 2014, THE FIRM REPORTED CERTAIN SHORT SALE TRANSACTIONS TO THE FINRA TRADE REPORTING FACILITY ("FTRF") WITHOUT THE REQUIRED SHORT SALE MODIFIER, IN ALLEGED VIOLATION OF FINRA RULE 6182; AND (III) THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO FINRA RULE 6182 CONCERNING THE REPORTING OF CORRECT SHORT SALE MODIFIERS TO THE FTRF, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $260,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 29, 2016. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 4, 2016, AND ON APRIL 29, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $260,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) DURING THE PERIOD OF JANUARY 30, 2009 THROUGH DECEMBER 31, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"), ACTING AS A PROGRAM DEALER IN AUCTION RATE SECURITIES ("ARS"), SUBMITTED INACCURATE INFORMATION IN CERTAIN RESPECTS REGARDING THE RESULT OF AN AUCTION IN CERTAIN INSTANCES TO THE MSRB'S SHORT-TERM OBLIGATION RATE TRANSPARENCY ("SHORT") SYSTEM: SPECIFICALLY, THAT THE FIRM ERRONEOUSLY REPORTED RATE TYPES FOR THE ARS INDICATING THAT THE INTEREST RATES WERE SET BY AUCTION RATHER THAN THE MAXIMUM INTEREST RATES, IN ALLEGED VIOLATION OF MSRB RULE G-34; AND (II) THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE MSRB RULES, RELATING TO MSRB RULE G-34 CONCERNING SHORT REPORTING OF RATE TYPES, IN ALLEGED VIOLATION OF MSRB RULE G-27. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $50,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 31, 2016. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MAY 18, 2016, AND ON MAY 31, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $50,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") OF NASDAQ PHLX LLC ("PHLX") ALLEGED THAT DURING THE PERIOD BETWEEN AUGUST 13, 2014 AND AUGUST 15, 2014, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) EFFECTED TRANSACTIONS IN AN OPTIONS POSITION THAT RESULTED IN ONE OF THE FIRM'S CUSTOMERS EXCEEDING THE APPLICABLE POSITION LIMIT FOR THREE CONSECUTIVE TRADING DAYS, IN ALLEGED VIOLATION OF PHLX RULE 1001; AND (II) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES ("WSPS") AND A SYSTEM OF SUPERVISION THAT WAS REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF, AND ACHIEVE COMPLIANCE WITH, PHLX'S POSITION LIMIT RULE: SPECIFICALLY, THE TIMING AND REVIEW OF THE FIRM'S POSITION LIMIT REPORTS UNDER ITS WSPS WERE NOT REASONABLY DESIGNED TO TIMELY DETECT CERTAIN POSITION LIMIT OVERAGES FROM THE TRADE DATE, NOTIFY THE FIRM'S CUSTOMERS OF SUCH OVERAGES, OR TAKE CORRECTIVE MEASURES TO REDUCE AND PREVENT FURTHER OVERAGES, IN ALLEGED VIOLATION OF PHLX RULE 748(H). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $25,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 1, 2016. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING TO REVISE ITS WSPS, AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WITH THE COMMITTEE WHICH WAS ACCEPTED BY THE COMMITTEE ON JULY 15, 2016, AND ON AUGUST 1, 2016, THE FIRM SUBMITTED A WIRE TO PHLX IN PAYMENT OF THE FINE IN THE AMOUNT OF $25,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP INC. ("CME") MARKET REGULATION ISSUED A SUMMARY FINE NOTICE TO GOLDMAN, SACHS & CO. (THE "FIRM") STATING THAT CME MARKET REGULATION DISCOVERED THAT THE FIRM FAILED TO MAINTAIN A COMPLETE AUDIT TRAIL WITH RESPECT TO CERTAIN TRADING SYSTEMS FOR A MINIMUM OF FIVE YEARS IN VIOLATION OF CME RULE 536.B.2. Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 22, 2016. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 22, 2016.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: BATS BZX EXCHANGE, INC. ("BZX") ALLEGED THAT DURING THE PERIOD BETWEEN AT LEAST FEBRUARY 19, 2010 AND JULY 7, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF BZX RULE 18.10; AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF BZX RULES 3.1, 5.1, 5.2 AND 5.3. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO AN AGGREGATE FINE IN THE AMOUNT OF $2,500,000, PAYABLE TO BZX AND THREE OTHER SELF-REGULATORY ORGANIZATIONS, OF WHICH $525,000 WAS PAID BY SUBMISSION OF A WIRE TO BZX ON JULY 31, 2017. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY BZX ON JUNE 26, 2017, AND BECAME FINAL ON JULY 14, 2017. ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $525,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.; NASDAQ ISE, LLC (F/K/A THE INTERNATIONAL SECURITIES EXCHANGE, LLC); AND NASDAQ PHLX LLC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: NASDAQ ISE, LLC ("ISE") ALLEGED THAT DURING THE PERIOD BETWEEN JANUARY 1, 2016 AND JULY 7, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF ISE RULE 415(A); AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF ISE RULE 401. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO AN AGGREGATE FINE IN THE AMOUNT OF $2,500,000, PAYABLE TO ISE AND THREE OTHER SELF-REGULATORY ORGANIZATIONS, OF WHICH $300,000 WAS PAID BY SUBMISSION OF A WIRE TO ISE ON JULY 31, 2017. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY ISE ON JULY 14, 2017, AND ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $300,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.; BATS BZX EXCHANGE, INC.; AND NASDAQ PHLX LLC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) DURING THE PERIOD BETWEEN AT LEAST JANUARY 9, 2010 AND JULY 7, 2016, FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OVER-THE-COUNTER ("OTC") OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF FINRA RULE 2360(B)(5); (II) DURING THE PERIOD FROM JULY 31, 2012 THROUGH APRIL 29, 2016, EXCEEDED THE POSITON LIMITS IN THREE DIFFERENT OTC OPTIONS FOR CERTAIN CUSTOMERS AND/OR PROPRIETARY ACCOUNTS, IN ALLEGED VIOLATION OF FINRA RULE 2360(B)(3), AND (III) DURING THE PERIOD BETWEEN AT LEAST JANUARY 19, 2010 AND JULY 7, 2016, FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM AND COMPLIANCE WITH APPLICABLE POSITION LIMITS, INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF NASD RULE 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND FINRA RULES 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014) AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO AN AGGREGATE FINE IN THE AMOUNT OF $2,500,000, PAYABLE TO FINRA AND THREE OTHER SELF-REGULATORY ORGANIZATIONS, OF WHICH $1,425,000 WAS PAID BY SUBMISSION OF A WIRE TO FINRA ON JULY 27, 2017. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON JULY 14, 2017, AND ON JULY 27, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $1,425,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: BATS BZX EXCHANGE, INC.; NASDAQ ISE, LLC (F/K/A THE INTERNATIONAL SECURITIES EXCHANGE, LLC); AND NASDAQ PHLX LLC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT GOLDMAN SACHS & CO. LLC (THE "FIRM"): (A) DURING THE PERIOD FROM DECEMBER 11, 2014 THROUGH DECEMBER 16, 2014, FAILED TO REPORT TO THE OVER-THE-COUNTER ("OTC") REPORTING FACILITY ("OTCRF") THE CORRECT TIME OF EXECUTION FOR CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES IN VIOLATION OF FINRA RULE 7330(D)(4); AND (B) DURING THE PERIODS FROM SEPTEMBER 1, 2014 TO DECEMBER 31, 2014, AND FROM JANUARY 1, 2015 TO APRIL 30, 2015, (I) FAILED TO TRANSMIT TO THE OTCRF CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES WITHIN 10 SECONDS AFTER EXECUTION, IN VIOLATION OF FINRA RULE 6622(A) AND FINRA RULE 2010, AND (II) DID NOT HAVE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD AND FINRA, CONCERNING OTC EQUITY TRADE REPORTING; SPECIFICALLY, THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE NOT SUFFICIENTLY INSTRUCTIVE AS TO HOW OFTEN THE RESPONSIBLE SUPERVISOR(S) SHOULD TAKE THE SPECIFIED STEPS DESIGNED TO ACHIEVE COMPLIANCE, AND THAT THE FIRM FAILED IN CERTAIN RESPECTS TO ENFORCE ITS SUPERVISORY PROCEDURES CONCERNING OTC EQUITY TRADE REPORTING, IN VIOLATION OF NASD RULE 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND FINRA RULES 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014) AND 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $39,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 10, 2017. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON NOVEMBER 1, 2017, AND ON NOVEMBER 10, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $39,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED, BASED ON A SELF-REPORT FROM GOLDMAN SACHS & CO. LLC (THE "FIRM"), THAT ORDER MODIFICATION OR CANCELLATION MESSAGES ON CERTAIN FIRM SYSTEMS IDENTIFIED THE TAG 50 ID OF THE TRADER WHO ORIGINATED AN ORDER, RATHER THAN THE TAG 50 ID OF THE TRADER WHO MODIFIED OR CANCELLED THE ORDER, IN DEEMED VIOLATION OF CME RULE 576. Status: Final Sanction Detail: THE CME IMPOSED A SUMMARY FINE ON THE FIRM IN THE AMOUNT OF $9,000.00, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 11, 2017. Summary: THE CME IMPOSED A SUMMARY FINE ON THE FIRM IN THE AMOUNT OF $9,000.00, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 11, 2017.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT GOLDMAN SACHS EXECUTION AND CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), DUE TO CERTAIN FLAWS IN ITS PROSPECTUS-DELIVERY SYSTEM, FAILED TO DELIVER CERTAIN ETF PROSPECTUSES THAT IT INTENDED TO DELIVER IN THE PERIOD BETWEEN JUNE 2008 AND OCTOBER 2014. AS A CONSEQUENCE OF GSEC'S ALLEGED FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES IN CONNECTION WITH ETF PROSPECTUS DELIVERY THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933, THE FIRM ALLEGEDLY VIOLATED NASD RULES 3010 (A) AND (B) AND 2110 AND FINRA RULE 2010. IN ADDITION, AS A RESULT OF GSEC'S ALLEGED FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT ADEQUATELY TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES CONCERNING ETF PROSPECTUS DELIVERY WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, THE FIRM ALLEGEDLY VIOLATED NASD RULES 3012 AND 2110 AND FINRA RULE 2010. (FINRA RULE 2010 REPLACED NASD RULE 2110 EFFECTIVE DECEMBER 15, 2008.) ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $700,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 14, 2017. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, A FINE AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 1, 2017, AND ON DECEMBER 14, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $700,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP INC. ("CME") MARKET REGULATION ISSUED A SUMMARY FINE NOTICE TO GOLDMAN SACHS & CO. LLC (THE "FIRM") STATING THAT CME MARKET REGULATION IDENTIFIED TWO BLOCK TRADES THAT WERE REPORTED LATE OR MISREPORTED BY THE FIRM DURING JANUARY 2018, IN VIOLATION OF CME RULE 526.F. Status: Final Sanction Detail: THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON APRIL 24, 2018. Summary: THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON APRIL 24, 2018.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT CERTAIN GOLDMAN SACHS & CO. LLC (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF DECEMBER 11, 2017 THROUGH FEBRUARY 23, 2018 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE IN EXCESS OF APPLICABLE THRESHOLD LEVELS, IN DEEMED VIOLATION OF CHICAGO MERCANTILE EXCHANGE INC. RULE 536.F. Status: Final Sanction Detail: THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 4, 2018. Summary: THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 4, 2018.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE MARKET REGULATION DEPARTMENT OF ICE FUTURES U.S., INC. ("ICE") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("THE FIRM") VIOLATED ICE RULE 2.22 BY REPORTING INACCURATE OPEN INTEREST FOR THE SEPTEMBER 2019 FCOJ-A FUTURES CONTRACT FOR THE TRADE DATES OF AUGUST 29, 2019, AUGUST 30, 2019 AND SEPTEMBER 2, 2019. ICE IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2019. Status: Final Sanction Detail: ICE IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2019. Summary: ICE IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2019.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: THE CHICAGO BOARD OF TRADE ("CBOT") IMPOSED A FINE ON GOLDMAN SACHS & CO. ("GOLDMAN") IN THE AMOUNT OF $15,000. CBOT CITED VIOLATIONS OF CBOT RULE 538.C. IN RELATION TO AN EXCHANGE FOR RELATED POSITION ("EFRP") PACKAGE EXECUTED IN THE TEN -YEAR TREASURY NOTE FUTURES AND OPTIONS MARKETS ON JULY 19, 2018, WHERE THE RELATED POSITION COMPONENTS OF THE EXCHANGE FOR RISK ("EFR") TRANSACTION DID NOT HAVE A REASONABLE DEGREE OF PRICE CORRELATION AND DID NOT HAVE OPPOSING MARKET BIAS TO THE EXCHANGE COMPONENT. FURTHER, THE RELATED COMPONENT OF THE EXCHANGE OF OPTION FOR OPTION ("EOO") TRANSACTION WAS NOT REASONABLY EQUIVALENT TO THE EXCHANGE COMPONENT. THE EFRP PACKAGE WAS THEREFORE NON-BONA FIDE AND IN VIOLATION OF CBOT RULE 538.C. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR THE FACTUAL ALLEGATIONS UPON WHICH THE PENALTY IS BASED, GOLDMAN SUBMITTED AN OFFER OF SETTLEMENT, WHICH WAS ACCEPTED, AND IT BECAME EFFECTIVE ON NOVEMBER 27, 2019. THE FINE IMPOSED BY CBOT WAS IN THE AMOUNT OF $15,000, WHICH WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 4, 2019. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR THE FACTUAL ALLEGATIONS UPON WHICH THE PENALTY IS BASED, GOLDMAN SUBMITTED AN OFFER OF SETTLEMENT, WHICH WAS ACCEPTED, AND IT BECAME EFFECTIVE ON NOVEMBER 27, 2019. THE FINE IMPOSED BY CBOT WAS IN THE AMOUNT OF $15,000, WHICH WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 4, 2019.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON DECEMBER 19, 2019, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") IN WHICH WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLDMAN SACHS & CO. LLC ("GOLDMAN") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FINDINGS ISSUED BY FINRA NAME A VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULE G-15(F) AND STATE THAT GOLDMAN EFFECTED ON A DISCRETIONARY BASIS CUSTOMER SALE TRANSACTIONS OF MUNICIPAL BONDS IN AMOUNTS LOWER THAN THE MINIMUM DENOMINATIONS OF THE RESPECTIVE ISSUES. GOLDMAN GENERALLY RELIED ON DATA IT RECEIVED FROM THIRD-PARTY VENDORS TO DETERMINE WHETHER A TRANSACTION WAS BELOW AN ISSUE'S MINIMUM DENOMINATION, AND THE VIOLATIVE TRANSACTIONS ARE PRIMARILY ATTRIBUTABLE TO INACCURACIES IN THAT VENDOR DATA. GOLDMAN HAS ALREADY VOLUNTARILY RESCINDED THE VIOLATIVE TRANSACTIONS OR OTHERWISE REIMBURSED AFFECTED CUSTOMERS. Status: Final Sanction Detail: ON DECEMBER 19, 2019 FINRA ACCEPTED AN AWC IN WHICH FINRA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $130,000 FOR A VIOLATION OF MSRB RULE G-15(F). Summary: ON DECEMBER 19, 2019 FINRA ACCEPTED AN AWC IN WHICH FINRA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $130,000 FOR A VIOLATION OF MSRB RULE G-15(F). THE FINE WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 26, 2019.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MAY 8, 2020, THE ICE FUTURES U.S. ("IFUS" OR "EXCHANGE") MARKET REGULATION DEPARTMENT NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT IT WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $10,000 PURSUANT TO IFUS RULE 21.02. THE EXCHANGE ALLEGES THAT IN SEVEN INSTANCES, GSCO APPEARED TO HAVE BEEN IN VIOLATION OF IFUS RULE 6.15(A) WHEN IT FAILED TO ACCURATELY SUBMIT REPORTABLE POSITIONS TO THE EXCHANGE. Status: Final Sanction Detail: THE FINE IMPOSED BY IFUS WAS IN THE AMOUNT OF $10,000, WHICH WAS PAID IN FULL BY GSCO BY WIRE ON MAY 28, 2020. Summary: THE FINE IMPOSED BY IFUS WAS IN THE AMOUNT OF $10,000, WHICH WAS PAID IN FULL BY GSCO BY WIRE ON MAY 28, 2020.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JUNE 15, 2020, A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") FROM NYSE ARCA, INC. ("NYSE ARCA") DIRECTED AT GOLDMAN SACHS & CO. LLC ("GOLDMAN") WAS FINALIZED. WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLDMAN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS. THE AWC STATES THAT GOLDMAN VIOLATED NYSE ARCA RULE 6.49-O(B) BY EFFECTING EQUITY TRANSACTIONS AFTER GAINING KNOWLEDGE OF UNDISCLOSED TERMS AND CONDITIONS OF A CUSTOMER ORDER IN THE SAME OPTIONS SERIES. THE FINDINGS STATE THAT A GOLDMAN TRADER RELAYED FACILITATED CROSS ORDERS FOR 800 CALL OPTIONS OF A CERTAIN OPTIONS SERIES TO AN NYSE ARCA FLOOR BROKER THAT WERE SYSTEMATIZED IN SIX SEPARATE PIECES AT SIX DIFFERENT TIMES, FOUR 100 QUANTITIES AND THEN TWO 200 QUANTITIES. THE FINDINGS ADDITIONALLY STATE THAT THE GOLDMAN TRADER SOLD A TOTAL OF 49,000 EQUITY SHARES OF THE OPTIONS SERIES AS HEDGES, AND WHEN DOING SO, HOWEVER, GOLDMAN SOLD MORE SHARES THAN NEEDED TO HEDGE THE DISCLOSED (OR SYSTEMIZED) PORTIONS OF THE SECOND THROUGH SIXTH FACILITATED OPTIONS ORDERS, THEREFORE RESULTING IN OVERHEDGES. Status: Final Sanction Detail: ON JUNE 15, 2020, AN AWC FROM NYSE ARCA DIRECTED AT GOLDMAN WAS FINALIZED. IN THE AWC, NYSE ARCA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $30,000 FOR A VIOLATION OF NYSE ARCA RULE 6.49-O(B). Summary: ON JUNE 15, 2020, AN AWC FROM NYSE ARCA DIRECTED AT GOLDMAN WAS FINALIZED. IN THE AWC, NYSE ARCA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $30,000 FOR A VIOLATION OF NYSE ARCA RULE 6.49-O(B). THE FINE WAS PAID BY GOLDMAN BY WIRE ON JUNE 22, 2020.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") ALLEGED THAT BETWEEN THE PERIOD OF JANUARY 2015 AND NOVEMBER 2019, GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED (I) SECTION 17(F)(2) OF THE SECURITIES AND EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND FINRA RULE 2010, FOR FAILING TO FINGERPRINT 1,061 ASSOCIATED, NON-REGISTERED INDIVIDUALS; (II) ARTICLE III, SECTION 3(B) OF THE FINRA BY-LAWS, FOR ALLOWING TWO INDIVIDUALS TO BE ASSOCIATED WITH THE FIRM WHO WERE SUBJECT TO STATUTORY DISQUALIFICATION; (III) 17(A)(3) OF THE EXCHANGE ACT AND FINRA RULES 4511 AND 2010, FOR FAILURE TO MAINTAIN ADEQUATE RECORDS OF FINGERPRINTING; AND (IV) FINRA RULES 3110 (A) AND (B) AND 2010, FOR FAILING TO MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES DESIGNED TO ENSURE FINGERPRINT SCREENING OF CERTAIN POPULATIONS OF NON-REGISTERED ASSOCIATED INDIVIDUALS (NAMELY EMPLOYEES WHO TRANSFERRED TO THE FIRM FROM FOREIGN OFFICES AND EMPLOYEES WHO JOINED THE FIRM AS A RESULT OF AN ACQUISITION). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,250,000, WHICH WAS PAID IN FULL BY WIRE ON FEBRUARY 9, 2021. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (THE "AWC") WITH FINRA ON JANUARY 22, 2021, PURSUANT TO WHICH THE FIRM CONSENTED TO (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $1,250,000, WHICH WAS PAID IN FULL BY WIRE ON FEBRUARY 9, 2021; AND (III) AN UNDERTAKING TO REVIEW THE FIRM'S SYSTEMS AND PROCEDURES REGARDING THE IDENTIFICATION, FINGERPRINTING, AND SCREENING OF NON-REGISTERED ASSOCIATED PERSONS, ALONG WITH A WRITTEN STATEMENT WITHIN 60 DAYS OF THE AWC DESCRIBING THE METHODOLOGY USED TO CONDUCT THE REVIEW AND CERTIFYING THAT THE FIRM HAS ADOPTED AND IMPLEMENTED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT LAWS AND RULES, AS SET FORTH IN THE AWC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MAY 19, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") TRADE DATA REVIEWED DURING ITS AUDIT OF TRADE DATES DECEMBER 2, 2020 THROUGH JANUARY 29, 2021 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION ERROR RATE IN EXCESS OF THE APPLICABLE 10% THRESHOLD LEVELS, SET FORTH IN CME RULE 536.F. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 20, 2021. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 20, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JULY 14, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF LISTED FUTURES POSITIONS IN JUNE 2021. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $1,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 28, 2021. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $1,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 28, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: IN A NOTICE DATED AUGUST 10, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") IDENTIFIED A REPORTING INFRACTION RELATED TO A REDUCTION OF OPEN INTEREST OF A FUTURES POSITION BY GOLDMAN SACHS & CO. LLC ("GSCO") IN VIOLATION OF RULE 854, CONCURRENT LONG AND SHORT POSITIONS. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 20, 2021. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 20, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON NOVEMBER 11, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX TRADE DATES IN POSITIONS IN OCTOBER 2021. Status: Final Sanction Detail: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON NOVEMBER 23, 2021. Summary: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON NOVEMBER 23, 2021.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAX PEARL, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAX EMERALD, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE BZX EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE EDGX EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE C2 EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NYSE ARCA, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO COMPLY WITH RECORDKEEPING REQUIREMENTS AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3 OF THE SECURITIES EXCHANGE ACT OF 1934, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT, DURING THE PERIOD OF JANUARY 2017 - DECEMBER 2020, GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ GEMX, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ ISE, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ MRX, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ OPTIONS MARKET, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ PHLX, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO COMPLY WITH RECORDKEEPING REQUIREMENTS AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3 OF THE SECURITIES EXCHANGE ACT OF 1934, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT, DURING THE PERIOD OF JANUARY 2017 - DECEMBER 2020, GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NYSE AMERICAN LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. Summary: WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 31, 2022, IN CONJUNCTION WITH ACCEPTING GOLDMAN SACHS & CO. LLC'S OFFER TO SETTLE THE MATTER, THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") ISSUED A COMPLAINT AGAINST THE FIRM ALLEGING VIOLATIONS OF NFA RULE 2-49(A), FOR FAILURE TO COMPLY WITH CERTAIN REQUIREMENTS UNDER CFTC REGULATION 23, AND NFA RULE 2-49(B), FOR FAILING TO PROMPTLY SUBMIT ACCURATE AND COMPLETE INFORMATION AS REQUIRED BY THE NFA. Status: Final Sanction Detail: GOLDMAN SACHS & CO. LLC MADE AN OFFER TO SETTLE THE MATTER, WITHOUT ADMITTING OR DENYING LIABILITY, BY PAYING A FINE OF $2,500,000 TO NFA. ON MARCH 31, 2022, THE BCC ACCEPTED THE OFFER, AND ISSUED A DECISION (EFFECTIVE ON APRIL 15, 2022) ORDERING GOLDMAN SACHS & CO. LLC TO PAY A FINE IN THAT AMOUNT. AS PART OF A SIDE LETTER EXECUTED IN CONNECTION WITH THE OFFER, THE FIRM AND NFA ALSO AGREED TO ADDITIONAL TERMS AND CONDITIONS WITH REGARD TO A SEPARATE SET OF ISSUES SELF-DISCLOSED TO NFA. Summary: GOLDMAN SACHS & CO. LLC MADE AN OFFER TO SETTLE THE MATTER, WITHOUT ADMITTING OR DENYING LIABILITY, BY PAYING A FINE OF $2,500,000 TO NFA. ON MARCH 31, 2022, THE BCC ACCEPTED THE OFFER, AND ISSUED A DECISION (EFFECTIVE ON APRIL 15, 2022) ORDERING GOLDMAN SACHS & CO. LLC TO PAY A FINE IN THAT AMOUNT. AS PART OF A SIDE LETTER EXECUTED IN CONNECTION WITH THE OFFER, THE FIRM AND NFA ALSO AGREED TO ADDITIONAL TERMS AND CONDITIONS WITH REGARD TO A SEPARATE SET OF ISSUES SELF-DISCLOSED TO NFA.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 13, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561, FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX DIFFERENT TRADE DATES IN MARCH 2022. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $5000 WHICH GSCO PAID BY SUBMISSION OF A WIRE ON APRIL 28, 2022. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $5000 WHICH GSCO PAID BY SUBMISSION OF A WIRE ON APRIL 28, 2022.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON OCTOBER 6, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT CME'S 512 COMMITTEE FOUND THAT GSCO VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON FIVE TRADE DATES IN SEPTEMBER 2022. Status: Final Sanction Detail: CME IMPOSED A FINE IN THE AMOUNT OF $10,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON OCTOBER 14, 2022. Summary: CME IMPOSED A FINE IN THE AMOUNT OF $10,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON OCTOBER 14, 2022.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JANUARY 19, 2023, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") REVIEWED GOLDMAN SACHS & CO. LLC'S ("GSCO") RESPONSE, AND ISSUED A CHARGE LETTER DATED JANUARY 20, 2023, WHICH ALLEGES THAT GSCO VIOLATED CME CUSTOMER GROSS MARGINING TECHNICAL OVERVIEW REQUIREMENTS AND CME RULE 980.G. Status: Final Sanction Detail: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY WAS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $50,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON MARCH 31, 2023. Summary: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY WAS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $50,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON MARCH 31, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT LLC ("ICC") IMPOSED A PENALTY OF $153,000 ON GOLDMAN SACHS & CO. LLC ("GSCO") FOR FAILURE TO SUBMIT DAILY PRICING INFORMATION OF INDEX AND SINGLE NAME PRODUCTS. Status: Final Sanction Detail: AFTER REVIEWING GSCO'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY. Summary: AFTER REVIEWING GSCO'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JULY 5, 2023, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") COMPLETED A REVIEW OF BLOCK TRADES REPORTED BY GOLDMAN SACHS & CO. LLC ("GSCO") DURING THE PERIOD JANUARY 2022 THROUGH APRIL 2023, AND FOUND THAT IN CERTAIN INSTANCES GSCO REPORTED TRADES WITH INACCURATE INFORMATION, IN VIOLATION OF CME RULE 526 AND MARKET REGULATION ADVISORY NOTICE RA2204-5, SECTION 7. Status: Final Sanction Detail: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $5,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 24, 2023. Summary: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $5,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 24, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON JULY 27, 2023, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") THAT CME HAD IDENTIFIED REPORTING INFRACTIONS WITH THE FIRM'S TRANSFER TRADE REPORTING IN VIOLATION OF CME RULE 853.A.6. Status: Final Sanction Detail: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 17, 2023. Summary: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 17, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON AUGUST 16, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS. FINRA FOUND THAT BETWEEN JULY 2018 AND SEPTEMBER 2021, GSCO FAILED TO REPORT, OR INACCURATELY REPORTED, OVER-THE-COUNTER ("OTC") OPTIONS POSITIONS TO THE LARGE OPTIONS POSITIONS REPORTING ("LOPR") SYSTEM. THE FINDINGS STATED THE FIRM'S SYSTEMS FAILED TO RECOGNIZE THAT THE ACCOUNTS OF CERTAIN CUSTOMERS WERE UNDER COMMON CONTROL OR ACTED IN CONCERT. FINRA ADDITIONALLY FOUND THAT GSCO FAILED TO MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2360(B)(5), WHICH IS A VIOLATION OF FINRA RULES 3110 AND 2010. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNT OF $425,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023. Summary: PURSUANT TO THE AWC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNT OF $425,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON AUGUST 15, 2023, CBOE BZX EXCHANGE ("CBOE BZX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED CBOE BZX'S FINDINGS. CBOE BZX FOUND THAT FROM OCTOBER 2018 THROUGH FEBRUARY 2021, GSCO FAILED TO REPORT OR INCORRECTLY REPORTED CERTAIN OPTIONS POSITIONS TO THE LARGE OPTIONS POSITION REPORT ("LOPR") AND THUS VIOLATED BZX RULE 18.10(A). THE EXCHANGE DETERMINED THAT BZX RULE 5.1 WAS VIOLATED AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND SUPERVISORY SYSTEMS REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF THE FIRM'S LOPR REPORTING OBLIGATIONS. Status: Final Sanction Detail: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNT OF $125,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023. Summary: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNT OF $125,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON SEPTEMBER 20, 2023, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("IFUS") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") MAY HAVE VIOLATED EXCHANGE RULES 6.15(A) AND 4.01(B) BY INACCURATELY REPORTING LARGE TRADER POSITIONS IN MULTIPLE INSTANCES BETWEEN NOVEMBER 2021 AND NOVEMBER 2022, AND FAILING TO IMPLEMENT SUPERVISORY SYSTEMS, POLICIES, AND PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE RULES. Status: Final Sanction Detail: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS, GSCO AGREED TO PAY A MONETARY FINE OF $70,000. THE FINE WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 9, 2023. Summary: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS, GSCO AGREED TO PAY A MONETARY FINE OF $70,000. THE FINE WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 9, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON SEPTEMBER 22, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS BUT CONSENTED TO THE SANCTIONS AND TO THE FINDINGS THAT FROM NOVEMBER 2012 THROUGH MARCH 2022, IT SUBMITTED ALMOST 25,000 ELECTRONIC BLUE SHEETS ("EBS") TO FINRA THAT INACCURATELY REPORTED ONE OR MORE OF 39 SEPARATE TYPES OF TRANSACTION INFORMATION AND MISREPORTED AT LEAST 97 MILLION TRANSACTIONS. AS A RESULT, THE FIRM VIOLATED FINRA RULES 8211, 8213, AND 2010. IN ADDITION, FINRA FOUND THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND THE SECURITIES AND EXCHANGE COMMISSION ("SEC") EBS REQUIREMENTS WAS IN VIOLATION OF FINRA RULES 3110, 2010 AND NASD RULE 3010. GSCO CURRENTLY HAS AN ONGOING REMEDIATION PROGRAM TO IMPROVE ITS EBS SYSTEM AND ADDRESS THE DISCOVERED DEFICIENCIES. Status: Final Sanction Detail: PURSUANT TO THE AWC, GSCO WAS CENSURED, IS REQUIRED TO CERTIFY TO FINRA WITHIN 90 DAYS THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENTED A SUPVERSORY SYSTEM RESONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT RULES, AND AGREED TO PAY A MONETARY FINE OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023. Summary: PURSUANT TO THE AWC, GSCO WAS CENSURED, IS REQUIRED TO CERTIFY TO FINRA WITHIN 90 DAYS THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENTED A SUPVERSORY SYSTEM RESONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT RULES, AND AGREED TO PAY A MONETARY FINE OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. Summary: THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON FEBRUARY 21, 2024, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("IFUS") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") MAY HAVE VIOLATED EXCHANGE RULE 4.02(C) ON JULY 29, 2022, WHEN AN EMPLOYEE, UPON RECEIPT OF SIMULTANEOUS BUY AND SELL ORDERS IN THE SAME FUTURES CONTRACT, FAILED TO INQUIRE ABOUT THE OWNERSHIP TO CONFIRM WHETHER THEY BELONGED TO THE SAME PRINCIPAL, AND ENTERED THE ORDERS RESULTING IN A WASH TRADE. Status: Final Sanction Detail: IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE ALLEGED RULE VIOLATION, GSCO AGREED TO PAY A MONETARY PENALTY OF $10,000. THE FINE WAS PAID IN FULL ON FEBRUARY 26, 2024. Summary: IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE ALLEGED RULE VIOLATION, GSCO AGREED TO PAY A MONETARY PENALTY OF $10,000. THE FINE WAS PAID IN FULL ON FEBRUARY 26, 2024.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON APRIL 30, 2024, THE MARKET REGULATION DEPARTMENT OF ICE FUTURES U.S., INC. ("IFUS") FOUND THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO MEET THE REQUIREMENTS OF EXCHANGE RULES 4.19(C)(II)(2), AND 4.19(E), BY FAILING TO PRESERVE THE REQUIRED ORDER MESSAGE DATA. Status: Final Sanction Detail: IFUS IMPOSED A SUMMARY FINE OF $15,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 8, 2024. Summary: IFUS IMPOSED A SUMMARY FINE OF $15,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 8, 2024.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MAY 16, 2024, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") THAT CME RECENTLY CONDUCTED A SUSPENSE ACCOUNT EXAM FOR TRADE DATES OCTOBER 1, 2023 THROUGH DECEMBER 31, 2023, WHERE CME IDENTIFIED POTENTIAL VIOLATIONS OF RULE 536.C REGARDING BUNCHED ORDERS AND ORDERS ELIGIBLE FOR POST EXECUTION ALLOCATION, FOR USING A GENERAL SUSPENSE ACCOUNT AND NOT OBTAINING SPECIFIC ACCOUNT DESIGNATIONS UNTIL AFTER ORDER ENTRY FOR SIX ORDERS. Status: Final Sanction Detail: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JUNE 12, 2024. Summary: CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JUNE 12, 2024.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON AUGUST 14, 2024, CBOE BYX EXCHANGE, INC. ("CBOE BYX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS BUT CONSENTED TO THE SANCTIONS. IN CONNECTION WITH A DECEMBER 15, 2022 ORDER, CBOE BYX FOUND THAT GSCO FAILED TO IMPLEMENT REASONABLY DESIGNED PRE-ORDER CONTROLS TO PREVENT ERRONEOUSLY PRICED LIMIT ORDERS FROM BEING ENTERED ON THE EXCHANGE. AS A RESULT, THE EXCHANGE DETERMINED THAT GSCO VIOLATED SEC RULE 15C3-5 AND BYX RULE 3.2. Status: Final Sanction Detail: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500. Summary: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON AUGUST 14, 2024, CBOE EDGX EXCHANGE, INC. ("CBOE EDGX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS BUT CONSENTED TO THE SANCTIONS. IN CONNECTION WITH A DECEMBER 15, 2022 ORDER, CBOE EDGX FOUND THAT GSCO FAILED TO IMPLEMENT REASONABLY DESIGNED PRE-ORDER CONTROLS TO PREVENT ERRONEOUSLY PRICED LIMIT ORDERS FROM BEING ENTERED ON THE EXCHANGE. AS A RESULT, THE EXCHANGE DETERMINED THAT GSCO VIOLATED SEC RULE 15C3-5 AND EDGX RULE 3.2. Status: Final Sanction Detail: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500. Summary: PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON OCTOBER 30, 2024, CME GROUP MARKET REGULATION ("CME") CONCLUDED ITS 2024 ELECTRONIC TRADING RECORDKEEPING EXAMINATION OF GOLDMAN SACHS & CO. LLC ("GSCO") FOR TRADE DATES APRIL 1 THROUGH JUNE 30, 2024. DURING THE REVIEW, CME FOUND ISSUES CONCERNING CERTAIN OPERATOR IDS THAT WERE ACTIVE AND REQUIRED TO BE REGISTERED IN THE EXCHANGE FEE SYSTEM BUT WERE NOT REGISTERED UNTIL AFTER THE REVIEW PERIOD, IN VIOLATION OF CME RULE 576 ("IDENTIFICATION OF GLOBEX TERMINAL OPERATORS"). GSCO REGISTERED THE OPERATOR IDS DURING THE EXAMINATION. Status: Final Sanction Detail: CME IMPOSED A $4,000 SUMMARY FINE ON GSCO FOR FAILURE TO COMPLY WITH CME RULE 576. GSCO PAID THE FINE ON NOVEMBER 12, 2024. Summary: CME IMPOSED A $4,000 SUMMARY FINE ON GSCO FOR FAILURE TO COMPLY WITH CME RULE 576. GSCO PAID THE FINE ON NOVEMBER 12, 2024.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ALLEGED FAILURE BY GS AS A MARKET MAKER TO MAKE REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASKED QUOTATION WHICH CAUSED A LOCKED OR CROSSSED MARKET CONDITION TO OCCUR. Status: Final Sanction Detail: ON JULY 14, 2000, GS CONSENTED TO A CENSURE AND FINE OF $13,000 BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED ON OCTOBER 10, 2000. Summary: ON JULY 14, 2000, GS CONSENTED TO A CENSURE AND FINE OF $13,000 BY SIGNING A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WHICH WAS ACCEPTED ON OCTOBER 10, 2000.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ALLEGATIONS OF VIOLATIONS OF CBOE RULE 4.1 (JUST AND EQUITABLE PRINCIPLES OF TRADE) AND RULES 6.43, 6.74(B)(III), 6.9(D) AND REGULATORY CIRCULAR RG97-113, HAVING TO DO WITH CONDUCT ON THE FLOOR RULES, IN CONNECTION WITH A SERIES OF TRADES ON ONE BUSINESS DAY. Status: Final Sanction Detail: GS PAID A FINE OF $15,000 ON 02/08/01. Summary: MATTER SETTLED WITHOUT ADMITTING OR DENYING THE VIOLATIONS ATTENDED.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CBOE CHARGED THAT GS VIOLATED RULE 4.11, POSITION LIMITS. Status: Final Sanction Detail: GS PAID A FINE OF $2,758.00

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: CME GROUP, INC. ("CME") MARKET REGULATION FOUND REPORTING INFRACTIONS WITH RESPECT TO J. ARON & COMPANY'S (THE "COMPANY") REPORTING OF CERTAIN BLOCK TRADES, INCLUDING: (I) LATE REPORTING OF CERTAIN BLOCK TRADES TO THE CHICAGO MERCANTILE EXCHANGE DURING MARCH AND APRIL, 2013; (II) ENTERING TRADES INTO THE CME CLEARPORT PLATFORM ON ONE DATE AS OUTRIGHT TRANSACTIONS WHERE IT APPEARED FROM AUDIT TRAIL DOCUMENTS THEY WERE SPREAD TRANSACTIONS AND WITH EXECUTION TIMES NOT SUPPORTED BY SUCH SUPPORTING DOCUMENTS; AND (III) REPORTING A BLOCK TRANSACTION TO THE NEW YORK MERCANTILE EXCHANGE (NYMEX) FACILITATION DESK, WHILE AUDIT TRAIL DOCUMENTS SUGGESTED THAT THE ORDER WAS EXECUTED IN INCREMENTS, EACH IN ALLEGED VIOLATION OF CME RULE 526.F. Status: Final Sanction Detail: THE CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 19, 2013. Summary: THE CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 19, 2013.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE FUTURES U.S., INC. ("IFUS") BUSINESS CONDUCT COMMITTEE ("BCC") DETERMINED THAT J. ARON & COMPANY ("J. ARON") MAY HAVE, IN ONE (1) INSTANCE, EXCEEDED THE SPOT MONTH SPECULATIVE POSITION LIMIT ESTABLISHED BY IFUS IN AN ENERGY FUTURES CONTRACT DURING CONTRACT EXPIRATION, IN ALLEGED VIOLATION OF IFUS RULE 6.20(B). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON CONSENTED TO A MONETARY PAYMENT OF $82,064 IN THE AGGREGATE, CONSISTING OF A FINE IN THE AMOUNT OF $20,000, AND DISGORGEMENT OF PROFITS IN THE AMOUNT OF $62,064, BOTH OF WHICH WERE PAID BY SUBMISSION OF A WIRE ON NOVEMBER 26, 2014. Summary: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON ENTERED INTO A SETTLEMENT AGREEMENT, WHICH WAS APPROVED BY THE BCC, IN WHICH J. ARON: (I) AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF IFUS RULE 6.20(B); AND (II) CONSENTED TO A MONETARY PAYMENT OF $82,064 IN THE AGGREGATE, CONSISTING OF A FINE IN THE AMOUNT OF $20,000, AND DISGORGEMENT OF PROFITS IN THE AMOUNT OF $62,064, BOTH OF WHICH WERE PAID BY SUBMISSION OF A WIRE ON NOVEMBER 26, 2014.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: AN ICE FUTURES U.S., INC. ("IFUS") SUBCOMMITTEE OF THE BUSINESS CONDUCT COMMITTEE (THE "BCC SUBCOMMITTEE") DETERMINED THAT J. ARON & COMPANY ("J. ARON") MAY HAVE VIOLATED IFUS RULE 6.20(B) IN ONE (1) INSTANCE BY CARRYING A POSITION IN EXCESS OF APPLICABLE SPOT MONTH POSITION LIMITS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON CONSENTED TO A FINE IN THE AMOUNT OF $35,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 2, 2015. Summary: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON ENTERED INTO A SETTLEMENT AGREEMENT, WHICH WAS APPROVED BY THE BCC SUBCOMMITTEE, IN WHICH J. ARON: (I) AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF IFUS RULE 6.20(B); AND (II) CONSENTED TO A FINE IN THE AMOUNT OF $35,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 2, 2015.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ICE CLEAR CREDIT, LLC ("ICC") ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2015, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVEN (7) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). Status: Final Sanction Detail: ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $7,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE. Summary: ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $7,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MAY 17, 2022, A PANEL OF THE COMMODITY EXCHANGE (COMEX) BUSINESS CONDUCT COMMITTEE FOUND THAT, ON SEVERAL OCCASIONS IN MAY 2020 AND JULY 2020, J. ARON & COMPANY LLC ("J. ARON"), PRIOR TO ENGAGING IN ANY PRE-HEDGING ACTIVITY, FAILED TO MAKE CLEAR TO ITS COUNTERPARTY THAT IT WAS TRADING PRINCIPALLY THEREBY VIOLATING COMEX RULE 526. Status: Final Sanction Detail: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH J. ARON NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, J. ARON AGREED TO PAY A FINE IN THE AMOUNT OF $125,000 AND TO DISGORGE PROFITS IN THE AMOUNT OF $10,825. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON JUNE 2, 2022. Summary: PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH J. ARON NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, J. ARON AGREED TO PAY A FINE IN THE AMOUNT OF $125,000 AND TO DISGORGE PROFITS IN THE AMOUNT OF $10,825. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON JUNE 2, 2022.

Regulatory · Item 11.E(2) as of Nov 19, 2024

Allegations: ON MARCH 2, 2023, THE ICE FUTURES U.S. ("IFUS" OR "EXCHANGE") MARKET REGULATION DEPARTMENT COMPLETED A REVIEW OF BLOCK TRADES SUBMITTED BY J. ARON & CO. LLC ("J. ARON") BETWEEN JULY 2021 AND NOVEMBER 2021, AND FOUND THAT ON MULTIPLE INSTANCES, J. ARON SUBMITTED BLOCK TRADES TO THE EXCHANGE BEYOND THE REQUIRED REPORTING WINDOW THEREBY VIOLATING IFUS RULE 4.07(C). Status: Final Sanction Detail: PURSUANT TO IFUS RULE 21.02, J. ARON WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $5,000 FOR THE VIOLATIONS. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON MARCH 17, 2023. Summary: PURSUANT TO IFUS RULE 21.02, J. ARON WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $5,000 FOR THE VIOLATIONS. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON MARCH 17, 2023.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") AND GOLDMAN SACHS BANK USA ("GS BANK") ENTERED INTO AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED, WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") ON JANUARY 12, 2018 (THE "CONSENT ASSESSMENT"). THE CONSENT ASSESSMENT RELATED TO ALLEGATIONS BY THE FEDERAL RESERVE THAT, PRIOR TO SEPTEMBER 1, 2011, GS GROUP AND GS BANK HAD ENGAGED IN DEFICIENT PRACTICES IN RESIDENTIAL MORTGAGE LOAN SERVICING AND FORECLOSURE PROCESSING INVOLVING LITTON LOAN SERVICING LP ("LITTON"), A FORMER SUBSIDIARY. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS GROUP AND GS BANK HAD PREVIOUSLY ENTERED INTO A CONSENT ORDER WITH THE FEDERAL RESERVE RELATING TO THE SAME ALLEGED CONDUCT ON SEPTEMBER 1, 2011, AS AMENDED ON FEBRUARY 28, 2013 (THE "AMENDED CONSENT", WHICH IS REPORTED ON A SEPARATE DRP). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AMENDED CONSENT, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE CONSENT ASSESSMENT, WHICH RELEASES AND DISCHARGES GS GROUP, GS BANK, AND THEIR AFFILIATES, SUCCESSORS, AND ASSIGNS FROM ALL POTENTIAL LIABILITY THAT HAS BEEN OR MIGHT HAVE BEEN ASSERTED BY THE FEDERAL RESERVE BASED ON THE CONDUCT THAT IS THE SUBJECT OF CONSENT ASSESSMENT OR THE AMENDED CONSENT, AND ASSESSES GS GROUP AND GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $14,000,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JANUARY 12, 2018. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AMENDED CONSENT, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE CONSENT ASSESSMENT, WHICH RELEASES AND DISCHARGES GS GROUP, GS BANK, AND THEIR AFFILIATES, SUCCESSORS, AND ASSIGNS FROM ALL POTENTIAL LIABILITY THAT HAS BEEN OR MIGHT HAVE BEEN ASSERTED BY THE FEDERAL RESERVE BASED ON THE CONDUCT THAT IS THE SUBJECT OF CONSENT ASSESSMENT OR THE AMENDED CONSENT, AND ASSESSES GS GROUP AND GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $14,000,000, WHICH WAS PAID TO THE FEDERAL RESERVE BY SUBMISSION OF A WIRE ON JANUARY 12, 2018.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") ALLEGED THAT GOLDMAN SACHS BANK USA ("GS BANK"), ENGAGED IN A PATTERN OR PRACTICE OF VIOLATIONS UNDER SECTION 102(F)(2) OF THE NATIONAL FLOOD INSURANCE ACT, 42 U.S.C. 4012A(F). Status: Final Sanction Detail: ON JANUARY 12, 2018, GS BANK AND THE FEDERAL RESERVE ENTERED INTO AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY PURSUANT TO THE NATIONAL FLOOD INSURANCE ACT, AS AMENDED, WHICH ASSESSES GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $90,000, WHICH WAS PAID TO THE FEDERAL RESERVE BY SUBMISSION OF A CHECK ON JANUARY 12, 2018. Summary: ON JANUARY 12, 2018, PRIOR TO THE TAKING OF ANY TESTIMONY OR ADJUDICATION OF OR FINDING ON ANY ISSUE OF FACT OR LAW, AND SOLELY FOR THE PURPOSE OF SETTLEMENT OF THE MATTER WITHOUT A FORMAL PROCEEDING BEING FILED AND WITHOUT THE NECESSITY FOR PROTRACTED OR EXTENDED HEARINGS OR TESTIMONY, GS BANK AND THE FEDERAL RESERVE ENTERED INTO AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY PURSUANT TO THE NATIONAL FLOOD INSURANCE ACT, AS AMENDED, WHICH ASSESSES GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $90,000, WHICH WAS PAID TO THE FEDERAL RESERVE BY SUBMISSION OF A CHECK ON JANUARY 12, 2018.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") HAS ALLEGED THAT: WHEREAS THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") SERVES AS A FOREIGN EXCHANGE ("FX") DEALER THROUGH CERTAIN OF ITS INDIRECT SUBSIDIARIES ("FX SUBSIDIARIES"), BY BUYING AND SELLING U.S. DOLLARS AND FOREIGN CURRENCY FOR THEIR OWN ACCOUNT AND BY SOLICITING AND RECEIVING ORDERS THROUGH COMMUNICATIONS BETWEEN CUSTOMERS AND SALES PERSONNEL THAT ARE EXECUTED ON THE SPOT MARKET ("COVERED FX ACTIVITIES"), FROM OCTOBER 2008 THROUGH OCTOBER 2012, GS GROUP AND CERTAIN SUBSIDIARIES (TOGETHER, THE "FIRM"): (A) LACKED ADEQUATE GOVERNANCE, COMPLIANCE RISK MANAGEMENT, COMPLIANCE AND/OR AUDIT POLICIES TO ENSURE THAT THE FX SUBSIDIARIES' COVERED FX ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE INTERNAL POLICIES; AND (B) HAD DEFICIENT POLICIES AND PROCEDURES THAT PREVENTED IT FROM DETECTING AND ADDRESSING POTENTIALLY UNSOUND CONDUCT BY CERTAIN OF THE FX SUBSIDIARIES' FX TRADERS, AND AS A RESULT OF THE DEFICIENT POLICIES AND PROCEDURES, ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES. Status: Final Sanction Detail: ON MAY 1, 2018, GS GROUP AND THE FEDERAL RESERVE ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED, WHICH ASSESSES THE FIRM A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000, WHICH THE FIRM PAID TO THE FEDERAL RESERVE ON MAY 2, 2018. Summary: ON MAY 1, 2018, PRIOR TO THE FILING OF ANY NOTICES OF CHARGES, OR TAKING OF ANY TESTIMONY, OR ADJUDICATION OF OR FINDING ON ANY ISSUES OF FACT OR LAW HEREIN, AND SOLELY FOR THE PURPOSE OF SETTLEMENT OF THIS MATTER WITHOUT A FORMAL PROCEEDING BEING FILED AND WITHOUT THE NECESSITY FOR PROTRACTED OR EXTENDED HEARINGS OR TESTIMONY, GS GROUP AND THE FEDERAL RESERVE ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED (THE "CONSENT ORDER"), PURSUANT TO WHICH: (A) GS GROUP, AS APPLICABLE, SHALL SUBMIT TO THE FEDERAL RESERVE WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE CONSENT ORDER, AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM, COMPLIANCE RISK MANAGEMENT PROGRAM, CONTROLS REVIEW, AND INTERNAL AUDIT PROGRAM, EACH AS ACCEPTABLE TO THE FEDERAL RESERVE; (B) THE FIRM SHALL ADOPT AND IMPLEMENT THESE PROGRAMS AND SUBMIT PROGRESS REPORTS TO THE FEDERAL RESERVE; (C) THE FIRM SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUAL AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF THE FIRM OR ANY SUBSIDIARY OR ANY AFFILIATE THEREOF WHO HAS PARTICIPATED IN THE CONDUCT UNDERLYING THE CONSENT ORDER, BEEN SUBJECT TO A FORMAL DISCIPLINARY ACTION AS A RESULT OF THE FIRM'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER AND SEPARATED FROM THE FIRM OR ANY SUBSIDIARY THEREOF OR HAD HIS OR HER EMPLOYMENT TERMINATED IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER; AND (D) THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 2, 2018.

Regulatory · Item 11.D(4) as of Nov 19, 2024

Allegations: ON OCTOBER 22, 2020, GOLDMAN SACHS (SINGAPORE) PTE ("GS SINGAPORE") RECEIVED A LETTER OF DIRECTION FROM THE MONETARY AUTHORITY OF SINGAPORE (THE "MAS LETTER"), REQUIRING GS SINGAPORE TO APPOINT AN INDEPENDENT AUDITOR TO REVIEW THE EFFECTIVENESS AND SUSTAINABILITY OF THE REMEDIAL MEASURES IMPLEMENTED BY GS SINGAPORE FOLLOWING THE MONETARY AUTHORITY OF SINGAPORE'S INSPECTION. Status: Final Summary: THE MSA LETTER REQUIRES GS SINGAPORE TO APPOINT AN INDEPENDENT AUDITOR TO REVIEW THE EFFECTIVENESS AND SUSTAINABILITY OF THE REMEDIAL MEASURES IMPLEMENTED BY GS SINGAPORE FOLLOWING THE MONETARY AUTHORITY OF SINGAPORE'S INSPECTION.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A NOTICE OF A DISCIPLINARY MEASURE DATED AUGUST 25, 2014, THE SECRETARY OF THE DISCIPLINARY AND ARBITRATION COMMITTEE OF MEXDER, MERCADO MEXICANO DE DERIVADOS, S.A. DE C.V. ("MEXDER"), INFORMED GOLDMAN, SACHS & CO. (THE "FIRM") OF MEXDER'S CONCLUSION THAT THE FIRM FAILED TO TIMELY NOTIFY MEXDER OF THE WITHDRAWAL FROM REGISTRATION WITH MEXDER OF AN EMPLOYEE OF THE FIRM WHO WAS AN ACCREDITED MEXDER SALES REPRESENTATIVE AND TRADER, IN ALLEGED FAILURE TO COMPLY WITH ARTICLE 6036.00 SUBSECTION III OF MEXDER INTERNAL REGULATIONS. Status: Final Sanction Detail: MEXDER IMPOSED AN ECONOMIC PENALTY ON THE FIRM IN THE AMOUNT OF $11,268.24 MEXICAN PESOS IN THE AGGREGATE, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2014. WHILE THE ACTUAL PAYMENT WAS MADE IN MEXICAN PESOS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF MXN13.2355:USD1 AS OF SEPTEMBER 18, 2014, THE EQUIVALENT U.S. DOLLAR VALUE ON SEPTEMBER 18, 2014 WAS $851.36, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: MEXDER IMPOSED AN ECONOMIC PENALTY ON THE FIRM IN THE AMOUNT OF $11,268.24 MEXICAN PESOS IN THE AGGREGATE, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2014.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: SEBI FOUND THAT GOLDMAN SACHS INVESTMENTS (MAURITIUS) I LTD. ("GSIML") VIOLATED SEBI CIRCULAR DATED AUG. 8, 2003, READ WITH REGULATION 20 OF FII REGULATIONS, BY SUBMITTING A FALSE DECLARATION TO SEBI WITH RESPECT TO THE ISSUANCE OF THE OFF-SHORE DERIVATIVE INSTRUMENTS TO AN OVERSEAS CORPORATE BODY AND VIOLATED REGULATION 13(1) OF FII REGULATIONS BY ISSUING SUCH OFF-SHORE DERIVATIVE INSTRUMENTS TO AN OVERSEAS CORPORATE BODY. Status: Final Sanction Detail: THE MONETARY AMOUNT LISTED IN QUESTION 12.A. IS THE APPROXIMATE U.S. DOLLAR AMOUNT REPRESENTING RS. 10,000,000 ON THE DATE OF THE RESOLUTION. Summary: IN COMPLIANCE WITH THE ADJUDICATION ORDER NO. AP/AO-16/2006-07, ON OCTOBER 17, 2006, GSIML SUBMITTED A PENALTY PAYMENT TO SEBI IN THE AMOUNT OF RS. 10,000,000, OR APPROXIMATELY $216,450.22 BASED ON THE EXCHANGE RATE ON THE RESOLUTION DATE.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FINANCIAL SERVICES AUTHORITY IN THE UK ("FSA") INVESTIGATED GOLDMAN SACHS INTERNATIONAL ("GSI") IN RELATION TO (I) THE MARKETING OF THE SYNTHETIC COLLATERALIZED DEBT OBLIGATION TRANSACTION NAMED ABACUS 2007-AC1 ("ABACUS") BY GSI, (II) THE FAILURE BY GSI TO NOTIFY THE FSA OF THE SECURITIES AND EXCHANGE COMMISSION'S ("SEC") INVESTIGATION INTO ABACUS AND (III) GSI'S SYSTEMS AND CONTROLS WITH RESPECT TO THE INTERNAL REPORTING AND ESCALATION OF REGULATORY MATTERS. Status: Final Sanction Detail: GSI AGREED TO THE IMPOSITION OF A FINE BY THE FSA OF GB£17.5 MILLION, WHICH AMOUNT WAS PAID ON SEPTEMBER 15, 2010. WHILE THE ACTUAL PAYMENT WAS MADE IN GB POUNDS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF GB£1:US$1.5641 AS OF SEPTEMBER 15, 2010, THE EQUIVALENT US DOLLAR VALUE ON SEPTEMBER 15, 2010 WAS US$27,371,750, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GSI AGREED TO THE IMPOSITION OF A FINE BY THE FSA OF GB£17.5 MILLION, WHICH AMOUNT WAS PAID ON SEPTEMBER 15, 2010. AS INDICATED IN A NOTICE PUBLISHED BY THE FSA ON SEPTEMBER 9, 2010 (THE "NOTICE"), IN RESPECT OF BREACHES OF FSA PRINCIPLES 2, 3 AND 11, THE FSA INCLUDED IN ITS 'REASONS FOR THE ACTION' THAT, DURING THE RELEVANT PERIOD, WHICH OCCURRED BETWEEN JULY 2009 AT THE LATEST AND APRIL 16, 2010: (I) IN BREACH OF FSA PRINCIPLE 2, GSI FAILED TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE IN RELATION TO ITS REGULATORY OBLIGATIONS. SPECIFICALLY, GSI FAILED TO CONSIDER THE REGULATORY REPORTING OBLIGATIONS FOR GSI OF THE SEC INVESTIGATION, INCLUDING THE GOLDMAN, SACHS & CO. WELLS NOTICE AND THE MR. FABRICE TOURRE WELLS NOTICE, (II) IN BREACH OF FSA PRINCIPLE 3, GSI FAILED TO TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY WITH ADEQUATE POLICIES, PROCEDURES, SYSTEMS AND CONTROLS IN RELATION TO INTERNAL COMMUNICATIONS WITHIN THE GS GROUP AND GSI TO ENABLE GSI TO FULFILL ITS EXTERNAL REGULATORY REPORTING OBLIGATIONS, AND (III) IN BREACH OF FSA PRINCIPLE 11, GSI FAILED TO DISCLOSE THE MR. TOURRE WELLS NOTICE TO THE FSA, WHICH WAS INFORMATION OF WHICH THE FSA WOULD REASONABLY EXPECT NOTICE AND WHICH WAS REASONABLY MATERIAL TO THE ASSESSMENT OF MR. TOURRE'S FITNESS AND PROPRIETY TO HOLD A CONTROLLED FUNCTION. THE FSA ACCEPTED THAT THIS FAILURE WAS NOT AS A RESULT OF GSI DELIBERATELY WITHHOLDING INFORMATION. NO FINDING WAS MADE WITH RESPECT TO THE MARKETING OF ABACUS BY GSI. AS ACKNOWLEDGED IN THE NOTICE, A PROGRAM OF ENHANCEMENTS TO GSI'S SYSTEMS IS UNDERWAY TO ENSURE THAT ALL RELEVANT ISSUES ARE REPORTED TO THE FSA. A NUMBER OF IMPROVEMENTS HAVE ALREADY BEEN MADE. THE NOTICE ALSO SPECIFICALLY STATES THAT THE BREACHES IT IDENTIFIED WERE NOT DELIBERATE, BUT INADVERTENT AND THAT THEY DO NOT REFLECT ADVERSELY ON THE INTEGRITY OF GSI OR THE INDIVIDUALS CONCERNED.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON JANUARY 28, 2011, MONITORING BY ICE FUTURES EUROPE (THE "EXCHANGE") DETECTED SIX NOTABLE "PRICE SPIKES" IN THE APRIL11 BRENT/WTI SPREAD THAT WERE INVESTIGATED BY THE EXCHANGE AND FOUND TO BE THE RESULT OF A LIMIT ORDER AND SEVERAL LARGE MARKET ORDERS PLACED IN QUICK SUCCESSION BY A GOLDMAN SACHS TRADER AT THE REQUEST OF HIS CLIENT, IN ALLEGED BREACH OF EXCHANGE RULE G.20. Status: Final Sanction Detail: GOLDMAN SACHS INTERNATIONAL ("GSI") AGREED TO THE IMPOSITION OF A FINE BY THE EXCHANGE OF GB£25,000, WHICH AMOUNT WAS PAID ON JUNE 17, 2011. WHILE THE ACTUAL PAYMENT WAS MADE IN GB POUNDS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF GB£1:US$1.6186 AS OF JUNE 17, 2011, THE EQUIVALENT US DOLLAR VALUE ON JUNE 17, 2011 WAS US$40,465, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: AS INDICATED IN A CIRCULAR PUBLISHED BY THE EXCHANGE ON JUNE 17, 2011 (THE "CIRCULAR"), ON JUNE 2, 2011 THE EXCHANGE'S AUTHORISATION, RULES AND CONDUCT COMMITTEE (THE "COMMITTEE") SUMMARILY CONCLUDED: (I) THE BEHAVIOR OF GSI AND ITS CLIENT TO BE A CLEAR CASE OF DISORDERLY TRADING, IN THAT THE DISTORTING PRICE IMPACT OF THE PLACEMENT OF SUCH LARGE ORDERS IN CLOSE PROXIMITY WAS NOT CONSIDERED, AND (II) BOTH GSI AND ITS CLIENT TO BE AT FAULT IN THE MATTER, EMPHASIZING THAT ALL EXCHANGE MEMBERS HAVE A RESPONSIBILITY TO TRADE IN AN ORDERLY FASHION AT ALL TIMES, WHETHER ON THEIR OWN BEHALF OR ON BEHALF OF A CLIENT. GSI DID NOT SEEK TO APPEAL THE COMMITTEE'S FINDINGS AND PAID THE FINE ON JUNE 17, 2011. THE CIRCULAR ALSO SPECIFICALLY STATES THAT WHILE THE COMMITTEE CONSIDERED THE BREACH TO BE OF A SERIOUS NATURE, THE COMMITTEE FOUND NO EVIDENCE OF INTENTIONAL MANIPULATION OF THE MARKET. GSI PROVIDED THE EXCHANGE WITH FULL COOPERATION THROUGHOUT ITS INQUIRIES.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FÜR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") ALLEGED A NEGLIGENT BREACH OF SUPERVISORY DUTIES IN CONTRAVENTION OF CERTAIN SHAREHOLDER DISCLOSURE REQUIREMENTS OF SECTION 21 (1) OF THE SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZES - WPHG) AGAINST GS EQUITY MARKETS, L.P. ("GSEM"). Status: Final Sanction Detail: BAFIN IMPOSED A MONETARY PENALTY ON GSEM OF 9,453.50 EUROS IN THE AGGREGATE, REPRESENTING AN ADMINISTRATIVE FINE OF 9,000 EUROS AND PROCEDURAL EXPENSES OF 453.50 EUROS, WHICH AMOUNT WAS PAID ON JULY 18, 2011. WHILE THE ACTUAL PAYMENT WAS MADE IN EUROS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF 1EURO:US$1.4042 AS OF JULY 18, 2011, THE EQUIVALENT US DOLLAR VALUE ON JULY 18, 2011 WAS US$13,274.60, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: BAFIN IMPOSED A MONETARY PENALTY ON GSEM OF 9,453.50 EUROS IN THE AGGREGATE, REPRESENTING AN ADMINISTRATIVE FINE OF 9,000 EUROS AND PROCEDURAL EXPENSES OF 453.50 EUROS, WHICH AMOUNT WAS PAID ON JULY 18, 2011.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: PURSUANT TO SETTLEMENT PROCEEDINGS, NYSE EURONEXT LIFFE ("LIFFE") MARKET SERVICES, LONDON ("MSL") ALLEGED THAT ON FEBRUARY 19, 2008, GOLDMAN SACHS INTERNATIONAL ("GSI"), THROUGH THE AGENCY OF AN UNREGISTERED INDIVIDUAL, PROCURED MATCHING BUSINESS FOR TWO CLIENT ORDERS WHICH, IN EACH CASE, WERE AT A PRICE INSIDE THE MINIMUM PRICE MOVEMENT OF THE STERLING FUTURES CONTRACT, AND WHICH NECESSITATED THE EXECUTION OF TWO TRADES IN THE SAME STRATEGY AT DIFFERENT PRICE LEVELS TO ACHIEVE THE AVERAGE PRICE, IN ALLEGED VIOLATION OF LIFFE RULE 2.2.3. Status: Final Sanction Detail: GSI AGREED TO THE PAYMENT OF A MONETARY PENALTY TO LIFFE OF £11,666 IN THE AGGREGATE, REPRESENTING A FINE OF £5,666, AND A CONTRIBUTION OF £6,000 TOWARDS THE COSTS INCURRED AS A RESULT OF THE DISCIPLINARY PROCEEDING, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON APRIL 9, 2009. WHILE THE ACTUAL PAYMENT WAS MADE IN BRITISH POUNDS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF £1:US$1.4623 AS OF APRIL 9, 2009, THE EQUIVALENT US DOLLAR VALUE ON APRIL 9, 2009 WAS US$17,059.19, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: FURTHER TO THE SETTLEMENT PROCEEDINGS, AND FOLLOWING THE REDUCTION OF THE FINE BY ONE THIRD, IT WAS AGREED THAT GSI BE FINED £5,666, AND MAKE A CONTRIBUTION OF £6,000 TOWARDS THE COSTS INCURRED AS A RESULT OF THE DISCIPLINARY PROCEEDING, IN RELATION TO CONTRAVENTION OF GENERAL NOTICE NO. 2515, IN RESPECT OF FACILITATING CONTINGENT ORDERS WHICH HAD THE EFFECT OF ACHIEVING A TRANSACTION AT AN AVERAGE PRICE INSIDE THE MINIMUM PRICE MOVEMENT OF THE CONTRACT CONCERNED. MSL (I) ACKNOWLEDGED THAT GSI HAD APOLOGIZED FOR THE INCIDENT AND HAD CO-OPERATED FULLY WITH MSL DURING THE COURSE OF ITS PRELIMINARY INVESTIGATION, (II) ACCEPTED THAT NEITHER THE SALES PERSON NOR THE RESPONSIBLE PERSON INVOLVED HAD BENEFITTED FROM THE EXECUTION OF THE BLOCK TRADES, AND THAT (III) GSI HAD TAKEN STEPS, SINCE THE INCIDENTS, TO ENSURE THAT ALL RELEVANT STAFF WERE FULLY AWARE OF THE PROVISIONS OF GENERAL NOTICE 2515.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A LETTER TO GOLDMAN SACHS STRUCTURED PRODUCTS (ASIA) LIMITED ("GSSPA") DATED FEBRUARY 8, 2012, THE STOCK EXCHANGE OF HONG KONG LIMITED ("HKEX") LISTING DIVISION (THE "DIVISION") INFORMED GSSPA THAT, HAVING REVIEWED CERTAIN FACTS AND CIRCUMSTANCES REGARDING FOUR NIKKEI LINKED WARRANTS ISSUED BY GSSPA ON FEBRUARY 17, 2011 (THE "WARRANTS"), THE DIVISION WAS OF THE VIEW THAT GSSPA HAD BREACHED CERTAIN PROVISIONS IN THE LISTING AGREEMENT BETWEEN GSSPA AND HKEX (THE "LISTING AGREEMENT") AND THE HKEX LISTING RULES DUE TO ERRORS IN THE LISTING DOCUMENTATION AND FOR NOT REQUESTING A TRADE SUSPENSION OF THE WARRANTS AS SOON AS REASONABLY PRACTICABLE ON MARCH 31, 2011. Status: Final Sanction Detail: THE DIVISION'S ASSERTIONS WERE REFERRED TO THE HKEX LISTING (DISCIPLINARY) COMMITTEE (THE "COMMITTEE"). WITHOUT ADMITTING OR CONTESTING THE DIVISION'S ASSERTIONS, GSSPA ENTERED INTO A SETTLEMENT AGREEMENT WITH HKEX, WHICH WAS ENDORSED BY THE COMMITTEE ON APRIL 24, 2012, IN WHICH HKEX CENSURED GSSPA FOR HAVING BREACHED CERTAIN PROVISIONS IN THE LISTING AGREEMENT. Summary: THE DIVISION'S ASSERTIONS WERE REFERRED TO THE COMMITTEE. WITHOUT ADMITTING OR CONTESTING THE DIVISION'S ASSERTIONS, GSSPA ENTERED INTO A SETTLEMENT AGREEMENT WITH HKEX, WHICH WAS ENDORSED BY THE COMMITTEE ON APRIL 24, 2012, IN WHICH HKEX CENSURED GSSPA FOR HAVING BREACHED CERTAIN PROVISIONS IN THE LISTING AGREEMENT. IN CONSIDERING THE OVERALL SANCTION TO BE IMPOSED ON GSSPA, THE COMMITTEE TOOK INTO ACCOUNT THAT: (I) THIS WAS AN ISOLATED INCIDENT, THERE BEING NO RECORD OF AN EARLIER FAILURE OF THIS NATURE BY GSSPA; (II) THE ERRORS APPEARED TO RESULT FROM HUMAN ERROR RATHER THAN A SYSTEMIC FAILURE; (III) THE WARRANTS HAD, DESPITE CERTAIN ERRORS, TRADED IN ACCORDANCE WITH THEIR INTENDED ECONOMICS FOR A PERIOD OF APPROXIMATELY SIX WEEKS FROM THEIR ISSUANCE PRIOR TO MARCH 31, 2011 WITH NO UNUSUAL PRICE MOVEMENTS; (IV) GSSPA NOTIFIED HKEX OF THE ERRORS PROMPTLY AND PRIOR TO THE OPENING OF THE MARKET ON MARCH 31, 2011, AND THEREAFTER MAINTAINED A FREQUENT AND CANDID DIALOGUE WITH HKEX; (V) GSSPA COOPERATED WITH HKEX, INCLUDING AGREEING TO A TRADING SUSPENSION WHEN THE SUGGESTION WAS MADE BY HKEX ON MARCH 31, 2011; (VI) THERE WAS NO PRECEDENT FOR REQUESTING A SUSPENSION FROM TRADING OF HONG KONG LISTED WARRANTS IN THESE CIRCUMSTANCES; (VII) THE TRADING ACTIVITY THAT RESULTED IN UNUSUAL PRICE MOVEMENT ON MARCH 31, 2011 DID NOT INVOLVE GSSPA AS LIQUIDITY PROVIDER OR IN ANY OTHER CAPACITY; (VIII) GSSPA OFFERED COMPENSATION TO ALL AFFECTED INVESTORS THROUGH A BUYBACK PROGRAM; (IX) GSSPA HAD CERTAIN INTERNAL CONTROLS IN PLACE FOR DOCUMENT REVIEW AT THE RELEVANT TIME AND HAS SINCE IMPLEMENTED REMEDIAL MEASURES ADDRESSING HKEX'S REGULATORY CONCERNS; (X) GSSPA HAS BEEN A VERY ACTIVE PARTICIPANT IN THE WARRANTS INDUSTRY WORKING GROUP FORMED TO CONSIDER ISSUES, INCLUDING THE STANDARDIZATION OF DOCUMENTATION, SO AS TO ENSURE THE CONTINUING SUCCESS AND HIGH STANDARDS OF THE HONG KONG WARRANTS MARKET; (XI) GSSPA VOLUNTARILY WITHDREW FROM ISSUING NEW WARRANTS FROM APRIL TO NOVEMBER 2011 AND FOCUSED ON RESOLVING THIS INCIDENT; AND (XII) GSSPA FULLY COOPERATED WITH THE DIVISION THROUGHOUT ITS INVESTIGATION AND HAS A CLEAN DISCIPLINARY RECORD.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A LETTER DATED AUGUST 7, 2012 TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), WITH REFERENCE TO THE PERIODIC INSPECTION VISIT PAID TO GSSA BY CMA BETWEEN JANUARY 7, 2012 TO JANUARY 25, 2012, CMA INFORMED GSSA OF A BOARD OF CMA RESOLUTION (THE "RESOLUTION"), ALLEGING: (A) A LACK OF A COMPLIANCE OFFICER AT GSSA FROM AUGUST 14, 2010 TO FEBRUARY 13, 2011; (B) THE LACK OF A BANK ACCOUNT WITH A LOCAL BANK FOR THE PURPOSE OF KEEPING THE FUNDS OF CMA CLIENTS; (C) NON-DISCLOSURE TO A CMA CLIENT OF CERTAIN FEES AND COMMISSIONS CHARGED BEFORE PROVIDING CERTAIN SECURITIES SERVICES TO THE CLIENT; (D) NOT INCLUDING IN THE CUSTODIAN'S AGREEMENT SIGNED WITH CERTAIN BRANCHES OF GSSA CERTAIN CONDITIONS STATED IN THE PARAGRAPH REFERRED TO; AND (E) NOT SETTING APPROPRIATE MEASURES TO MAINTAIN A CLEAR AND APPROPRIATE DIVISION OF RESPONSIBILITIES AMONG THE MEMBERS OF THE BOARD OF DIRECTORS, PARTNERS OR SENIOR MANAGEMENT OF CMA, IN ALLEGED VIOLATION OF ARTICLES 20(B)(3), 10(C), 46, 89(A) AND 53(A), RESPECTIVELY, OF THE CMA AUTHORIZED PERSONS REGULATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 90,000 SAUDI RIYALS (SR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 29, 2012. WHILE THE ACTUAL PAYMENT WAS MADE IN SAUDI RIYALS, USING THE FOREIGN EXCHANGE SPOT RATE OF SR1:US$0.266656 AS OF AUGUST 29, 2012, THE EQUIVALENT US DOLLAR VALUE ON AUGUST 29, 2012 WAS US$23,999.04, WHICH IS THE AMOUNT REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 90,000 SAUDI RIYALS (SR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 29, 2012. THE RESOLUTION STIPULATED IT IS NECESSARY TO DISCUSS THE MATTER OF VIOLATIONS AT THE NEXT MEETING OF THE BOARD OF DIRECTORS OF GSSA TO SET THE MEASURES AND MECHANISMS REQUIRED TO PREVENT REOCCURRENCE IN THE FUTURE.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON FEBRUARY 17, 2015, THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION NOTIFIED GOLDMAN SACHS MÉXICO, CASA DE BOLSA, S.A. DE C.V. ("GS MEXICO") OF ITS DECISION TO IMPOSE AN ADMINISTRATIVE PENALTY FOR THE FAILURE BY GS MEXICO TO TIMELY FILE A QUARTERLY REPORT OF U.S. DOLLAR CASH TRANSACTIONS EFFECTED DURING THE FIRST QUARTER OF 2014 IN ACCORDANCE WITH SECTION 35 OF THE NEW GENERAL GUIDELINES TO ARTICLE 212 OF THE MEXICAN SECURITIES MARKET LAW (NUEVAS DISPOSICIONES DE CARÁCTER GENERAL A QUE SE REFIERE EL ARTÍCULO 212 DE LA LEY DEL MERCADO DE VALORES). Status: Final Sanction Detail: THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION IMPOSED AN ADMINISTRATIVE FINANCIAL PENALTY ON GS MEXICO IN THE AMOUNT OF MXN$269,160 IN THE AGGREGATE, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON MARCH 10, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN MEXICAN PESOS, USING THE FEDERAL RESERVE FOREIGN EXCHANGE RATE OF MXN$15.5815:USD$1 AS OF MARCH 10, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON MARCH 10, 2015 WAS USD$17,274.33, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION IMPOSED AN ADMINISTRATIVE FINANCIAL PENALTY ON GS MEXICO IN THE AMOUNT OF MXN$269,160, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON MARCH 10, 2015.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ANBIMA - ASSOCIAÇÃO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA") ALLEGED THAT, CERTAIN BRAZILIAN FINANCIAL INSTITUTIONS, INCLUDING GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A. ("OFFERING COORDINATORS") ACTING IN A PUBLIC OFFERING (THE "OFFERING") OF EQUITY SECURITIES OF THE BRAZILIAN ISSUER OI S.A. (THE "ISSUER"), FAILED TO APPROPRIATELY DISCLOSE CERTAIN RELATIONSHIPS IN THE OFFERING MATERIALS ASSOCIATED WITH CERTAIN OFFERING COORDINATORS BEING CREDITORS AND SECURITY HOLDERS OF THE ISSUER WHO USED PART OF THE PROCEEDS FROM THE OFFERING TO AMORTIZE SUCH LOANS (PARTIALLY OR TOTALLY), IN ALLEGED CONTRAVENTION OF ARTICLE 10 OF THE ANBIMA CODE OF REGULATION AND BEST PRACTICES TO PUBLIC OFFERINGS (CÓDIGO ANBIMA DE REGULAÇÃO E MELHORES PRÁTICAS PARA OFERTAS PÚBLICAS DE DISTRIBUIÇÃO E AQUISIÇÃO DE VALORES MOBILIÁRIOS, "ANBIMA'S CODE"). Status: Final Sanction Detail: ANBIMA AND THE OFFERING COORDINATORS ENTERED INTO A SETTLEMENT AGREEMENT ON MARCH 18, 2015, IN WHICH THE OFFERING COORDINATORS AGREED TO PREPARE EDUCATIONAL MATERIAL AND SCHEDULE INTERNAL WORKSHOPS TO BE PRESENTED BY REPRESENTATIVES FROM ANBIMA TO THE INVESTMENT BANKING TEAM OF EACH OFFERING COORDINATOR ON THE RULES OF ANBIMA'S CODE. IN ADDITION, THE OFFERING COORDINATORS AGREED TO A FINANCIAL PAYMENT TO ANBIMA, GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A.'S PORTION OF WHICH WAS BRL$18,894.83, WHICH AMOUNT WILL BE PAID BY GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A. UPON RECEIPT OF AN INVOICE. WHILE THE ACTUAL PAYMENT WILL BE MADE IN BRAZILIAN REAIS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF BRL$3.0784:USD$1 AS OF APRIL 10, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON APRIL 10, 2015 WAS USD$6,137.87, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: ANBIMA AND THE OFFERING COORDINATORS ENTERED INTO A SETTLEMENT AGREEMENT ON MARCH 18, 2015, IN WHICH THE OFFERING COORDINATORS AGREED TO PREPARE AN EDUCATIONAL MATERIAL AND SCHEDULE INTERNAL WORKSHOPS TO BE PRESENTED BY REPRESENTATIVES FROM ANBIMA TO THE INVESTMENT BANKING TEAM OF EACH OFFERING COORDINATOR ON THE RULES OF ANBIMA'S CODE. IN ADDITION, THE OFFERING COORDINATORS AGREED TO A FINANCIAL PAYMENT TO ANBIMA, GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A.'S PORTION OF WHICH WAS BRL$18,894.83, WHICH AMOUNT WILL BE PAID BY GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A. UPON RECEIPT OF AN INVOICE.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A LETTER DATED JUNE 17, 2015 TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING THAT GSSA WAS LATE IN NOTIFYING THE CMA OF THE RESIGNATION OF GSSA'S CHIEF EXECUTIVE OFFICER, IN ALLEGED VIOLATION OF ARTICLE 15 PARAGRAPH A OF THE CMA LICENSEES REGULATIONS. Status: Final Sanction Detail: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON JULY 5, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN SAUDI ARABIAN RIYALS, USING THE FOREIGN EXCHANGE SPOT RATE OF SAR1:USD0.2666347 AS OF JULY 6, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON JULY 5, 2015 WAS US$2,666.35, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON JULY 5, 2015. THE CMA'S DECISION STIPULATED THE NEED FOR GSSA TO DISCUSS THE MATTER OF THE VIOLATION AT THE NEXT MEETING OF THE BOARD OF DIRECTORS OF GSSA AND TO NOTIFY THE CMA OF THE BOARD'S RESPONSE IN THIS REGARD.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ANBIMA - ASSOCIAÇÃO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA") FILED A PROCEEDING FOR INVESTIGATION OF IRREGULARITIES ("PAI") TO INVESTIGATE WHETHER GOLDMAN SACHS DO BRASIL BANCO MÚLTIPLO S.A. ("GSBR") MAY HAVE VIOLATED ARTICLE 27, PARAGRAPH 3, V OF THE ANBIMA CODE OF REGULATION AND BEST PRACTICES TO INVESTMENT FUNDS (CÓDIGO ANBIMA DE REGULAÇÃO E MELHORES PRÁTICAS PARA FUNDOS DE INVESTIMENTO, "ANBIMA'S CODE OF FUNDS") IN CONNECTION WITH GSBR'S TAX TREATMENT OF PAYMENTS OF INTEREST ON CAPITAL IN CONNECTION WITH STOCK LENDING TRADES INVOLVING A BRAZILIAN INVESTMENT FUND MANAGED BY GSBR (THE "FUND"). Status: Final Sanction Detail: GSBR AGREED TO MAKE A FINANCIAL PAYMENT TO ANBIMA IN THE AMOUNT OF FIVE HUNDRED THOUSAND REAIS (BRL$500,000.00), WHICH AMOUNT WAS PAID BY GSBR ON AUGUST 3, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN BRAZILIAN REAIS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF BRL$3.4487:USD$1 AS OF AUGUST 3, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON AUGUST 3, 2015 WAS USD$144,982.17, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION, ANBIMA AND GSBR ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2015, IN WHICH GSBR AGREED TO: (I) ENSURE FULL COMPLIANCE WITH ALL PROVISIONS OF THE ANBIMA'S CODE OF FUNDS, SPECIFICALLY WITH RESPECT TO MATTERS RELATING TO THE PAI; (II) ADOPT ADDITIONAL INTERNAL CONTROLS RELATING TO GOVERNANCE AND MANAGEMENT OF THE FUND AND CONDUCT RELATED TRAINING WITH SUBMISSION TO ANBIMA OF A LIST OF ATTENDEES OF THE TRAINING ONCE COMPLETED; (III) REFRAIN FROM PREPARATION OF ANY MATERIAL FOR DISTRIBUTION, SOLICITATION, ADVERTISEMENT OR ANY OTHER MATERIAL INTENDED TO SOLICIT NEW SHAREHOLDERS FOR THE FUND; AND (IV) REFRAIN FROM USING THE FUND'S PERFORMANCE TRACK RECORD IN THE MARKETING MATERIAL OF ANY OTHER FUND MANAGED BY GSBR FOR A PERIOD OF TWELVE (12) MONTHS. IN ADDITION, GSBR AGREED TO MAKE A FINANCIAL PAYMENT TO ANBIMA IN THE AMOUNT OF FIVE HUNDRED THOUSAND REAIS (BRL$500,000.00), WHICH AMOUNT WAS PAID BY GSBR ON AUGUST 3, 2015.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS CONFEDERATION ALLEGED THAT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") PUBLISHED TWICE AN INCOMPLETE NOTIFICATION REGARDING THE FIRM'S HOLDINGS IN CERTAIN SECURITIES IN THE PERIOD BETWEEN DECEMBER 12, 2013 AND FEBRUARY 12, 2014, AND PUBLISHED DELAYED NOTIFICATION OF THE FIRM'S QUALIFIED SHAREHOLDING IN CERTAIN SECURITIES EXCEEDING THE NOTIFICATION THRESHOLD IN THE PERIOD BETWEEN AUGUST 19, 2014 AND AUGUST 8, 2015, EACH IN ALLEGED INFRINGEMENT OF ARTICLE 41 OF THE SWISS FEDERAL ACT ON STOCK EXCHANGES AND SECURITIES TRADING ("SESTA"). Status: Final Sanction Detail: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GS GROUP CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN SWISS FRANCS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF CHF0.9828:USD1 AS OF DECEMBER 11, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON DECEMBER 11, 2015 WAS $20,350.02, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GS GROUP ENTERED INTO A SETTLEMENT AGREEMENT WITH FDF ON DECEMBER 8, 2015, AND CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE SECURITIES AND FUTURES COMMISSION OF HONG KONG ("SFC") CENSURED GOLDMAN SACHS (ASIA) L.L.C. ("GS ASIA") IN RESPECT TO GS ASIA'S FAILURE, WHILE ACTING AS A FINANCIAL ADVISOR IN RELATION TO A VOLUNTARY GENERAL SECURITIES OFFERING OF AN ISSUER, TO (I) DISCLOSE ITS DEALINGS IN THE RELEVANT SECURITIES BETWEEN NOVEMBER 8, 2013 AND JANUARY 6, 2014, (II) SEEK, DURING THE OFFER PERIOD, THE SFC'S CONSENT PRIOR TO DEALING IN PRINCIPAL TRADES IN THE RELEVANT SECURITIES OF THE ISSUER WHICH FELL OUTSIDE THE SCOPE OF DEALINGS COVERED BY THE EXEMPT PRINCIPAL TRADING AND EXEMPT FUND MANAGER STATUS GRANTED TO CERTAIN GOLDMAN SACHS ENTITIES AND, (III) COMPLY WITH CERTAIN REQUIREMENTS IN RELATION TO RESEARCH REPORTS ON THE ISSUER, IN BREACH OF RULES 22, 21.5, NOTE 4 TO RULE 8.1 AND 10 OF THE CODE ON TAKEOVERS AND MERGERS. Status: Final Sanction Detail: THE SFC ISSUED A PUBLIC CENSURE OF GS ASIA DATED FEBRUARY 2, 2016. Summary: THE SFC ISSUED A PUBLIC CENSURE OF GS ASIA DATED FEBRUARY 2, 2016 (THE "CENSURE"). IN DECIDING THE CENSURE, THE SFC TOOK INTO ACCOUNT GOLDMAN SACHS' COOPERATION AND SELF-REPORTING OF THE BREACHES.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: IN A LETTER DATED MAY 12, 2016 TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING THAT THERE WAS ONLY ONE INDIVIDUAL ASSOCIATED WITH GSSA REGISTERED WITH THE CMA UNDER INVESTMENT FUND MANAGEMENT AND CLIENT PORTFOLIO MANAGEMENT ACTIVITIES, IN ALLEGED VIOLATION OF CMA CIRCULAR NO. T/1/6/9/15, DATED JUNE 17, 2015. Status: Final Sanction Detail: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 23, 2016. WHILE THE ACTUAL PAYMENT WAS MADE IN SAUDI ARABIAN RIYALS, USING THE FOREIGN EXCHANGE SPOT RATE OF SAR1:USD0.2665316 AS OF MAY 23, 2016, THE EQUIVALENT U.S. DOLLAR VALUE ON MAY 23, 2016 WAS US$2,665.32, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 23, 2016. THE CMA'S DECISION STIPULATED THE NEED FOR GSSA TO DISCUSS THE MATTER OF THE VIOLATION AT THE NEXT MEETING OF THE BOARD OF DIRECTORS OF GSSA.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") SANCTIONS COMMITTEE (THE "SANCTIONS COMMITTEE") ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED SEC. 72A OF THE EXCHANGE RULES OF THE FSE BY CONVEYING CERTAIN UNLABELED ORDERS GENERATED BY ALGORITHMIC TRADING TO THE XETRA TRADING PLATFORM OF THE FSE IN THE PERIOD FROM MARCH 29, 2016 TO SEPTEMBER 20, 2016. Status: Final Sanction Detail: THE FSE ISSUED A REPRIMAND TO GSI, AND REQUIRED GSI TO PAY A 500 EURO FEE FOR THE PROCEEDINGS. Summary: THE FSE ISSUED A REPRIMAND TO GSI, AND REQUIRED GSI TO PAY A 500 EURO FEE FOR THE PROCEEDINGS. IN ITS DECISION, THE FSE NOTED THAT GSI DISCOVERED THE ERROR ITSELF AND THEN IMMEDIATELY DISCLOSED AND REMEDIED IT.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA ("FSC") HAS IMPOSED AN ADMINISTRATIVE FINE ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR VIOLATION OF CERTAIN SHORT SALE RESTRICTIONS AS SET OUT IN ARTICLES 180(1) AND 180-2(1) OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT (THE "ACT") WITH RESPECT TO CERTAIN OF GSI'S SHORT SALE ORDERS AND SHORT POSITION REPORTS. THE FINE WAS IMPOSED PURSUANT TO ARTICLE 449 OF THE ACT, ARTICLE 390 OF THE ENFORCEMENT DECREE OF THE ACT, ARTICLES 26 AND 48 OF THE REGULATION ON INVESTIGATION OF CAPITAL MARKETS, AND ARTICLE 20 OF THE REGULATION ON EXAMINATION AND SANCTIONS AGAINST FINANCIAL INSTITUTIONS. Status: Final Sanction Detail: THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 7,504,800,000 SOUTH KOREAN WON (KRW), WHICH WAS PAID BY GSI BY WIRE ON DECEMBER 18, 2018. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SOUTH KOREAN WON, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF KRW1127.81:USD1 AS OF DECEMBER 18, 2018, THE EQUIVALENT U.S. DOLLAR VALUE ON DECEMBER 18, 2018 WAS APPROXIMATELY $6,654,607.36, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 7,504,800,000 SOUTH KOREAN WON (KRW), WHICH WAS PAID BY GSI BY WIRE ON DECEMBER 18, 2018.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA ("FSC") HAS IMPOSED AN ADMINISTRATIVE FINE ON GOLDMAN SACHS INDIA INVESTMENTS (SINGAPORE) PTE. LTD. ("KRPL") FOR VIOLATION OF CERTAIN SHORT SALE RESTRICTIONS AS SET OUT IN ARTICLE 180(1) OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT (THE "ACT") WITH RESPECT TO CERTAIN OF KRPL'S SHORT SALE ORDERS ON OCTOBER 31, 2017 AND JANUARY 9, 2018. THE FINE WAS IMPOSED PURSUANT TO ARTICLE 449 OF THE ACT, ARTICLE 390 OF THE ENFORCEMENT DECREE OF THE ACT, AND ARTICLES 26 AND 48 OF THE REGULATION ON SANCTIONS AGAINST FINANCIAL INSTITUTIONS. Status: Final Sanction Detail: THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 72,000,000 SOUTH KOREAN WON ("KRW"), WHICH WAS PAID BY WIRE ON APRIL 2, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SOUTH KOREAN WON, THE EQUIVALENT U.S. DOLLAR VALUE ON THE DATE OF THE WIRE WAS $63,615.48, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 72,000,000 SOUTH KOREAN WON ("KRW"), WHICH WAS PAID BY KRPL BY WIRE ON APRIL 2, 2019.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: THE FCA HAS IMPOSED A FINANCIAL PENALTY OF £34,344,700 ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR FAILURE TO PROVIDE ACCURATE AND TIMELY INFORMATION IN RELATION TO CERTAIN REPORTABLE TRANSACTIONS TO THE FINANCIAL CONDUCT AUTHORITY ("FCA") IN ALLEGED VIOLATION OF SUP 17.4.1EU, SUP 17.1.4R AND SUP 15.6.1R. GSI ALSO FAILED TO TAKE REASONABLE CARE TO ORGANISE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY IN RESPECT OF ITS TRANSACTION REPORTING IN ALLEGED VIOLATION OF PRINCIPLE 3 OF THE FCA'S PRINCIPLES FOR BUSINESSES. THE FINE WAS IMPOSED PURSUANT TO SECTION 206 OF THE FINANCIAL SERVICES AND MARKETS ACT 2000. Status: Final Sanction Detail: THE FINE IMPOSED BY THE FINANCIAL CONDUCT AUTHORITY WAS IN THE AMOUNT OF £49,063,900. HOWEVER, GOLDMAN SACHS INTERNATIONAL AGREED TO RESOLVE THE CASE AND THEREFORE QUALIFIED FOR A 30% DISCOUNT IN THE OVERALL PENALTY REDUCING THE FINE TO £34,344,700. THE FINE WAS PAID BY WIRE ON APRIL 2, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN POUND STERLING, THE EQUIVALENT U.S. DOLLAR VALUE ON THE DATE OF THE WIRE WAS $44,768,316.4, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE FINE IMPOSED BY THE FINANCIAL CONDUCT AUTHORITY WAS IN THE AMOUNT OF £49,063,900. HOWEVER, GOLDMAN SACHS INTERNATIONAL AGREED TO RESOLVE THE CASE AND THEREFORE QUALIFIED FOR A 30% DISCOUNT IN THE OVERALL PENALTY REDUCING THE FINE TO £34,344,700. THE FINE WAS PAID BY WIRE ON APRIL 2, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN POUND STERLING, THE EQUIVALENT U.S. DOLLAR VALUE ON THE DATE OF THE WIRE WAS $44,768,316.4, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON NOVEMBER 13, 2019, THE AUSTRALIA SECURITIES EXCHANGE ("ASX") IMPOSED A FINE ON GOLDMAN SACHS AUSTRALIA PTY LTD ("GSA") IN THE AMOUNT OF 50,000 AUSTRALIAN DOLLARS (AUD). ASX CITED VIOLATIONS OF ASX CLEAR (FUTURES) OPERATING RULE 46.1 AND RULE 46.5 IN RELATION TO FUTURES CLEARING AND THE DAILY CLOSE OUT OF BACK-TO-BACK FUTURES POSITIONS, IN PARTICULAR FOR PHYSICALLY SETTLED BANK BILLS FUTURES CONTRACTS. Status: Final Sanction Detail: ACKNOWLEDGING THAT, AMONG OTHER MATTERS, THE FIRM HAS UNDERTAKEN MEANINGFUL REMEDIATION AND AN EARLY DECISION BY THE FIRM NOT TO CONTEST THE MATTER, THE FIRM PAID A PENALTY OF 50,000 AUD (PLUS GOODS AND SERVICES TAX) ON DECEMBER 10, 2019 TO THE ASX FOR THE CONTRAVENTION. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN AUD, BASED ON THE FOREIGN EXCHANGE RATE OF 1 USD: 1.4625 AUD AS OF DECEMBER 9, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 34,189 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. ASX INTENDS TO PUBLISH A PUBLIC NOTICE ON 16 DECEMBER, 2019 CONCERNING THE CONTRAVENTION. Summary: THE FINE IMPOSED BY ASX WAS IN THE AMOUNT OF 50,000 AUD, WHICH WAS PAID BY GSA BY WIRE ON DECEMBER 10, 2019. ASX INTENDS TO PUBLISH A PUBLIC NOTICE ON 16 DECEMBER, 2019 CONCERNING THE CONTRAVENTION.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: AKK - ÁLLAMADÓSSÁG KEZELO KÖZPONT ZÁRTKÖRUEN MUKÖDO RÉSZVÉNYTÁRSASÁG ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2020, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. Status: Final Sanction Detail: AKK - ÁLLAMADÓSSÁG KEZELO KÖZPONT ZÁRTKÖRUEN MUKÖDO RÉSZVÉNYTÁRSASÁG ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2020, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. Summary: THE AKK IMPOSED A FINE ON GSI IN THE AMOUNT OF HUF 500,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 27, 2020.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: ON OCTOBER 23, 2024, GOLDMAN SACHS BANK USA ("GS BANK") ENTERED INTO A CONSENT ORDER (THE "ORDER") WITH THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") RELATED TO THE ADMINISTRATION OF THE APPLE CARD BETWEEN 2019 AND 2021. SPECIFICALLY, THE CFPB CONDUCTED AN INVESTIGATION OF GS BANK'S HANDLING OF DISPUTES AND ITS OFFERING OF THE INTEREST-FREE PURCHASE PROMOTION KNOWN AS APPLE CARD MONTHLY INSTALLMENTS ("ACMI"). IN THE ORDER, THE CFPB ALLEGED THAT BETWEEN DECEMBER 2019 AND APPROXIMATELY JULY 2020, GS BANK MADE MISLEADING REPRESENTATIONS ABOUT ACMI ENROLLMENT AND, BETWEEN DECEMBER 2019 AND APPROXIMATELY MAY 2021, MISREPRESENTED HOW REFUNDS TO CONSUMERS' ACMI AND NON-ACMI BALANCES WOULD BE APPLIED. IN ADDITION, THE CFPB ALLEGED THAT GS BANK'S HANDLING OF CREDIT CARD TRANSACTION DISPUTES BETWEEN PRODUCT LAUNCH IN AUGUST 2019 AND APPROXIMATELY DECEMBER 2021 VIOLATED THE TRUTH IN LENDING ACT AND ITS IMPLEMENTING REGULATION Z, AND ALSO INVOLVED UNFAIR PRACTICES UNDER THE CONSUMER FINANCIAL PROTECTION ACT OF 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE ORDER, GS BANK STIPULATED TO THE ENTRY OF THE ORDER AND AGREED TO PAY A $45 MILLION CIVIL MONEY PENALTY TO THE CFPB, $19.8 MILLION IN REDRESS TO CONSUMERS WITH CREDIT GIVEN FOR RESTITUTION GS BANK ALREADY PROVIDED TO AFFECTED CONSUMERS, TO REFRAIN FROM VIOLATING RELEVANT STATUES AND REGULATIONS, AND TO TAKE CERTAIN OTHER REMEDIAL MEASURES, INCLUDING CREATING AND IMPLEMENTING A COMPREHENSIVE COMPLIANCE PLAN DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE LAWS. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE ORDER, GS BANK STIPULATED TO THE ENTRY OF THE ORDER AND AGREED TO PAY A $45 MILLION CIVIL MONEY PENALTY TO THE CFPB, $19.8 MILLION IN REDRESS TO CONSUMERS WITH CREDIT GIVEN FOR RESTITUTION GS BANK ALREADY PROVIDED TO AFFECTED CONSUMERS, TO REFRAIN FROM VIOLATING RELEVANT STATUES AND REGULATIONS, AND TO TAKE CERTAIN OTHER REMEDIAL MEASURES, INCLUDING CREATING AND IMPLEMENTING A COMPREHENSIVE COMPLIANCE PLAN DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE LAWS.

Regulatory · Item 11.D(2) as of Nov 19, 2024

Allegations: GOLDMAN SACHS FUTURES (SINGAPORE) PTE LTD FAILED TO IMPOSE MARGINS ON ONE CUSTOMER, VIOLATING SGX-DT RULE 822-CUSTOMER MARGINS, SGX-DT RULE 415(F)-FAILURE TO PROVIDE INFORMATION IN THE COMPANY'S MONTHLY SUBMISSION OF ITS CREDIT FACILITIES OBTAINED FROM FINANCIAL INSTITUTIONS, AND SGX-DT RULE 3500-FAILURE TO OBTAIN A DATED DISCLAIMER STATEMENT FROM ONE CUSTOMER ON SGX-DT MSCI TAIWAN STOCK INDEX FUTURES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS FUTURES (SINGAPORE) PTE LTD PAID A FINE OF S$250.00 FOR VIOLATION OF SGX-DT RULE 822. THERE WERE NO FINES IMPOSED FOR VIOLATIONS OF RULES SGX-DT RULE 415(F) AND SGX-DT RULE 3500. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS FUTURES (SINGAPORE) PTE LTD PAID A FINE OF S$250.00.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: IN DECEMBER OF 2005, THE REGULATOR FOR THE ASSET MANAGEMENT INDUSTRY IN JAPAN (THE "FINANCIAL SERVICES AGENCY" OR "FSA") ISSUED AN IMPROVEMENT ORDER TO GOLDMAN SACHS ASSET MANAGEMENT CO., LTD. ("GSAMC"), A PARTICIPATING INVESTMENT ADVISORY AFFILIATE OF GOLDMAN SACHS ASSET MANAGEMENT ("GSAM"), IN CONNECTION WITH CERTAIN ISSUES IDENTIFIED DURING A REGULAR EXAMINATION OF GSAMC'S OPERATIONS. THREE MAIN ISSUES LED TO THE ISSUANCE OF THE IMPROVEMENT ORDER: (I) A POST-TRADE REALLOCAITON OF CERAIN SECURITIES BETWEEN DISCRETIONARY CLIENT ACCOUNTS; (II) A SITUATION INVOLVING CROSS TRADES BETWEEN PUBLIC OFFERING AND PRIVATE PLACEMENT FUNDS; AND (III) A SITUATION INVOLVING THE OFFERING OF JAPANESE PUBLIC MUTUAL FUNDS PRIOR TO THE FILING OF REGISTRATION STATEMENTS. THESE SITUATIONS RESULTED IN TECHNICAL VIOLATIONS OF CERTAIN JAPANESE REGULATORY REQUIREMENTS. Status: Final Sanction Detail: REVISION OF CONTROLS. Summary: GSAMC HAS SINCE REVISED ITS CONTROLS IN THESE AREAS. THE IMPROVEMENT ORDER DID NOT PROVIDE FOR ANY FINES OR SUSPENSIONS OF GSAMC OR ITS EMPLOYEES, AND IT IS NOT ANITCIPATED THAT THE IMPROVEMENT ORDER WILL MATERIALLY AFFECT GSAMC'S ABILITY TO PROVIDE INVESTMENT MANAGEMENT SERVICES TO ITS CLIENTS.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: NZX LIMITED ("NZX") ALLEGED THAT GOLDMAN SACHS JBWERE (NZ) LIMITED ("JBWERE (NZ)") BREACHED NZX PARTICIPANT RULES 11.3.1 AND 8.1.1(C) BY FAILING TO BRING A CLIENT'S ORDER TO MARKET AND BY INACCURATELY ADVISING THE SAME CLIENT THAT ITS ORDER HAD BEEN PLACED. Status: Final Sanction Detail: JBWERE (NZ) PAID A MONETARY PENALTY IN THE AMOUNT OF NZ$30,000 TO THE NZX ON JUNE 22, 2010. Summary: THE NZX AND JBWERE (NZ) AGREED TO SETTLEMENT TERMS THAT WERE APPROVED BY THE NZ MARKETS DISCIPLINARY TRIBUNAL ON MAY 25, 2010, AND ON JUNE 22, 2010, JBWERE (NZ) PAID A MONETARY PENALTY IN THE AMOUNT OF NZ$30,000 TO THE NZX.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO A CONSENT ORDER FOR A CIVIL MONEY PENALTY WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE "DFS", AND THE CONSENT ORDER, THE "DFS ORDER"), WHICH ALLEGED VIOLATIONS OF THE NEW YORK BANKING LAW ("BANKING LAW") ARISING OUT OF INVESTMENTS BY A GS GROUP WHOLLY-OWNED SUBSIDIARY, GOLDMAN SACHS BANK USA ("GS BANK"), IN INSTRUMENTS RELATED TO 1MALAYSIA DEVELOPMENT BERHAD ("1MDB"). THE CONDUCT DESCRIBED IN THE DFS ORDER INCLUDES (I) THE FAILURE OF GS GROUP TO ADEQUATELY DETECT OR ADDRESS CERTAIN RED FLAGS IN CONNECTION WITH THE 1MDB BOND TRANSACTIONS; (II) GS GROUP'S FAILURE TO ESCALATE OR ADDRESS ALLEGATIONS OF BRIBERY COMMUNICATED TO CERTAIN SENIOR BUSINESS PERSONNEL FOLLOWING THE COMPLETION OF THE 1MDB OFFERINGS; (III) GS GROUP'S FAILURE TO ADDRESS ALLEGATIONS OF ITS EMPLOYEES SUSPECTED INVOLVEMENT IN THE 1MDB MISCONDUCT; AND (IV) GS GROUP'S FAILURE TO CONVEY TO GS BANK RED FLAGS OR INFORMATION KNOWN ABOUT THE 1MDB OFFERINGS OR THE MISCONDUCT OF ITS EMPLOYEES SO THAT GS BANK COULD AFFIRMATIVELY REPORT THE INCIDENT TO THE DFS. THE DFS ORDER ALSO FINDS THAT GS GROUP VIOLATED SECTION 44 OF THE BANKING LAW BY CONDUCTING BUSINESS IN AN UNSAFE AND UNSOUND MANNER AND 3 N.Y.C.R.R. SECTION 300.4 BY FAILING TO SUBMIT A REPORT TO THE SUPERINTENDENT OF THE DFS OF ONE OR MORE INCIDENTS THAT APPEAR TO RELATE TO A PLAN OR SCHEME THAT WOULD BE OF INTEREST TO SIMILAR ORGANIZATIONS LOCATED IN THE SAME AREA OR THROUGH THE STATE. Status: Final Sanction Detail: PURSUANT TO THE DFS ORDER, THE DFS REQUIRED GS GROUP TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000. Summary: GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000 TO THE DFS.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE", AND THE ORDER, THE "FEDERAL RESERVE ORDER"), WHICH ALLEGED GS GROUP ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES RELATING TO THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") BOND TRANSACTIONS THAT RESULTED FROM DEFICIENT POLICIES, PROCEDURES AND CONTROLS. SUCH DEFICIENCIES INCLUDED (I) THE LACK OF, OR FAILURE TO IMPLEMENT, ADEQUATE COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THE 1MDB OFFERINGS COMPLIED WITH SAFE AND SOUND PRACTICES; (II) THE FAILURE OF THE REVIEW AND APPROVAL PROCESS TO APPRECIATE THE SIGNIFICANT RISKS ASSOCIATED WITH THE 1MDB OFFERINGS; (III) THE FAILURE OF GS GROUP CONTROL FUNCTIONS AND SENIOR PERSONNEL TO ADDRESS RED FLAGS, INSIST ON ADEQUATE INFORMATION AND DOCUMENTATION REGARDING KEY ASPECTS OF THE OFFERINGS PRIOR TO EXECUTION, AND EFFECTIVELY SUPERVISE A SENIOR BUSINESS EMPLOYEE ABOUT WHOM CERTAIN GS GROUP PERSONNEL HAD EXPRESSED INTEGRITY CONCERNS IN THE PAST; AND (IV) THE FAILURE TO ESCALATE OR ADDRESS ALLEGATIONS OF BRIBERY COMMUNICATED TO CERTAIN SENIOR BUSINESS PERSONNEL. Status: Final Sanction Detail: PURSUANT TO THE FEDERAL RESERVE ORDER, THE FEDERAL RESERVE ORDERED GS GROUP TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $154,000,000. Summary: IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE FEDERAL RESERVE ORDER REQUIRES THAT GS GROUP TAKE CERTAIN AFFIRMATIVE ACTIONS, INCLUDING SUBMITTING TO THE FEDERAL RESERVE (I) A WRITTEN PLAN TO ENHANCE, AND MAINTAIN IMPROVEMENTS TO, OVERSIGHT OF THE REVIEW AND APPROVAL OF CERTAIN SIGNIFICANT AND COMPLEX TRANSACTIONS; (II) A WRITTEN PLAN TO ENHANCE ITS EXISTING ANTI-BRIBERY COMPLIANCE PROGRAM FOR SUCH TRANSACTIONS; AND (III) A WRITTEN ENHANCED DUE DILIGENCE PROGRAM FOR SUCH TRANSACTIONS, IN EACH CASE EACH ACCEPTABLE TO THE FEDERAL RESERVE.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE BANK OF ENGLAND PRUDENTIAL REGULATION AUTHORITY (THE "PRA" AND THE WARNING NOTICE, THE "PRA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS; AND (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. Status: Final Sanction Detail: PURSUANT TO THE PRA NOTICE, THE PRA IMPOSED ON GSI A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000. Summary: GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE PRA NOTICE.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE UK FINANCIAL CONDUCT AUTHORITY (THE "FCA" AND THE NOTICE, THE "FCA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS AND; (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. Status: Final Sanction Detail: PURSUANT TO THE FCA NOTICE, THE FCA IMPOSED ON GSI A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000. Summary: GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE FCA NOTICE.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: ON OCTOBER 22, 2020, GOLDMAN SACHS (SINGAPORE) PTE ("GS SINGAPORE") RECEIVED A NOTICE OF CONDITIONAL WARNING FROM THE SINGAPORE COMMERCIAL AFFAIRS DEPARTMENT ("SCAD"), AT THE DIRECTION OF THE SINGAPORE ATTORNEY GENERAL'S CHAMBERS (THE "SINGAPORE NOTICE"), WHICH ALLEGED GS SINGAPORE CORRUPTLY GAVE GRATIFICATION AS A REWARD IN RELATION TO EACH OF THE 1MALAYSIA DEVELOPMENT BERHAD BOND TRANSACTIONS. Status: Final Sanction Detail: PURSUANT TO THE SINGAPORE NOTICE, THE SCAD, AT THE DIRECTION OF THE SINGAPORE ATTORNEY GENERAL'S CHAMBERS, ORDERED GS SINGAPORE TO PAY A FINANCIAL PENALTY IN THE AMOUNT OF $122,000,000. Summary: GS SINGAPORE PAID A FINANCIAL PENALTY IN THE AMOUNT OF $122,000,000 IN CONNECTION WITH THE SINGAPORE NOTICE.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: THE HONG KONG SECURITIES AND FUTURES COMMISSION ("HKSFC") ISSUED A STATEMENT OF DISCIPLINARY ACTION (THE "SFC STATEMENT") AGAINST GOLDMAN SACHS (ASIA) L.L.C. ("GS ASIA"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., ON OCTOBER 22, 2020, RELATING TO GS ASIA'S FAILURE TO PROPERLY EXAMINE AND ADDRESS RED FLAGS IN CONNECTION WITH THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") TRANSACTIONS AND TO DILIGENTLY SUPERVISE ITS SENIOR PERSONNEL IN CONNECTION WITH THEIR PARTICIPATION IN THE 1MDB TRANSACTIONS. Status: Final Sanction Detail: PURSUANT TO THE SFC STATEMENT, THE HKSFC IMPOSED ON GS ASIA A FINANCIAL PENALTY IN THE AMOUNT OF $350,000,000. Summary: GS ASIA PAID A FINANCIAL PENALTY IN THE AMOUNT OF $350,000,000 IN CONNECTION WITH THE SFC STATEMENT.

Regulatory · Item 11.D(2), 11.D(4), 11.D(5) as of Nov 19, 2024

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE "DFS") HAS ALLEGED THAT: (A) A FORMER ASSOCIATE OF GOLDMAN, SACHS & CO. (TOGETHER WITH THE GOLDMAN SACHS GROUP, INC., "GOLDMAN SACHS") ENGAGED IN THE THEFT OF DFS CONFIDENTIAL SUPERVISORY INFORMATION, AND THAT A FORMER GOLDMAN SACHS MANAGING DIRECTOR IMPROPERLY RECEIVED THIS INFORMATION WITHOUT REPORTING IT; AND (B) GOLDMAN SACHS FAILED: (I) TO EFFECTIVELY SUPERVISE THE ASSOCIATE TO PREVENT THIS THEFT FROM OCCURRING; (II) TO IMPLEMENT AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES RELATING TO POST-EMPLOYMENT RESTRICTIONS FOR FORMER GOVERNMENT EMPLOYEES; AND (III) TO IMPLEMENT AND MAINTAIN SUFFICIENT POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH NEW YORK STATE BANKING LAW SECTION 36(10) ("SECTION 36(10)"), SPECIFICALLY WITH RESPECT TO GOLDMAN SACHS' UNAUTHORIZED POSSESSION AND DISTRIBUTION OF DFS CONFIDENTIAL SUPERVISORY INFORMATION. Status: Final Sanction Detail: THE CONSENT ORDER REQUIRED GOLDMAN SACHS TO PAY A CIVIL MONETARY PENALTY TO THE DFS IN THE AMOUNT OF $50 MILLION, WHICH GOLDMAN SACHS PAID ON NOVEMBER 9, 2015. Summary: GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAW SECTIONS 39 AND 44 ON OCTOBER 28, 2015 (THE "CONSENT ORDER"), PURSUANT TO WHICH GOLDMAN SACHS: (A) VOLUNTARILY WILL NOT ACCEPT ANY NEW ENGAGEMENTS THAT WOULD REQUIRE THE DFS TO AUTHORIZE THE DISCLOSURE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10) TO GOLDMAN SACHS DURING THE THREE-YEAR PERIOD FOLLOWING THE DATE OF THE CONSENT ORDER; (B) AGREED TO IMPLEMENT REFORMS TO ITS POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT THE IMPROPER USE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10), INCLUDING: (I) POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THE PROTECTION AND PROPER HANDLING OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); (II) CONFIRMING THAT, TO THE BEST OF GOLDMAN SACHS' KNOWLEDGE, AS OF THE DATE OF THE CONSENT ORDER, GOLDMAN SACHS HAD NOT ACCEPTED ANY ENGAGEMENTS THAT WOULD REQUIRE THE DFS TO AUTHORIZE THE DISCLOSURE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); (III) POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT GOLDMAN SACHS IS AWARE OF APPLICABLE POST-EMPLOYMENT RESTRICTIONS FOR FORMER GOVERNMENT EMPLOYEES HIRED AFTER THE DATE OF THE CONSENT ORDER WHO HAVE LEFT THE GOVERNMENT WITHIN THE PAST FIVE YEARS AND THAT GOLDMAN SACHS HAS TAKEN STEPS NECESSARY TO ADDRESS COMPLIANCE WITH THOSE RESTRICTIONS; (IV) PROCESSES TO MONITOR THE ASSIGNMENT OF SUCH FORMER GOVERNMENT EMPLOYEES TO PREVENT VIOLATIONS OF POST-EMPLOYMENT RESTRICTIONS AND PROTECT CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); AND (V) PROCESSES TO MONITOR THE USE OF EMAIL TO ADDRESS THE MISUSE OF CONFIDENTIAL MATERIAL UNDER SECTION 36(10); AND (C) PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50 MILLION ON NOVEMBER 9, 2015.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF AUCTION RATE SECURITIES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE OBLIGATIONS, GOLDMAN, SACHS & CO. (THE "FIRM") ENTERED INTO AN ASSURANCE OF DISCONTINUANCE ("AOD") WITH THE STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ON JUNE 2, 2009, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,952,439.67 TO THE STATE OF NEW YORK, WHICH AMOUNT WAS PAID ON JUNE 15, 2009. Summary: WITHOUT ADMITTING OR DENYING THE OBLIGATIONS, THE FIRM ENTERED INTO AN AOD WITH THE STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ON JUNE 2, 2009, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,952,439.67 TO THE STATE OF NEW YORK, WHICH AMOUNT WAS PAID ON JUNE 15, 2009.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE CALIFORNIA DEPARTMENT OF CORPORATIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE CALIFORNIA DEPARTMENT OF CORPORATION ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,595,769.53 TO THE STATE OF CALIFORNIA, WHICH WAS PAID ON MAY 6, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE CALIFORNIA DEPARTMENT OF CORPORATIONS ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,595,769.53 TO THE STATE OF CALIFORNIA, WHICH WAS PAID ON MAY 6, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE IDAHO DEPARTMENT OF FINANCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE IDAHO DEPARTMENT OF FINANCE ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,234.69 TO THE STATE OF IDAHO. THE FINE IS NOT REQUIRED TO BE PAID UNTIL AFTER JULY 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE IDAHO DEPARTMENT OF FINANCE ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,234.69 TO THE STATE OF IDAHO. THE FINE IS NOT REQUIRED TO BE PAID UNTIL AFTER JULY 1, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $51,668.04 TO THE STATE OF VERMONT, WHICH AMOUNT WAS PAID ON MAY 6, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION ON APRIL 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $51,668.04 TO THE STATE OF VERMONT, WHICH AMOUNT WAS PAID ON MAY 6, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT ON MARCH 19, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,559,615.06 TO THE STATE OF ILLINOIS, WHICH AMOUNT WAS PAID ON MARCH 31, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT ON MARCH 19, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,559,615.06 TO THE STATE OF ILLINOIS, WHICH AMOUNT WAS PAID ON MARCH 31, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS ON APRIL 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $285,652.04 TO THE STATE OF WASHINGTON, WHICH AMOUNT WAS PAID ON MAY 7, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OF FINANCIAL INSTITUTIONS ON APRIL 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $285,652.04 TO THE STATE OF WASHINGTON, WHICH AMOUNT WAS PAID ON MAY 7, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATION DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATION DIVISION OF SECURITIES ON APRIL 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,792.96 TO THE STATE OF SOUTH DAKOTA, WHICH AMOUNT WAS PAID ON MAY 7, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATION DIVISION OF SECURITIES ON APRIL 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,792.96 TO THE STATE OF SOUTH DAKOTA, WHICH AMOUNT WAS PAID ON MAY 7, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE INDIANA SECRETARY OF STATE SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE INDIANA SECRETARY OF STATE SECURITIES DIVISION ON APRIL 29, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $284,818.71 TO THE STATE OF INDIANA, WHICH AMOUNT WAS PAID ON MAY 6, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE INDIANA SECRETARY OF STATE SECURITIES DIVISION ON APRIL 29, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $284,818.71 TO THE STATE OF INDIANA, WHICH AMOUNT WAS PAID ON MAY 6, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION ON APRIL 30, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $211,744.22 TO THE STATE OF RHODE ISLAND, WHICH AMOUNT WAS PAID ON MAY 14, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION ON APRIL 30, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $211,744.22 TO THE STATE OF RHODE ISLAND, WHICH AMOUNT WAS PAID ON MAY 14, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ARIZONA CORPORATION COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ORDER TO CEASE AND DESIST, ORDER FOR ADMINISTRATIVE PENALTIES, AND CONSENT TO SAME WITH THE ARIZONA CORPORATION COMMISSION ON MAY 17, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $172,067.59 TO THE STATE OF ARIZONA, WHICH AMOUNT WAS PAID ON MAY 28, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ORDER TO CEASE AND DESIST, ORDER FOR ADMINISTRATIVE PENALTIES, AND CONSENT TO SAME WITH THE ARIZONA CORPORATION COMMISSION ON MAY 17, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $172,067.59 TO THE STATE OF ARIZONA, WHICH AMOUNT WAS PAID ON MAY 28, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ALABAMA SECURITIES COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,181,331.82 TO THE ALABAMA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE ALABAMA SECURITIES COMMISSION ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,181,331.82 TO THE ALABAMA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE GEORGIA OFFICE OF THE SECRETARY OF STATE, SECURITIES AND BUSINESS REGULATION DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE GEORGIA OFFICE OF THE SECRETARY OF STATE, SECURITIES AND BUSINESS REGULATION DIVISION ON JUNE 29, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $986,271.87 TO THE GEORGIA OFFICE OF THE SECRETARY OF STATE, SECURITIES AND BUSINESS REGULATION DIVISION, WHICH AMOUNT WAS PAID ON JULY 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE GEORGIA OFFICE OF THE SECRETARY OF STATE, SECURITIES AND BUSINESS REGULATION DIVISION ON JUNE 29, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $986,271.87 TO THE GEORGIA OFFICE OF THE SECRETARY OF STATE, SECURITIES AND BUSINESS REGULATION DIVISION, WHICH AMOUNT WAS PAID ON JULY 1, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MAINE DEPARTMENT OF PROFESSIONAL & FINANCIAL REGULATION, OFFICE OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MAINE DEPARTMENT OF PROFESSIONAL & FINANCIAL REGULATION, OFFICE OF SECURITIES ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $52,907.93 TO THE MAINE DEPARTMENT OF PROFESSIONAL & FINANCIAL REGULATION, OFFICE OF SECURITIES, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MAINE DEPARTMENT OF PROFESSIONAL & FINANCIAL REGULATION, OFFICE OF SECURITIES ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $52,907.93 TO THE MAINE DEPARTMENT OF PROFESSIONAL & FINANCIAL REGULATION, OFFICE OF SECURITIES, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SECURITIES AND CHARITIES DIVISION OF THE MISSISSIPPI SECRETARY OF STATE'S OFFICE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SECURITIES AND CHARITIES DIVISION OF THE MISSISSIPPI SECRETARY OF STATE'S OFFICE ON JUNE 22, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $49,382.88 TO THE SECURITIES AND CHARITIES DIVISION OF THE MISSISSIPPI SECRETARY OF STATE'S OFFICE, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SECURITIES AND CHARITIES DIVISION OF THE MISSISSIPPI SECRETARY OF STATE'S OFFICE ON JUNE 22, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $49,382.88 TO THE SECURITIES AND CHARITIES DIVISION OF THE MISSISSIPPI SECRETARY OF STATE'S OFFICE, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMISSIONER OF SECURITIES AND INSURANCE, OFFICE OF THE MONTANA STATE AUDITOR, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES AND INSURANCE, OFFICE OF THE MONTANA STATE AUDITOR ON JUNE 24, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $81,980.58 TO THE COMMISSIONER OF SECURITIES AND INSURANCE, OFFICE OF THE MONTANA STATE AUDITOR, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES AND INSURANCE, OFFICE OF THE MONTANA STATE AUDITOR ON JUNE 24, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $81,980.58 TO THE COMMISSIONER OF SECURITIES AND INSURANCE, OFFICE OF THE MONTANA STATE AUDITOR, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEVADA SECRETARY OF STATE SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NEVADA SECRETARY OF STATE SECURITIES DIVISION ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $278,460.65 TO THE NEVADA SECRETARY OF STATE SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JULY 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NEVADA SECRETARY OF STATE SECURITIES DIVISION ON JUNE 21, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $278,460.65 TO THE NEVADA SECRETARY OF STATE SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JULY 1, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NORTH DAKOTA SECURITIES DEPARTMENT, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH DAKOTA SECURITIES DEPARTMENT ON JUNE 22, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE NORTH DAKOTA SECURITIES DEPARTMENT, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH DAKOTA SECURITIES DEPARTMENT ON JUNE 22, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE NORTH DAKOTA SECURITIES DEPARTMENT, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OFFICE OF FINANCIAL INSTITUTIONS OF PUERTO RICO, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE OFFICE OF FINANCIAL INSTITUTIONS OF PUERTO RICO ON JUNE 23, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE OFFICE OF FINANCIAL INSTITUTIONS OF PUERTO RICO, WHICH AMOUNT WAS PAID ON JUNE 30, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE OFFICE OF FINANCIAL INSTITUTIONS OF PUERTO RICO ON JUNE 23, 2010, IN WHICH THE FIRM AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE OFFICE OF FINANCIAL INSTITUTIONS OF PUERTO RICO, WHICH AMOUNT WAS PAID ON JUNE 30, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE TEXAS STATE SECURITIES BOARD, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE TEXAS STATE SECURITIES BOARD ON JULY 27, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $2,878,447.86 TO THE TEXAS STATE SECURITIES BOARD, WHICH AMOUNT WAS PAID ON AUGUST 5, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SECURITIES COMMISSIONER OF SOUTH CAROLINA, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE SECURITIES COMMISSIONER OF SOUTH CAROLINA ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SECURITIES COMMISSIONER OF SOUTH CAROLINA ON AUGUST 9, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $67,707.37 TO THE SECURITIES COMMISSIONER OF SOUTH CAROLINA, WHICH AMOUNT WAS PAID ON AUGUST 19, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE SECURITIES COMMISSIONER OF SOUTH CAROLINA ON AUGUST 9, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $67,707.37 TO THE SECURITIES COMMISSIONER OF SOUTH CAROLINA, WHICH AMOUNT WAS PAID ON AUGUST 19, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, ON AUGUST 19, 2010 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $410,721.37 TO THE TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON SEPTEMBER 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, ON AUGUST 19, 2010 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $410,721.37 TO THE TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON SEPTEMBER 1, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS ALLEGED THAT GOLDMAN, SACHS & CO.(THE "FIRM") FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS ON SEPTEMBER 10, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $118.528.64 TO THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS, WHICH AMOUNT WAS PAID ON SEPTEMBER 23, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS ON SEPTEMBER 10, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $118.528.64 TO THE LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS, WHICH AMOUNT WAS PAID ON SEPTEMBER 23, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE ON OCTOBER 25, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $89,151.79 TO THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE, WHICH AMOUNT WAS PAID ON NOVEMBER 1, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE ON OCTOBER 25, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $89,151.79 TO THE DIVISION OF SECURITIES OF THE STATE OF DELAWARE, WHICH AMOUNT WAS PAID ON NOVEMBER 1, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE KANSAS SECURITIES COMMISSIONER, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE KANSAS SECURITIES COMMISSIONER ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE KANSAS SECURITIES COMMISSIONER ON OCTOBER 25, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $789,931.65 TO THE KANSAS SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON NOVEMBER 2, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE KANSAS SECURITIES COMMISSIONER ON OCTOBER 25, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $789,931.65 TO THE KANSAS SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON NOVEMBER 2, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE ON NOVEMBER 3, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE, WHICH AMOUNT WAS PAID ON NOVEMBER 17, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE ON NOVEMBER 3, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $45,000.00 TO THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE, WHICH AMOUNT WAS PAID ON NOVEMBER 17, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE IOWA INSURANCE DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE IOWA INSURANCE DIVISION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE IOWA INSURANCE DIVISION ON DECEMBER 2, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $53,181.86 TO THE IOWA INSURANCE DIVISION, WHICH AMOUNT WAS PAID ON DECEMBER 10, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE IOWA INSURANCE DIVISION ON DECEMBER 2, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $53,181.86 TO THE IOWA INSURANCE DIVISION, WHICH AMOUNT WAS PAID ON DECEMBER 10, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALE OF ARS. IN THE ORDER TO CEASE AND DESIST, ORDER FOR ASSESSING CIVIL PENALTY, AND CONSENT TO ENTRY OF ORDER, THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ORDER TO CEASE AND DESIST, ORDER FOR ASSESSING CIVIL PENALTY, AND CONSENT TO ENTRY OF ORDER WITH THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES ON DECEMBER 6, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $80,863.23 TO THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES, WHICH AMOUNT WAS PAID ON DECEMBER 10, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ORDER TO CEASE AND DESIST, ORDER FOR ASSESSING CIVIL PENALTY, AND CONSENT TO ENTRY OF ORDER WITH THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES ON DECEMBER 6, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $80,863.23 TO THE OREGON DEPARTMENT OF BUSINESS AND CONSUMER SERVICES, WHICH AMOUNT WAS PAID ON DECEMBER 10, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE ARKANSAS SECURITIES COMMISSIONER, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE ARKANSAS SECURITIES COMMISSIONER ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE ARKANSAS SECURITIES COMMISSIONER ON DECEMBER 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $78,556.45 TO THE ARKANSAS SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON JANUARY 6, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE ARKANSAS SECURITIES COMMISSIONER ON DECEMBER 28, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $78,556.45 TO THE ARKANSAS SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON JANUARY 6, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE CONNECTICUT DEPARTMENT OF BANKING, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE CONNECTICUT DEPARTMENT OF BANKING ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE CONNECTICUT DEPARTMENT OF BANKING ON DECEMBER 17, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,014,903.35 TO THE CONNECTICUT DEPARTMENT OF BANKING, WHICH AMOUNT WAS PAID ON DECEMBER 23, 2010. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE CONNECTICUT DEPARTMENT OF BANKING ON DECEMBER 17, 2010, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,014,903.35 TO THE CONNECTICUT DEPARTMENT OF BANKING, WHICH AMOUNT WAS PAID ON DECEMBER 23, 2010.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES ON JANUARY 18, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $46,009.22 TO THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES ON JANUARY 18, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $46,009.22 TO THE STATE OF ALASKA, DIVISION OF BANKING AND SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES ON JANUARY 12, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $508,021.39 TO THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES ON JANUARY 12, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $508,021.39 TO THE COLORADO DEPARTMENT OF REGULATORY AGENCIES, DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION ON JANUARY 14, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $91,099.58 TO THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION ON JANUARY 14, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $91,099.58 TO THE MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEBRASKA DEPARTMENT OF BANKING & FINANCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE NEBRASKA DEPARTMENT OF BANKING & FINANCE ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEBRASKA DEPARTMENT OF BANKING & FINANCE ON JANUARY 11, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $51,307.60 TO THE NEBRASKA DEPARTMENT OF BANKING & FINANCE, WHICH AMOUNT WAS PAID ON JANUARY 21, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEBRASKA DEPARTMENT OF BANKING & FINANCE ON JANUARY 11, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $51,307.60 TO THE NEBRASKA DEPARTMENT OF BANKING & FINANCE, WHICH AMOUNT WAS PAID ON JANUARY 21, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING ON JANUARY 21, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $333,137.12 TO THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING, WHICH AMOUNT WAS PAID ON JANUARY 31, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING ON JANUARY 21, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $333,137.12 TO THE VIRGINIA STATE CORPORATION COMMISSION, DIVISION OF SECURITIES & RETAIL FRANCHISING, WHICH AMOUNT WAS PAID ON JANUARY 31, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE WISCONSIN DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE WISCONSIN DIVISION OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE WISCONSIN DIVISION OF SECURITIES ON JANUARY 18, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $95,100.40 TO THE WISCONSIN DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE WISCONSIN DIVISION OF SECURITIES ON JANUARY 18, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $95,100.40 TO THE WISCONSIN DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON JANUARY 26, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MASSACHUSETTS SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MASSACHUSETTS SECURITIES DIVISION ON MAY 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,368,553.05 TO THE MASSACHUSETTS SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON MAY 13, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE MASSACHUSETTS SECURITIES DIVISION ON MAY 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,368,553.05 TO THE MASSACHUSETTS SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON MAY 13, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MARYLAND SECURITIES COMMISSIONER, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE MARYLAND SECURITIES COMMISSIONER ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MARYLAND SECURITIES COMMISSIONER ON MAY 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $722,977.33 TO THE MARYLAND SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON MAY 13, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MARYLAND SECURITIES COMMISSIONER ON MAY 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $722,977.33 TO THE MARYLAND SECURITIES COMMISSIONER, WHICH AMOUNT WAS PAID ON MAY 13, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEW JERSEY BUREAU OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE NEW JERSEY BUREAU OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEW JERSEY BUREAU OF SECURITIES ON MAY 6, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $959,794.35 TO THE NEW JERSEY BUREAU OF SECURITIES, WHICH AMOUNT WAS PAID ON MAY 11, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEW JERSEY BUREAU OF SECURITIES ON MAY 6, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $959,794.35 TO THE NEW JERSEY BUREAU OF SECURITIES, WHICH AMOUNT WAS PAID ON MAY 11, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION ON JUNE 14, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $92,584.57 TO THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, WHICH AMOUNT WAS PAID ON JUNE 20, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION ON JUNE 14, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $92,584.57 TO THE NEW HAMPSHIRE DEPARTMENT OF STATE, BUREAU OF SECURITIES REGULATION, WHICH AMOUNT WAS PAID ON JUNE 20, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE WEST VIRGINIA SECURITIES COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE WEST VIRGINIA SECURITIES COMMISSION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE WEST VIRGINIA SECURITIES COMMISSION ON JUNE 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,378.87 TO THE WEST VIRGINIA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON JUNE 20, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE WEST VIRGINIA SECURITIES COMMISSION ON JUNE 10, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,378.87 TO THE WEST VIRGINIA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON JUNE 20, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE MINNESOTA DEPARTMENT OF COMMERCE, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MINNESOTA DEPARTMENT OF COMMERCE ON OCTOBER 27, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $176,017.95 TO THE MINNESOTA DEPARTMENT OF COMMERCE, WHICH AMOUNT WAS PAID ON NOVEMBER 3, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE MINNESOTA DEPARTMENT OF COMMERCE ON OCTOBER 27, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $176,017.95 TO THE MINNESOTA DEPARTMENT OF COMMERCE, WHICH AMOUNT WAS PAID ON NOVEMBER 3, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE FLORIDA OFFICE OF FINANCIAL REGULATION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT AGREEMENT AND FINAL ORDER, THE FLORIDA OFFICE OF FINANCIAL REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. ("THE FIRM") FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT AGREEMENT AND FINAL ORDER WITH THE FLORIDA OFFICE OF FINANCIAL REGULATION ON NOVEMBER 3, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,755,209.90 TO THE FLORIDA OFFICE OF FINANCIAL REGULATION, WHICH AMOUNT WAS PAID ON NOVEMBER 14, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT AGREEMENT AND FINAL ORDER WITH THE FLORIDA OFFICE OF FINANCIAL REGULATION ON NOVEMBER 3, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $1,755,209.90 TO THE FLORIDA OFFICE OF FINANCIAL REGULATION, WHICH AMOUNT WAS PAID ON NOVEMBER 14, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NEW MEXICO SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE NEW MEXICO SECURITIES DIVISION ALLEGED THAT GOLDMAN, SACHS & CO. ("THE FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEW MEXICO SECURITIES DIVISION ON NOVEMBER 15, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $73,187.42 TO THE NEW MEXICO SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON NOVEMBER 23, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEW MEXICO SECURITIES DIVISION ON NOVEMBER 15, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $73,187.42 TO THE NEW MEXICO SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON NOVEMBER 23, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OHIO DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE OHIO DIVISION OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. ("THE FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE OHIO DIVISION OF SECURITIES ON NOVEMBER 2, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $410,062.50 TO THE OHIO DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON NOVEMBER 15, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE OHIO DIVISION OF SECURITIES ON NOVEMBER 2, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $410,062.50 TO THE OHIO DIVISION OF SECURITIES WHICH AMOUNT WAS PAID ON NOVEMBER 15, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA ALLEGED THAT GOLDMAN, SACHS & CO. ("THE FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA ON NOVEMBER 2, 2011, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $98,427.93 TO THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA, WHICH AMOUNT WAS PAID ON NOVEMBER 14, 2011. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA ON NOVEMBER 2, 2011 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $98,427.93 TO THE DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE GOVERNMENT OF THE DISTRICT OF COLUMBIA, WHICH AMOUNT WAS PAID ON NOVEMBER 14, 2011.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE OKLAHOMA DEPARTMENT OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE OKLAHOMA DEPARTMENT OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE OKLAHOMA DEPARTMENT OF SECURITIES ON MARCH 20, 2012, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $188,128.55 TO THE OKLAHOMA DEPARTMENT OF SECURITIES, WHICH AMOUNT WAS PAID APRIL 2, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE OKLAHOMA DEPARTMENT OF SECURITIES ON MARCH 20, 2012, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $188,128.55 TO THE OKLAHOMA DEPARTMENT OF SECURITIES, WHICH AMOUNT WAS PAID APRIL 2, 2012.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE UTAH DIVISION OF SECURITIES, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE STIPULATION AND CONSENT ORDER, THE UTAH DIVISION OF SECURITIES ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A STIPULATION AND CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES ON MARCH 22, 2012, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $88,007.05 TO THE UTAH DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON APRIL 6, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A STIPULATION AND CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES ON MARCH 22, 2012, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $88,007.05 TO THE UTAH DIVISION OF SECURITIES, WHICH AMOUNT WAS PAID ON APRIL 6, 2012.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE PENNSYLVANIA SECURITIES COMMISSION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE PROCEEDING, FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER, THE PENNSYLVANIA SECURITIES COMMISSION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINSITRATIVE PROCEEDING, FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER WITH THE PENNSYLVANIA SECURITIES COMMISSION ON SEPTEMBER 5, 2012 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $221,331.78 TO THE PENNSYLVANIA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON SEPTEMBER 17, 2012. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINSITRATIVE PROCEEDING, FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER WITH THE PENNSYLVANIA SECURITIES COMMISSION ON SEPTEMBER 5, 2012 IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $221,331.78 TO THE PENNSYLVANIA SECURITIES COMMISSION, WHICH AMOUNT WAS PAID ON SEPTEMBER 17, 2012.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ON JUNE 18, 2014, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $125,175.05 TO THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JUNE 26, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ON JUNE 18, 2014, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $125,175.05 TO THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JUNE 26, 2014.

Regulatory · Item 11.D(1), 11.D(2) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ON JUNE 20, 2016, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,703.26 TO THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, WHICH AMOUNT WAS PAID ON JUNE 28, 2016. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ON JUNE 20, 2016, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,703.26 TO THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, WHICH AMOUNT WAS PAID ON JUNE 28, 2016.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE SECURITIES DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS AND INVESTMENT BANKING. Status: Final Sanction Detail: THE $309,130 PAYMENT TO THE SECURITIES DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $$25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE SECURITIES DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA THAT FOUND GOLDMAN SACHS TO HAVE FAILED TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING UNDER §35-1-520(2)(B)(I) OF THE ACT.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: VARIOUS STATE REGULATORS, INCLUDING THE COMMISSIONER OF SECURITIES OF THE STATE OF LOUISIANA, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO CONFLICTS OF INTEREST BETWEEN EQUITY. Status: Final Sanction Detail: THE $344,339 PAYMENT TO THE COMMISSIONER OF SECURITIES OF THE STATE OF LOUISIANA WAS PART OF A GLOBAL SETTLEMENT WITH THE SEC, NYSE, NASD AND VARIOUS STATE REGULATORS, THAT INCLUDED: $25,000,000 AS DISGORGEMENT; $25,000,000 AS PENALTIES; $50,000,000 TO FUND INDEPENDENT, THIRD-PARTY RESEARCH; $10,000,000 FOR INVESTOR EDUCATION. Summary: WITHOUT ADMITTING OR DENYING LIABILITY, GOLDMAN SACHS ENTERED INTO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES OF THE STATE OF LOUISIANA THAT FOUND GOLDMAN SACHS TO HAVE VIOLATED THE LOUISIANA SECURITIES LAW IN FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING. ADDITIONALLY, GOLDMAN SACHS FAILED TO SUPERVISE ITS EMPLOYEES TO ENSURE ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURED AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

Regulatory · Item 11.D(1), 11.D(2), 11.D(4) as of Nov 19, 2024

Allegations: THE COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION (THE "DIVISION") ALLEGED THAT, FROM JANUARY 1, 2006 THROUGH JUNE 9, 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) TO ESTABLISH ADEQUATE PROCEDURES AND SUPERVISORY PROCESSES DESIGNED TO IDENTIFY AND MANAGE POTENTIAL CONFLICTS OF INTEREST RELATED TO ITS RESEARCH SERVICES; (II) TO HAVE ADEQUATE PROCEDURES IN PLACE REASONABLY DESIGNED TO PREVENT OR DETECT THE DISSEMINATION BY GLOBAL INVESTMENT RESEARCH ("GIR") EQUITY ANALYSTS OF CERTAIN UNPUBLISHED SHORT TERM TRADING IDEAS WHICH FAVORED THE INTERESTS OF CERTAIN PRIORITY CLIENTS; (III) TO REASONABLY SUPERVISE ITS GIR EQUITY ANALYSTS' COMMUNICATIONS TO PREVENT AND DETECT DISSEMINATION BY GIR EQUITY ANALYSTS OF CERTAIN UNPUBLISHED SHORT TERM TRADING IDEAS WHICH FAVORED THE INTERESTS OF CERTAIN PRIORITY CLIENTS; (IV) TO PREVENT THE USE AND DISSEMINATION BY GIR EQUITY ANALYSTS OF CERTAIN UNPUBLISHED SHORT TERM TRADING IDEAS WHICH FAVORED THE INTERESTS OF CERTAIN PRIORITY CLIENTS; AND (V) TO DEAL FAIRLY AND OBJECTIVELY WITH ALL CLIENTS IN CONNECTION WITH THE DISSEMINATION BY GIR EQUITY ANALYSTS OF CERTAIN UNPUBLISHED SHORT TERM TRADING IDEAS, IN ALLEGED VIOLATION OF SECTION 204(A)(2)(G) AND SECTION 204(A)(2)(J) OF THE MASSACHUSETTS UNIFORM SECURITIES ACT (THE "ACT"). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE LEGAL CONCLUSIONS OR VIOLATIONS, THE FIRM CONSENTED TO A CIVIL PENALTY IN THE AMOUNT OF $10,000,000 WHICH WAS PAID TO THE COMMONWEALTH OF MASSACHUSETTS, BY SUBMISSION OF A WIRE, ON JUNE 15, 2011. Summary: WITHOUT ADMITTING OR DENYING THE LEGAL CONCLUSIONS OR VIOLATIONS, THE FIRM ENTERED INTO AN OFFER OF SETTLEMENT WITH THE MASSACHUSETTS SECURITIES DIVISION ON JUNE 8, 2011 (THE "OFFER") AND A CONSENT ORDER, DATED JUNE 9, 2011 (THE "ORDER"), PURSUANT TO WHICH THE FIRM CONSENTED TO A CIVIL PENALTY IN THE AMOUNT OF $10,000,000 WHICH WAS PAID TO THE COMMONWEALTH OF MASSACHUSETTS, ON JUNE 15, 2011. IN CONNECTION WITH THE ORDER, THE FIRM AGREED TO (I) PERMANENTLY CEASE AND DESIST FROM VIOLATIONS OF THE ACT IN CONNECTION WITH RELATED RESEARCH ACTIVITIES; (II) PERMANENTLY DISCONTINUE THE ASI; (III) PERMANENTLY DISCONTINUE HUDDLES; (IV) WITHIN 90 DAYS OF THE SIGNED ORDER, REVIEW AND ENHANCE, AS APPROPRIATE, ITS WRITTEN SUPERVISORY POLICIES AND PROCEDURES WITH RESPECT TO CERTAIN PRACTICES WITHIN GIR; AND (V) REQUIRE THE DIRECTOR OR THE CO-DIRECTOR OF AMERICAS EQUITY RESEARCH TO CERTIFY TO THE DIVISION IN WRITING, WITHIN 180 DAYS AFTER THE DATE OF ENTRY OF THE ORDER, THAT THE FIRM HAS FULLY ADOPTED AND COMPLIED WITH THE VARIOUS UNDERTAKINGS SET FORTH IN THE CONSENT ORDER.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 27, 2022, THE SEC INSTITUTED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST GOLDMAN SACHS & CO. ("GSCO") PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), BASED ON THEIR DETERMINATION THAT FEDERAL SECURITIES LAWS WERE VIOLATED. GSCO ADMITTED AND ACCEPTED THE SEC'S JURISDICTION AND THE SUBJECT MATTER OF THESE PROCEEDINGS AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") WHICH THE SEC ACCEPTED. THE SEC FOUND THAT FROM JANUARY 2018 TO SEPTEMBER 2021, GSCO EMPLOYEES USED THEIR PERSONAL DEVICES TO COMMUNICATE BOTH INTERNALLY AND EXTERNALLY BY PERSONAL TEXT MESSAGES OR OTHER TEXT MESSAGING PLATFORMS SUCH AS WHATSAPP ("OFF-CHANNEL COMMUNICATIONS"), IN RELATION TO THE BUSINESS OF THE BROKER-DEALER OPERATED BY GSCO. GSCO'S FAILURE TO MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS WAS FIRM-WIDE, AND INVOLVED EMPLOYEES AT ALL LEVELS OF AUTHORITY. AS A RESULT, GSCO VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4). THE SEC FOUND GSCO'S FAILURE TO IMPLEMENT ITS POLICIES AND PROCEDURES THAT PROHIBIT SUCH OFF-CHANNEL COMMUNICATIONS LED TO ITS FAILURE TO SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. THE SEC UNCOVERED GSCO'S MISCONDUCT AFTER COMMENCING A RISK-BASED INITIATIVE TO INVESTIGATE THE USE OF OFF-CHANNEL AND UNPRESERVED COMMUNICATIONS AT BROKER-DEALERS. AS A RESULT, GSCO HAS INITIATED A REVIEW OF ITS RECORDKEEPING FAILURES AND BEGUN A PROGRAM OF REMEDIATION. Status: Final Sanction Detail: THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $125,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022. Summary: THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $125,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 27, 2022, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THEY HAD REASON TO BELIEVE THAT FROM AT LEAST JANUARY 2016 TO THE PRESENT ("RELEVANT PERIOD"), GOLDMAN SACHS & CO. LLC ("GSCO" ) VIOLATED SECTIONS 4G, 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6G, 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND CFTC REGULATIONS ("REGULATIONS") 1.31, 1.35, 23.201(A), 23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.201(A), 23.202(A)(1), (B)(1), 23.602(A), 166.3 (2021). AS A RESULT, THE CFTC DEEMED IT APPROPRIATE TO INSTITUTE PUBLIC ADMINISTRATIVE PROCEEDINGS TO DETERMINE WHETHER GSCO ENGAGED IN THE LISTED VIOLATIONS AND DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSING REMEDIAL SANCTIONS. GSCO ADMITTED AND ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") WHICH THE CFTC ACCEPTED. THE CFTC BECAME AWARE OF GSCO EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS FOR BUSINESS CONVERSATIONS DURING THE COURSE OF AN INVESTIGATION INTO CERTAIN OF GSCO'S TRADING. AS A RESULT, THE CFTC SUBPOENAED THE RECORDS OF FOUR GSCO TRADERS. THE COMMUNICATIONS PRODUCED BY THE TRADERS IN RESPONSE TO THOSE SUBPOENAS INDICATED THAT THE TRADERS FREQUENTLY USED NON-GSCO-APPROVED METHODS OF COMMUNICATION, INCLUDING TEXT AND WHATSAPP ("OFF-CHANNEL COMMUNICATIONS"), TO COMMUNICATE WITH OTHER GSCO TRADERS AND WITH BROKERS. THE COMMUNICATIONS ALSO REVEALED THAT EMPLOYEES AT ALL LEVELS OF AUTHORITY WERE INVOLVED IN THE USE OF THESE OFF-CHANNEL COMMUNICATIONS, WHICH WERE SENT AND RECEIVED BY GSCO EMPLOYEES RELATING TO GSCO'S BUSINESS AS A CFTC REGISTRANT, WHICH WERE REQUIRED TO BE MAINTAINED UNDER CFTC-MANDATED RECORDKEEPING REQUIREMENTS. THESE RECORDS WERE GENERALLY NOT MAINTAINED AND PRESERVED BY GSCO, AND GSCO WOULD NOT HAVE BEEN ABLE TO FURNISH SUCH COMMUNICATIONS PROMPTLY TO A CFTC REPRESENTATIVE IF AND WHEN REQUESTED, WHICH VIOLATES THE ACT. IN ADDITION, THE WIDESPREAD USE OF UNAUTHORIZED OFF-CHANNEL COMMUNICATIONS BY GSCO'S EMPLOYEES TO CONDUCT FIRM BUSINESS VIOLATED GSCO'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS. THEREFORE, THE CFTC FOUND GSCO ALSO FAILED TO IMPLEMENT A DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH THE CFTC'S RECORDKEEPING REQUIREMENTS AND THE FIRM'S OWN POLICIES AND PROCEDURES, AND BECAUSE THE FIRM FAILED TO MAINTAIN CFTC-REQUIRED RECORDS, GSCO FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS BUSINESS AS A CFTC REGISTRANT, IN VIOLATION OF THE ACT. Status: Final Sanction Detail: THE CFTC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022. Summary: THE CFTC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022.

Regulatory as of Nov 19, 2024

Allegations: ON APRIL 10, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO. THE CFTC FOUND THAT FROM IN OR ABOUT APRIL 2015 TO AT LEAST SEPTEMBER 2016 ("RELEVANT PERIOD"), GSCO VIOLATED SECTION 4S(H)(1) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. § 6S(H)(1), AND SECTIONS 23.431 AND 23.433, 17 C.F.R. §§ 23.431, 23.433, OF THE COMMISSION REGULATIONS ("REGULATIONS") IN CONNECTION WITH CERTAIN SWAP TRANSACTIONS BY FAILING TO PROVIDE OR PROVIDING INACCURATE PRE-TRADE-MID-MARKET-MARKS ("PTMMM") TO US-BASED COUNTERPARTIES AND BY FAILING TO COMMUNICATE IN A FAIR AND BALANCED MANNER BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH. THE SWAPS IN QUESTION WERE EQUITY-INDEX SWAPS IN WHICH THE EQUITY LEG OF THE SWAP WAS STRUCK ON THE SAME DAY AS THE OTHER MATERIAL TERMS OF THE SWAP WERE AGREED UPON ("SAME-DAY SWAPS"), RATHER THAN THE DAY AFTER THE DATE OF AGREEMENT. GSCO ADMITTED THAT FOR NEARLY ALL SAME-DAY SWAPS EXECUTED IN 2015 AND 2016 IT EITHER FAILED TO DISCLOSE A PTMMM OR FAILED TO DISCLOSE AN ACCURATE PTMMM. GSCO NETIHER ADMITTED NOR DENIED THE REST OF THE CFTC'S FINDINGS. Status: Final Sanction Detail: THE CFTC ORDERED THAT GSCO CEASE AND DESIST AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $15,000,000. THE FINE WAS PAID ON APRIL 20, 2023. Summary: THE CFTC ORDERED THAT GSCO CEASE AND DESIST AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $15,000,000. THE FINE WAS PAID ON APRIL 20, 2023.

Regulatory as of Nov 19, 2024

Allegations: ON AUGUST 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO. THE CFTC FOUND THAT FROM AT LEAST MARCH 2020 TO NOVEMBER 2020 ("RELEVANT PERIOD"), GSCO VIOLATED SECTION 4S(F)(1)(C) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. § 6S(F)(1)(C), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31(B)(2) AND 23.202(A)(1) AND (B)(1), 17 C.F.R. §§ 1.31(B)(2), 23.202(A)(1), (B)(1) (2022), AND VIOLATED THE CEASE-AND DESIST PROVISION OF A PRIOR COMMISSION ORDER. THE COMMISSION FOUND THAT GSCO USED RECORDING SYSTEM COMPONENTS FROM TWO VENDORS TO RECORD CERTAIN PHONE CALLS, AND DUE TO FAILURES IN THOSE SYSTEMS, GSCO FAILED TO MAKE AND RETAIN A NUMBER OF RECORDINGS OF TRADERS AND SALES PERSONNEL THAT CONTAINED THE ORAL COMMUNICATIONS THAT LED TO THE EXECUTION OF SWAPS AND RELATED CASH AND FORWARD TRANSACTIONS DURING THE RELEVANT PERIOD. CONSEQUENTLY, GSCO ALSO VIOLATED AN ORDER THAT THE COMMISSION HAD PREVIOUSLY ISSUED ON NOVEMBER 26, 2019, RELATED TO OTHER SWAP DEALER RECORDKEEPING VIOLATIONS UNDER THE SAME PROVISIONS. GSCO NEITHER ADMITTED NOR DENIED ANY OF CFTC'S FINDINGS. Status: Final Sanction Detail: THE CFTC ORDERED THAT GSCO CEASE AND DESIST, AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $5,500,000. THE FINE WAS PAID ON SEPTEMBER 8, 2023. Summary: THE CFTC ORDERED THAT GSCO CEASE AND DESIST, AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $5,500,000. THE FINE WAS PAID ON SEPTEMBER 8, 2023.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 22, 2023, THE SECURITIES AND EXCHANGE COMMISSION ("SEC" OR "COMMISSION") INSTITUTED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST GOLDMAN SACHS & CO. ("GSCO" OR "THE FIRM") PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), BASED ON THEIR DETERMINATION THAT FEDERAL SECURITIES LAWS WERE VIOLATED. GSCO ADMITTED THE SEC'S JURISDICTION AND THE FACTS SET FORTH IN THE ORDER AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICH THE SEC ACCEPTED. THE SEC FOUND THAT FROM AT LEAST NOVEMBER 2012 THROUGH OCTOBER 2022, AT LEAST 22,192 OUT OF 52,147 OF THE ELECTRONIC BLUE SHEETS ("EBS") SUBMITTED BY GSCO INCLUDED INACCURATE OR INCOMPLETE INFORMATION, RESULTING IN THE MISREPORTING OF TRADE DATA. AS A RESULT, THE FIRM VIOLATED THE RECORDKEEPING AND REPORTING REQUIREMENTS OF SECTION 17(A)(1) OF THE EXCHANGE ACT AND RULES 17A-4(J) AND 17A-25. GSCO INITIATED A VOLUNTARY REMEDIATION PROGRAM AND IS RESUBMITTING CORRECTED EBS TO THE COMMISSION. Status: Final Sanction Detail: THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023. Summary: THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE COMMISSION'S FINDINGS. THE CFTC FOUND THAT FROM DECEMBER 31, 2012 TO THE PRESENT, GSCO VIOLATED SECTIONS 2(A)(13)(F) AND (G) AND 4S(H)(1) OF THE COMMODITY EXCHANGE ACT ("CEA"), 7 U.S.C. §§ 2(A)(13)(F), (G), 6S(H)(1), AND COMMISSION REGULATIONS 23.431(A)(3)(I), 23.602(A), 43.3(A)(1), 45.3(B)(1), 45.4(C), 45.6, 17 C.F.R. §§ 23.431(A)(3)(I), 23.602(A), 43.3(A)(1), 45.3(B)(1), 45.4(C), AND 45.6 (2022) IN CONNECTION WITH GSCO'S ALLEGED FAILURE TO REPORT ACCURATELY AND TIMELY SWAP DATA, DISCLOSE CERTAIN PTMMMS IN ACCORDANCE WITH THE CFTC'S REQUIREMENTS, AND SUPERVISE CERTAIN AREAS OF ITS SWAP DEALER BUSINESS, INCLUDING SWAP DATA REPORTING, PRE-TRADE MID MARKET MARKS ("PTMMM") DISCLOSURES, A PERSONNEL REPORTING LINE, CLEARING MEMBER RISK MANAGEMENT POLICY, NOTICES REGARDING ITS INITIAL MARGIN MODEL AND TO UNSEGREGATED CLIENTS, AND DISCLOSURE OF STATIC MATERIAL ECONOMIC TERMS. GSCO HAS AND CONTINUES TO TAKE REMEDIAL STEPS TO ADDRESS THE DEFICIENCIES. Status: Final Sanction Detail: THE CFTC ORDERED THAT GSCO CEASE AND DESIST FROM VIOLATING THESE PROVISIONS OF THE CEA AND COMMISSION REGULATIONS; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023. Summary: THE CFTC ORDERED THAT GSCO CEASE AND DESIST FROM VIOLATING THESE PROVISIONS OF THE CEA AND COMMISSION REGULATIONS; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE COMMISSION'S FINDINGS. THE CFTC FOUND THAT GSCO FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM WITH RESPECT TO DISRUPTIVE TRADING, IN VIOLATION OF COMMISSION REGULATION 166.3, IN CONNECTION WITH A SINGLE EIGHT-MINUTE TRADING EPISODE FROM DECEMBER 29, 2017. ADDITIONALLY, THE CFTC FOUND THAT GSCO REASONABLY SHOULD HAVE KNOWN THAT THE OMISSION OF INFORMATION REGARDING THE FIRM'S CONTROL SYSTEMS AND THEIR MALFUNCTION IN CONNECTION WITH DECEMBER 29, 2017 TRADING EPISODE FROM A STATEMENT TO THE CFTC'S DIVISION OF ENFORCEMENT WAS MATERIALLY MISLEADING, IN VIOLATION OF SECTION 6(C)(2) OF THE COMMODITY EXCHANGE ACT. Status: Final Sanction Detail: THE CFTC ORDERED THAT GSCO CEASE AND DESIST; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $3,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023. Summary: THE CFTC ORDERED THAT GSCO CEASE AND DESIST; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $3,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023.

Regulatory as of Nov 19, 2024

Allegations: ON SEPTEMBER 25, 2024, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC"), WHICH ALLEGED GS GROUP AND RELEVANT GS GROUP AFFILIATES FAILED TO TIMELY FILE SECTION 16(A) REPORTS WITH RESPECT TO CERTAIN ISSUERS, INCLUDING LATE-REPORTED TRANSACTIONS EXECUTED FROM MARCH 2018 TO NOVEMBER 2021. WITHOUT ADMITTING OR DENYING THE FINDINGS, GS GROUP CONSENTED TO THE ENTRY OF THE SEC'S ORDER TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 16(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 16A-3 AND AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $300,000, WHICH GS GROUP PAID ON OCTOBER 15, 2024. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, GS GROUP CONSENTED TO THE ENTRY OF THE SEC'S ORDER TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 16(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 16A-3 AND AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $300,000, WHICH GS GROUP PAID ON OCTOBER 15, 2024. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, GS GROUP CONSENTED TO THE ENTRY OF THE SEC'S ORDER TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 16(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 16A-3 AND AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $300,000, WHICH GS GROUP PAID ON OCTOBER 15, 2024.

Regulatory as of Nov 19, 2024

Allegations: ON DECEMBER 21, 2016, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS (THE "ORDER") AGAINST THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") AND GOLDMAN, SACHS & CO. (THE "FIRM", AND TOGETHER WITH GS GROUP, "GOLDMAN") RELATING TO ATTEMPTED MANIPULATION OF THE U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION FIX ("USD ISDAFIX"), AN INTEREST RATE BENCHMARK. SPECIFICALLY, THE CFTC FOUND THAT, FROM JANUARY 2007 THROUGH MARCH 2012, CERTAIN TRADERS ON THE FIRM'S INTEREST RATE PRODUCTS TRADING DESKS SUBMITTED BIDS AND OFFERS, AND EXECUTED TRADES, THAT WERE DESIGNED TO ATTEMPT TO MANIPULATE THE USD ISDAFIX. IN ADDITION, THE CFTC FOUND THAT THESE TRADERS ATTEMPTED TO AFFECT THE RATE AT WHICH USD ISDAFIX WAS SET BY MAKING FALSE, MISLEADING, OR KNOWINGLY INACCURATE SUBMISSIONS TO CERTAIN SWAPS BROKERS FOR INCLUSION IN THE CALCULATION OF THE DAILY RATES. THE ORDER ALSO STATES THAT THE TRADERS SUBMITTED ORAL AND WRITTEN REQUESTS FOR CERTAIN RATES TO BE SUBMITTED, WHICH WOULD BENEFIT THE FIRM'S TRADING POSITIONS. THE CFTC FOUND THAT GOLDMAN VIOLATED COMMODITY EXCHANGE ACT SECTIONS 6(C), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9, 13B, 13(A)(2) (2006), AND FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011, SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9(1), 9(1)(A), 9(3), 13B, 13(A)(2) (2012), AND CFTC REGULATIONS 180.1(A) AND 180.2, 17 C.F.R. §§ 180.1(A), 180.2 (2015). Status: Final Sanction Detail: THE ORDER REQUIRED GOLDMAN TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $120 MILLION, WHICH THE FIRM PAID DECEMBER 28, 2016. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, GOLDMAN CONSENTED TO THE ENTRY OF THE ORDER ON DECEMBER 21, 2016 BY THE CFTC, PURSUANT TO WHICH GOLDMAN: (A) SHALL CEASE AND DESIST FROM VIOLATING COMMODITY EXCHANGE ACT SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9(1), 9(1)(A), 9(3), 13B, 13(A)(2) (2012), AND CFTC REGULATIONS 180.1(A) AND 180.2, 17 C.F.R. §§ 180.1(A), 180.2 (2015); (B) PAY A CIVIL MONETARY PENALTY OF $120 MILLION, WHICH THE FIRM PAID ON DECEMBER 28, 2016; AND (C) COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE ORDER, INCLUDING PROVIDING A REPORT TO THE CFTC WITHIN 120 DAYS OF THE ORDER, ADDRESSING REMEDIATION EFFORTS BOTH PRIOR TO AND SINCE THE ENTRY OF THE ORDER, AND PROVIDING AN ADDITIONAL REPORT TO THE CFTC, NO LATER THAN 365 DAYS OF THE ENTRY OF THE ORDER, EXPLAINING HOW IT HAS COMPLIED WITH THE UNDERTAKINGS SET FORTH IN THE ORDER.

Regulatory as of Nov 19, 2024

Allegations: THE SEC ALLEGED THAT GOLDMAN SACHS SALES TRADERS FOR THE ASIAN SHARES SALES DESK MADE PUBLIC OFFERS OF SECURITIES VIA E MAIL TO CERTAIN INSTITUTIONAL CUSTOMERS IN CONNECTION WITH FOUR INTERNATIONAL PUBLIC OFFERINGS DURING THE "WAITING PERIOD," WHEN THE REGISTRATION STATEMENTS WERE FILED, BUT NOT YET DECLARED EFFECTIVE BY THE SEC, DURING THE PERIOD OCTOBER 1999 TO MARCH 2000, IN VIOLATION OF SECTION 5(B) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"). THE SEC ALLEGED THAT GOLDMAN SACHS FAILED TO SUPERVISE THESE SALES TRADERS FOR PURPOSES OF SECTION 15(B)(4)(E) OF THE SECURITIES EXCHANGE ACT OF 1934. THE SEC ALSO ALLEGED THAT A GOLDMAN SACHS REPRESENTATIVE MADE COMMENTS TO THE MEDIA ON FOUR OCCASIONS IN CONNECTION WITH ONE OF THE PUBLIC OFFERING DURING THE "PRE-FILING PERIOD," THE PERIOD BEFORE THE REGISTRATION STATEMENT WAS FILED WITH THE SEC, FROM JANUARY TO FEBRUARY 2000, IN VIOLATION OF SECTION 5(C) OF THE SECURITIES ACT. Status: Final Sanction Detail: GOLDMAN SACHS PAID A TOTAL FINE OF $2,000,000. Summary: GOLDMAN SACHS SUBMITTED AN OFFER TO THE SEC, WHICH WAS ACCEPTED. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GOLDMAN SACHS OFFERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS, AND ANY FUTURE VIOLATIONS, OF SECTION 5(B) AND 5(C) OF THE SECURITIES ACT, AND TO PAY A CIVIL MONEY PENALTY OF $2,000,000 TO THE UNITED STATES TREASURY.

Regulatory as of Nov 19, 2024

Allegations: SEC ALLEGED THAT FOURTEEN INVESTMENT BANKING FIRMS, INCLUDING GS, VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933, BY ENGAGING IN ONE OR MORE PRACTICES RELATING TO AUCTIONS OF AUCTION RATE SECURITIES DURING THE PERIOD FROM JANUARY 1, 2003 THROUGH JUNE 30, 2004 AS DESCRIBED IN THE CEASE-AND-DESIST ORDER ENTERED BY THE SEC. Status: Final Sanction Detail: GOLDMAN SACHS & CO. CONSENTED TO A CENSURE AND A CEASE-AND-DESIST ORDER AND, ON JUNE 9, 2006, PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $1,500,000. Summary: AS PART OF A MULTI-FIRM SETTLEMENT, GS SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BY THE SEC ON MAY 31, 2006. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS CONSENTED TO A CENSURE AND CEASE-AND-DESIST ORDER AND PAYMENT OF $1,500,000 CIVIL MONEY PENALTY.

Regulatory as of Nov 19, 2024

Allegations: STARTING IN JULY 2008, NEIL M.M. MORRISON ("MORRISON") WAS EMPLOYED BY GOLDMAN, SACHS & CO. (THE "FIRM") TO SOLICIT MUNICIPAL UNDERWRITING BUSINESS FROM, AMONG OTHERS, THE COMMONWEALTH OF MASSACHUSETTS TREASURER'S OFFICE. FROM NOVEMBER 2008 TO OCTOBER 2010, MORRISON WAS ALSO SUBSTANTIALLY ENGAGED IN THE POLITICAL CAMPAIGNS, INCLUDING THE NOVEMBER 2010 MASSACHUSETTS GUBERNATORIAL CAMPAIGN, FOR TIMOTHY P. CAHILL ("CAHILL"), THE THEN-TREASURER OF MASSACHUSETTS. MORRISON WORKED ON CAHILL'S CAMPAIGN DURING WORK HOURS USING FIRM RESOURCES. MORRISON ALSO MADE A SECRET, UNDISCLOSED CASH CAMPAIGN CONTRIBUTION TO CAHILL. WITHIN TWO YEARS OF MORRISON'S CONTRIBUTIONS, THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESS WITH ISSUERS ASSOCIATED WITH CAHILL AS TREASURER AND AS A CANDIDATE FOR GOVERNOR. THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") ALLEGED THAT THE FIRM'S ENGAGEMENT IN MUNICIPAL SECURITIES BUSINESS WITH THESE ISSUERS VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT AND MSRB RULE G-37(B), AND THAT THE FIRM'S FAILURE TO MAINTAIN RECORDS OF AND TO REPORT IN REGULATORY FILINGS THE CONTRIBUTIONS AND CAMPAIGN WORK, AND TO TAKE STEPS TO ENSURE THAT THE ATTRIBUTED CONTRIBUTIONS, OR CAMPAIGN WORK OR THE CONFLICTS OF INTEREST RAISED BY THEM WERE DISCLOSED IN BOND OFFERING DOCUMENTS, VIOLATED MSRB RULES G-8, G-9, G-17, G-27 AND G-37. WITHOUT ADMITTING OR DENYING THE VIOLATIONS (EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS), THE FIRM CONSENTED TO THE ENTRY OF THE ORDER. Status: Final Sanction Detail: THE FIRM AGREES TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, MSRB RULE G 37(B), MSRB RULE G-17, MSRB RULE G-27, MSRB RULE G-37(E), MSRB RULE G-8 AND MSRB RULE G-9. THE FIRM IS CENSURED AND WILL PAY DISGORGEMENT OF $7,558,942 AND PREJUDGMENT INTEREST OF $670,033. OF THE $7,558,942 IN DISGORGEMENT, $2,120,547 WILL BE DEEMED SATISFIED BY RESPONDENT'S PAYMENT OF $1,512,902 TO THE COMMONWEALTH OF MASSACHUSETTS AND $607,645 TO THE MASSACHUSETTS WATER POLLUTION ABATEMENT TRUST IN A RELATED ACTION BY THE COMMONWEALTH OF MASSACHUSETTS. THE REMAINING $5,438,395 AND PREJUDGMENT INTEREST OF $670,033 WILL BE PAID TO THE COMMISSION FOR REMITTANCE TO THE UNITED STATES TREASURY. FINALLY, THE ORDER REQUIRES THE FIRM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,750,000 TO THE COMMISSION, OF WHICH $1,875,000 WILL BE TRANSFERRED TO THE MSRB IN ACCORDANCE WITH SECTION 15B(C)(9)(A) OF THE EXCHANGE ACT, AND OF WHICH THE REMAINING $1,875,000 WILL BE TRANSFERRED TO THE UNITED STATES TREASURY. THE DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL MONEY PENALTY WERE PAID IN FULL BY SUBMISSION OF A WIRE TO THE COMMISSION ON OCTOBER 3, 2012, AND BY SUBMISSION OF CHECKS TO THE COMMONWEALTH OF MASSACHUSETTS AND THE MASSACHUSETTS WATER POLLUTION ABATEMENT TRUST ON OCTOBER 4, 2012. Summary: THE FIRM AGREES TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, MSRB RULE G 37(B), MSRB RULE G-17, MSRB RULE G-27, MSRB RULE G-37(E), MSRB RULE G-8 AND MSRB RULE G-9. THE FIRM IS CENSURED AND WILL PAY DISGORGEMENT OF $7,558,942 AND PREJUDGMENT INTEREST OF $670,033. OF THE $7,558,942 IN DISGORGEMENT, $2,120,547 WILL BE DEEMED SATISFIED BY RESPONDENT'S PAYMENT OF $1,512,902 TO THE COMMONWEALTH OF MASSACHUSETTS AND $607,645 TO THE MASSACHUSETTS WATER POLLUTION ABATEMENT TRUST IN A RELATED ACTION BY THE COMMONWEALTH OF MASSACHUSETTS. THE REMAINING $5,438,395 AND PREJUDGMENT INTEREST OF $670,033 WILL BE PAID TO THE COMMISSION FOR REMITTANCE TO THE UNITED STATES TREASURY. FINALLY, THE ORDER REQUIRES THE FIRM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,750,000 TO THE COMMISSION, OF WHICH $1,875,000 WILL BE TRANSFERRED TO THE MSRB IN ACCORDANCE WITH SECTION 15B(C)(9)(A) OF THE EXCHANGE ACT, AND OF WHICH THE REMAINING $1,875,000 WILL BE TRANSFERRED TO THE UNITED STATES TREASURY. THE DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL MONEY PENALTY WERE PAID IN FULL BY SUBMISSION OF A WIRE TO THE COMMISSION ON OCTOBER 3, 2012, AND BY SUBMISSION OF CHECKS TO THE COMMONWEALTH OF MASSACHUSETTS AND THE MASSACHUSETTS WATER POLLUTION ABATEMENT TRUST ON OCTOBER 4, 2012.

Regulatory as of Nov 19, 2024

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"), IN AN ORDER, SET FORTH FINDINGS AND CONCLUSIONS TO WHICH GOLDMAN, SACHS & CO. (THE "FIRM") CONSENTED, WITHOUT ADMITTING OR DENYING THEM, AS PART OF AN OFFER OF SETTLEMENT THAT WAS ACCEPTED BY THE CFTC AND BECAME EFFECTIVE ON DECEMBER 7, 2012 (THE "ORDER"). IN ITS FINDINGS IN THE ORDER, THE CFTC ASSERTED THAT THE FIRM FAILED FOR SEVERAL MONTHS, INCLUDING AT LEAST NOVEMBER AND DECEMBER 2007, TO ENSURE THAT CERTAIN ASPECTS OF ITS RISK MANAGEMENT, COMPLIANCE, AND SUPERVISION PROGRAMS COMPORTED WITH ITS OBLIGATIONS TO SUPERVISE DILIGENTLY ITS BUSINESS AS A CFTC REGISTRANT. DURING NOVEMBER AND DECEMBER 2007, THE FIRM FURTHER FAILED TO SUPERVISE DILIGENTLY THE TRADING ACTIVITIES OF AN ASSOCIATED PERSON, WHOSE TRADING ACTIVITIES ON SEVEN DAYS IN MID-NOVEMBER AND MID-DECEMBER 2007 IN THE E-MINI S&P 500 FUTURES CONTRACT, TRADED ON THE CHICAGO MERCANTILE EXCHANGE'S GLOBEX PLATFORM, RESULTED IN A SUBSTANTIAL LOSS TO THE FIRM ($118 MILLION). AS A RESULT, THE CFTC ALLEGED THAT THE FIRM FAILED TO HAVE POLICIES OR PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT THE MANUAL ENTRY OF FABRICATED FUTURES TRADES INTO ITS FRONT OFFICE SYSTEMS, WHICH AGGREGATED MANUALLY ENTERED AND ELECTRONICALLY EXECUTED TRADES IN THE SAME PRODUCT, IN ALLEGED VIOLATION OF CFTC REGULATION 166.3. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR CONCLUSIONS THEREIN, THE FIRM MADE AN OFFER OF SETTLEMENT AND CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OF THE COMMODITY EXCHANGE ACT, AS AMENDED, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS THAT WAS ACCEPTED BY THE CFTC AND BECAME EFFECTIVE ON DECEMBER 7, 2012 (THE "ORDER"). THE ORDER ORDERS THE FIRM TO CEASE AND DESIST FROM VIOLATING CFTC REGULATION 166.3 AND IMPOSES A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE TO THE CFTC ON DECEMBER 14, 2012. IN ADDITION, THE ORDER INCLUDED UNDERTAKINGS BY THE FIRM. Summary: WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OR CONCLUSIONS THEREIN, THE FIRM MADE AN OFFER OF SETTLEMENT AND CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OF THE COMMODITY EXCHANGE ACT, AS AMENDED, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS THAT WAS ACCEPTED BY THE CFTC AND BECAME EFFECTIVE ON DECEMBER 7, 2012 (THE "ORDER"). THE ORDER ORDERS THE FIRM TO CEASE AND DESIST FROM VIOLATING CFTC REGULATION 166.3 AND IMPOSES A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000, WHICH WAS PAID BY THE SUBMISSION OF A WIRE TO THE CFTC ON DECEMBER 14, 2012. IN ADDITION, THE ORDER INCLUDED UNDERTAKINGS BY THE FIRM. IN SETTLING THE MATTER, THE CFTC TOOK INTO ACCOUNT THE COOPERATION OF THE FIRM AND THE CORRECTIVE ACTION THE FIRM UNDERTOOK AFTER THE TRADER'S ACTIVITIES WERE DISCOVERED.

Regulatory as of Nov 19, 2024

Allegations: THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") HAS ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND, AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN THE FIRM OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. THE VIOLATIONS DISCUSSED IN THE ORDER WERE SELF-REPORTED BY THE FIRM TO THE SEC PURSUANT TO THE DIVISION OF ENFORCEMENT'S MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION INITIATIVE. Status: Final Sanction Detail: THE ORDER REQUIRED THE FIRM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000, WHICH THE FIRM PAID ON JUNE 25, 2015. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ON JUNE 18, 2015 BY THE SEC PURSUANT TO WHICH THE FIRM: (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933; (II) PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 ON JUNE 25, 2015; AND (III) SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.

Regulatory as of Nov 19, 2024

Allegations: THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") HAS ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") DID NOT HAVE A SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MANAGE THE FINANCIAL, REGULATORY, AND OTHER RISKS OF MARKET ACCESS IN RELATION TO ITS LISTED EQUITY OPTIONS BUSINESS, WHICH CONTRIBUTED TO THE ENTRY OF ERRONEOUS ELECTRONIC OPTIONS ORDERS ON MULTIPLE OPTIONS EXCHANGES ON AUGUST 20, 2013. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED SECTION 15(C)(3) OF THE EXCHANGE ACT AND RULE 15C3-5 THEREUNDER IN RELATION TO ITS CONTROLS AND SUPERVISORY PROCEDURES ADDRESSING (I) THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT OR CAPITAL THRESHOLDS; (II) THE ENTRY OF ERRONEOUS ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS OR THAT INDICATE DUPLICATIVE ORDERS; AND (III) THE MANAGEMENT OF SOFTWARE CHANGES THAT IMPACT ORDER FLOW. Status: Final Sanction Detail: THE ORDER REQUIRED THE FIRM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $7 MILLION, WHICH THE FIRM PAID ON JUNE 30, 2015. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ON JUNE 30, 2015 BY THE SEC PURSUANT TO WHICH THE FIRM: (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15(C)(3) OF THE EXCHANGE ACT AND RULE 15C3-5 THEREUNDER; (II) IS CENSURED; AND (III) PAID A TOTAL CIVIL MONEY PENALTY OF $7 MILLION ON JUNE 30, 2015.

Regulatory as of Nov 19, 2024

Allegations: THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") VIOLATED REGULATION SHO UNDER THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") BY IMPROPERLY RELYING ON THE FIRM'S AUTOMATED LOCATE FUNCTION IN THE ORDER MANAGEMENT SYSTEM WITHOUT HAVING CONFIRMED THE AVAILABILITY OF THE SECURITIES TO BE LOCATED. IN ADDITION, THE SEC ALLEGED THAT FIRM EMPLOYEES DID NOT PROVIDE SUFFICIENT AND ACCURATE INFORMATION WITH RESPECT TO THESE LOCATES IN THE FIRM'S LOCATE LOG, WHICH MUST REFLECT THE BASIS UPON WHICH THE FIRM PROVIDED THE LOCATES. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED RULE 203(B)(1) OF REGULATION SHO AND SECTION 17(A) OF THE EXCHANGE ACT. Status: Final Sanction Detail: THE ORDER REQUIRED THE FIRM TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15 MILLION, WHICH THE FIRM PAID ON JANUARY 20, 2016. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (RELEASE NO. 34-76899, JAN. 14, 2016). PURSUANT TO THE ORDER, THE FIRM MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 203(B)(1) OF REGULATION SHO, AND ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 203(B)(1)(III) THEREUNDER RELATING TO SHORT SALE LOCATE RECORDS. ALSO PURSUANT TO THE ORDER, THE FIRM WAS CENSURED AND PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000 ON JANUARY 20, 2016. THE SEC STATED THAT, IN DETERMINING TO ACCEPT THE FIRM'S OFFER OF SETTLEMENT, IT CONSIDERED CERTAIN REMEDIAL ACTS TAKEN BY THE FIRM.

Regulatory as of Nov 19, 2024

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO AN ORDER INSTITUTING CEASE AND DESIST PROCEEDINGS WITH THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC" AND THE ORDER, THE "SEC ORDER"), WHICH ALLEGED GS GROUP FAILED TO REASONABLY MAINTAIN A SUFFICIENT SYSTEM OF INTERNAL ACCOUNTING CONTROLS BETWEEN 2012 AND 2015 WITH RESPECT TO THE PROCESS BY WHICH IT REVIEWED AND APPROVED THE COMMITMENT OF FIRM CAPITAL IN LARGE, SIGNIFICANT AND COMPLEX TRANSITIONS, SUCH AS THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") OFFERINGS, AND THAT DOCUMENTATION PREPARED IN CONNECTION WITH THE 1MDB TRANSACTIONS DID NOT ACCURATELY REFLECT CERTAIN ASPECTS OF THE BOND OFFERINGS, INCLUDING THE INVOLVEMENT OF A THIRD PARTY INTERMEDIARY IN THE OFFERINGS. Status: Final Sanction Detail: PURSUANT TO THE SEC ORDER, THE SEC REQUIRED GS GROUP (I) TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000,000 AND (II) TO PAY DISGORGEMENT OF $606,300,000, WITH DOLLAR-FOR-DOLLAR DISGORGEMENT CREDIT UP TO THAT AMOUNT BASED ON THE U.S. DOLLAR VALUE OF SIMILAR PAYMENTS MADE TO THE GOVERNMENT OF MALAYSIA AND 1MDB PURSUANT TO THE PARALLEL SETTLEMENT AGREEMENT ENTERED INTO BY GS GROUP ON AUGUST 18, 2020 (THE "SETTLEMENT AGREEMENT"). Summary: GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000,000 TO THE SEC AND DISGORGEMENT OF $606,300,000, WITH DOLLAR-FOR-DOLLAR DISGORGEMENT CREDIT UP TO THAT AMOUNT BASED ON THE U.S. DOLLAR VALUE OF SIMILAR PAYMENTS MADE PURSUANT TO THE SETTLEMENT AGREEMENT.

Regulatory as of Nov 19, 2024

Allegations: THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") HAS ALLEGED THAT THE HUDDLES PROGRAM OF GOLDMAN, SACHS & CO. (THE "FIRM") -A PRACTICE WHERE THE FIRM'S EQUITY RESEARCH ANALYSTS ALLEGEDLY PROVIDED THEIR BEST TRADING IDEAS TO FIRM TRADERS AND A SELECT GROUP OF THE FIRM'S TOP CLIENTS-CREATED A SERIOUS AND SUBSTANTIAL RISK THAT ANALYSTS WOULD SHARE MATERIAL NONPUBLIC INFORMATION CONCERNING THEIR PUBLISHED RESEARCH WITH ASYMMETRIC SERVICE INITIATIVE ("ASI") CLIENTS AND FIRM TRADERS. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED SECTION 15(G) OF THE EXCHANGE ACT BY FAILING ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE POLICIES AND PROCEDURES TO PREVENT SUCH MISUSE IN LIGHT OF THE RISKS ARISING FROM THE HUDDLES AND ASI. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO A TOTAL CIVIL MONEY PENALTY OF $22 MILLION WHICH WAS PAID ON APRIL 19, 2012, $11 MILLION OF WHICH WAS PAID TO THE FINANCIAL INDUSTRY REGULATORY AUTHORITY IN A RELATED PROCEEDING, AND $11 MILLION OF WHICH WAS PAID TO THE SEC. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND DESIST ORDER ON APRIL 12, 2012 (THE "ORDER") BY THE SEC PURSUANT TO WHICH FIRM (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15(G) OF THE EXCHANGE ACT; (II) IS CENSURED; (III) PAID A TOTAL CIVIL MONEY PENALTY OF $22 MILLION ON APRIL 19, 2012, $11 MILLION OF WHICH WAS PAID TO THE FINANCIAL INDUSTRY REGULATORY AUTHORITY IN A RELATED PROCEEDING, AND $11 MILLION OF WHICH WAS PAID TO THE SEC, AND (IV) SHALL COMPLY WITH CERTAIN OTHER UNDERTAKINGS, INCLUDING A COMPREHENSIVE REVIEW, INCLUDING RECOMMENDATIONS, OF THE POLICIES, PROCEDURES AND PRACTICES MAINTAINED AND IMPLEMENTED BY THE FIRM PURSUANT TO SECTION 15(G) OF THE EXCHANGE ACT THAT RELATE TO THE FINDINGS OF THE ORDER.

Disclosure text reproduced verbatim from the firm's own Form ADV filings.

How they charge

  • Percentage of assets under management
  • Fixed fees
  • Commissions
  • Performance-based fees
  • Other fees
  • EXECUTION CHARGES, CUSTODY, MANAGEMENT FEE

Services

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Custody

Reported custodians

Amounts as reported in ADV Item 5.K.(3) (custodians holding 10%+ of SMA assets).

Firm reports having custody of client funds or securities (Item 9.A).

Source

All data on this page comes from this firm's Form ADV filings, reproduced without modification. Latest filing: Jul 27, 2026.

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