X0405 TA-1/A 0000842657 XXXXXXXX 084-01713 true LIVE SEC DWS Service Co Deutsche AM Service Co 417949 222 S. Riverside Plaza Chicago IL 60606 N 212-250-2500 N Y Y DST Systems, Inc. 084-00448 333 West 11th Street Kansas City MO 64105 N Corporation Kristine Lyons 09/22/2005 Director and Vice President NA true Nancy Tanzil 05/13/2014 Chief Financial Officer and Treasurer NA DWS Investment Management Americas Inc. 02/06/1998 100% owner of Registrant E true Deutsche Asset Management US Holding Corporation (DeAM US Holding Corp.) 08/01/2017 100% owner of DIMA E true 05/01/2018 Michael Sharkey 11/01/2017 Director and President NA true Anjie Larocca 06/14/2017 Secretary NA true Deutsche Bank AG 04/02/2018 owner of DB Beteiligungs - Holding GmbH E true DWS Group GmbH & Co KGaA 04/02/2018 100% owner of DeAM US Holding Corp. E true DB Beteiligungs - Holding GmbH 04/02/2018 77,5% owner of DWS Group GmbH & Co KGaA E true DWS USA Corporation 05/01/2018 100% owner of DIMA E true Hepsen Uzcan 06/25/2018 Director and Vice President NA true Nicole Grogan 07/26/2019 Director and Vice President NA true N N Y DB Group Services UK LTD, A Control Affiliate of the Registrant Libor 04/23/2015 U.S. Department of Justice, U.S. District Court, District of Connectict The Registrant has not been the subject of this matter: Date Initiated: 4/23/2015. DB Group Services UK LTD. a UK-based affiliate of DBSI, agreed to plead guilty to one count of wire fraud relating to manipulative conduct relating to USD Libor and also agreed to pay a fine of $150 million. DB Group Services UK LTD plead guilty to one count of wire fraud relating to manipulative conduct relating to USD Libor and also agreed to pay a fine of $150 million. DB Group Services UK LTD plead guilty to one count of wire fraud relating to manipulative conduct relating to USD Libor and also agreed to pay a fine of $150 million. Deutsche Securities Korea. CO. (DSK), a Control Affiliate of the Registrant 2011 GOHAP 1120 01/25/2016 The Seoul Central District Court The Registrant has not been the subject of this matter: Date Initiated: 1/25/2016. Deutsche Securities Korea. CO. ("DSK"). On August 19, 2011, The Korean Seoul Central District Prosecutors' Office filed a criminal indictment against DSK for vicarious criminal liability for negligence in supervising the acts of one of the four individuals, which was a DSK employee. DSK is a broker dealer in Korea that is a subsidiary of DBAG and an affiliate of Deutsche Bank Securities Inc. The subject KOSPI Matter involves the allegation that the DB's equity traders based in Hong Kong and in DSK manipulated the closing KOSPI200 Index on Nov 10, 2010, when they sold a large basket of stocks worth approx. USD 1.6 Billion, when unwinding an index arbitrage position. During the closing auction on that day the KOSPI200 fell by approx. 2.7%. The equity traders had various other positions that resulted in a profit arising from the fall in the index. The FSS and the Korean prosecutors investigated the matter in 2011. A criminal indictment was filed against three ex-employees of DB Hong Kong and one employee of DSK and against DSK for vicarious criminal liability for the acts of its employee. The criminal trial commenced in Jan 2012 with a decision at the first trial level rendered on January 25, 2016. Appeals have been filed and are pending . While Korea is a jurisdiction that does not differentiate between a felony and misdemeanor, the eventual punishment rendered against DSK in Jan 2016, a fine over $1000, now makes it clear that this event falls under the definition of a felony as provided in the Form BD definitions. DSK was convicted on 1/25/2016. DSK was subject to a criminal fine of KRW 1.5 Billion (Approx. USD 1.25M) and forfeiture of illegal profits. The prosecutor has filed an appeal and DSK has filed a counter-appeal. There is no final due date set for the criminal fine due to the pending appeals. DB and DSK have already disgorged the profits on the trading activities to the prosecutors. DSK was convicted on 1/25/2016. DSK was subject to a criminal fine of KRW 1.5 Billion (Approx. USD 1.25M) and forfeiture of illegal profits. The prosecutor has filed an appeal and DSK has filed a counter-appeal. Y Deutsche Securities Korea. CO. (DSK), a Control Affiliate of the Registrant 2011 GOHAP 1120 01/25/2016 The Seoul Central District Court In reference to the "Title of Action" noted above, please see response to question 10(a)(1)(v.). In reference to the "Title of Action" noted above, please see response to questions 10(a)(1)(vi.). Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEC Auction Rate Securities Action 6/3/09 06/09/2009 U.S. District Court, Southern District of New York The Registrant has not been the subject of this matter: Initiation date 6/3/2009. The SEC's complaint alleged that Deutsche Bank Securities Inc. ("DBSI") misled its customers about the nature, liquidity and risks associated with Auction Rate Securities ("ARS") that DBSI underwrote, marketed and sold and that DBSI reinforced the perception that ARS were safe and liquid by committing its own capital to support ARS auctions for which it served as the lead manager to ensure that those auctions did not fail. Without admitting or denying the allegations in the SEC complaint, DBSI consented to the entry of an injunction permanently enjoining it from engaging in violations of Section 15(C) of the Securities Exchange Act of 1934. The SEC has granted waivers, exemptions, and no-action relief from the collateral consequences of the injunction in areas under the SEC's jurisdiction. In addition to the injunction noted above, the judgment of the District Court requires DBSI to comply with the undertakings specified in the judgment, and provides that DBSI may be required to pay civil monetary penalties pursuant to Section 21(D)(3) of the Exchange Act. The undertakings require, among other things, that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; agree not to liquidate its own inventory of a particular ARS without making that liquidity opportunity available, as soon as practicable, for eligible customers; and provide other relief as described in the judgment. Without admitting or denying the allegations in the SEC complaint, DBSI consented to the entry of an injunction permanently enjoining it from engaging in violations of Section 15(C) of the Securities Exchange Act of 1934. Y Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Interest-Rate Swaps 03/22/2011 Civil Division of the Federal Court of Justice of Germany Karlsruhe, Germany The Registrant has not been the subject of this matter: Initiation date: 2/5/2010. The Civil Division of the Federal Court of Justice of Germany found that Deutsche Bank AG ("DBAG") violated certain advisory duties in providing advice on entering into an interest rate swap agreement (CMS spread ladder swap contract) structured by the Bank but not disclosing a conflict of interest. Monetary Fine: 541,000 euros plus interest (after deducting interest payments received). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant TRIBUNALE ORDINARIO DI MILANO - SEZIONE SECONDA; 11622/16 REG. GEN. 11/08/2019 PROCURA DELLA REPUBBLICA PRESSO IL TRIBUNALE DI MILANO THE MILAN PUBLIC PROSECUTOR ALLEGED THAT DEUTSCHE BANK AG/DEUTSCHE BANK AG LONDON BRANCH ("DB AG") FAILED TO PROVIDE ADEQUATE MANAGEMENT AND SUPERVISION UNDER ITALIAN LEGISLATIVE DECREE 231 (NON-CRIMINAL LIABILITY) IN CONNECTION WITH ALLEGEDLY UNLAWFUL REPO TRANSACTIONS BETWEEN DB AG AND BANCA MONTE DEI PASCHI DI SIENA ("BMPS") AND ITS SUBSIDIARY SANTORINI. THE TRANSACTIONS WERE ALLEGEDLY INTENDED TO HIDE BMPS LOSSES BY ALLOWING BMPS TO ACCOUNT FOR THE TRADES AS A FINANCING ON AN ACCRUAL BASIS, AND PERMITTED SOME BMPS SENIOR MANAGEMENT TO DISSEMINATE FALSE INFORMATION TO THE MARKET THROUGH THE PUBLICATION OF PRESS RELEASES QUOTING FINANCIAL DATA EMERGING FROM CERTAIN BMPS FINANCIAL STATEMENTS. 11/8/19TRIBUNALE FOUND DBAG NON-CRIMINALLY LIABLE FOR FAILING TO PROVIDE ADEQ MGMT & SUPERVISION & SUBJECTED DBAG TO CONFISCATION OF 64.891MM EUROS IN PROFITS & FINED DBAG 3MM EUROS.THE PENALTIES/SENTENCES WILL ONLY BE EFFECTIVE AFTER CONCL OF ANY APPEALS DEUTSCHE BANK NATIONAL TRUST COMPANY, DEUTSCHE BANK TRUST COMPANY AMERICAS, & DEUTSCHE BANK TRUST COMPANY DELAWARE; CONTROL AFFILIATES OF REGISTRANT N/A 09/15/2020 U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA Description: THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ALLEGED THAT DEUTSCHE BANK NATIONAL TRUST COMPANY ("DBNTC"), SOLELY IN ITS CAPACITY AS LENDER TRUSTEE OF PEAKS TRUST 2009-1 ("PEAKS"), DEUTSCHE BANK TRUST COMPANY DELAWARE ("DBTCD"), SOLELY IN ITS CAPACITY AS OWNER TRUSTEE OF PEAKS, AND DEUTSCHE BANK TRUST COMPANY AMERICAS ("DBTCA"), SOLELY IN ITS CAPACITY AS INDENTURE TRUSTEE AND COLLATERAL AGENT OF PEAKS (TOGETHER WITH DBNTC AND DBTCD, THE "DB TRUSTEE ENTITIES"), PROVIDED SUBSTANTIAL ASSISTANCE TO ITT TECHNICAL INSTITUTE AND ITT EDUCATION SERVICES, INC. (COLLECTIVELY, "ITT") IN THEIR ABOVE-REFERENCED CAPACITIES RELATED TO PEAKS FROM JULY 2011 THROUGH THE DATE OF THE ORDER. IT IS ALLEGED THAT ITT ENGAGED IN UNFAIR, DECEPTIVE, OR ABUSIVE PRACTICES IN CONNECTION WITH ITS PRIVATE STUDENT LOAN PROGRAM. THE CFPB SETTLEMENT DID NOT INCLUDE ANY FINDINGS AGAINST OR ADMISSIONS OF LIABILITY BY THE DB TRUSTEE ENTITIES. AS A RESULT OF THE SETTLEMENT, PEAKS WILL BE TERMINATED AND THE PEAKS STUDENT LOANS WILL BE DISCHARGED. THE DB TRUSTEE ENTITIES HAVE ALSO ENTERED INTO ASSURANCES OF VOLUNTARY COMPLIANCE WITH THE ATTORNEYS GENERAL OF 47 STATES AND THE DISTRICT OF COLUMBIA UNDER SUBSTANTIALLY SIMILAR TERMS. CFPB STLMT HAD NO FINDINGS AGAINST/ADMISSIONS OF LIAB. BY DB TRUSTEE ENTITIES. PEAKS WILL BE TERMED & PEAKS STUDENT LOANS WILL BE DISCHRGD. DB TRUSTEE ENTITIES ENTERED INTO ASSURANCES OF VOLUNTARY COMPL W/ ATTY GEN OF 47 STATES & DC UNDER SIMILAR TERMS. DEUTSCHE BANK AG (DBAG), a Control Affiliate of the Registrant M 2021/60 03/10/2022 EUREX DEUTSCHLAND (EUREX) EUREX DEUTSCHLAND ("EUREX") FOUND THAT, FROM APRIL 2021 THROUGH JUNE 2021, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 126 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. 2/10/22, DBAG RECEIVED A DECISION FROM EUREX FINDING FROM 4/21-6/21 DBAG FAILED TO CONVERT SHORT CODES IN VIOLATION OF THE GERMAN STOCK EXCHANGE ACT & ARTICLE 25 OF REGULATION 600/2014, & ISSUING A REPRIMAND TO DBAG. THE DECISION BECAME FINAL ON 3/10/22. DEUTSCHE BANK AG (DBAG), a Control Affiliate of the Registrant H 53-2021 05/27/2022 FRANKFURT STOCK EXCHANGE ("FSE") THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM JUNE 2021 THROUGH OCTOBER 2021, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 366 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. 4/25/22, DB AG RECEIVED A DECISION FROM FSE FINDING DB AG FAILED TO CONVERT SHORT CODES INTO LONG CODES AS REQUIRED BY FSE RULES. FSE ISSUED A REPRIMAND TO DB AG, BUT NOT IMPOSING A FINE OR OTHER MONETARY SANCTION. DECISION BECAME FINAL ON 5/27/22. Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant United States Securities and Exchange Commission. 01/19/2017 File No. 3-12514 The Registrant has not been the subject of this matter: Amended filing date: 12/21/2006. On December 21, 2006 the SEC instituted and settled an administrative proceeding against Deutsche Bank Securities Inc. ("DBSI") in connection with DBSI's alleged failure to properly supervise one of its former registered representatives who had engaged in deceptive market timing of mutual fund shares in client accounts. The SEC further alleged that DBSI, through the conduct of the former registered representative, violated Rule 22C-1(A), as adopted under section 22(C) of the Investment Company Act of 1940 by the conduct of the former registered representative entering late trades for at least one customer. The SEC alleged that the former registered representative received and entered orders to purchase, redeem or exchange mutual fund shares for the 4:00 P.M. eastern time market close on certain occasions where customer orders received before 4:00 P.M. were blocked by fund companies as market timing trades. The customer orders entered into after 4:00 P.M. served as substitute orders for those that had been previously received and blocked before 4:00 P.M. The SEC also alleged that DBSI violated Section 15(B)(4)(E) of the Exchange Act because it allegedly failed to properly supervise the former registered representative who had engaged in the conduct. On December 21, 2006 the SEC also issued an order under Rule 602(E) of the Securities Act of 1933 on behalf of Deutsche Asset Management, Inc., Deutsche Investment Management Americas, Inc., and Deutsche Bank Securities Inc., granting a waiver of the disqualification provision of Rule 602(C)(3). Without admitting or denying the SEC's allegations or findings, DBSI agreed to total payment of $442,954, consisting of $202,835 in disgorgement, $202,835 in civil penalty, and $37,284 in prejudgment interest. The fine of $442,954 was paid on January 19, 2007. Without admitting or denying the SEC's allegations or findings, DBSI agreed to total payment of $442,954, consisting of $202,835 in disgorgement, $202,835 in civil penalty, and $37,284 in prejudgment interest. The fine was paid on January 19, 2007. Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management Inc. (DAMI), Control Affiliates of the Registrant Docket/Case Number: 3-12513 12/21/2006 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: Initiation date: 12/21/2006. Deutsche Investment Management Americas Inc. ("DIMA"), and Deutsche Asset Management, Inc. ("DAMI") which merged into DIMA as of 12/31/2006, serve as investment advisors to the DWS Scudder Funds. The SEC alleged DIMA and DAMI breached their fiduciary duty to certain DWS Scudder Funds by failing to effectively limit trading activity in DWS Scudder Funds. The SEC also alleged that DIMA and DAMI breached their fiduciary duty to certain DWS Scudder Funds by entering into market timing arrangements with investors. The SEC censured DIMA and DAMI and ordered DIMA and DAMI to pay $17.2 million in disgorgement, which will be deemed to be paid through payments made under a separate order by the New York Attorney General. The SEC also issued a cease and desist order against DIMA and DAMI. DIMA and DAMI are subject to certain undertakings regarding the conduct of its business in the future, including: formation of a code of ethics oversight committee to oversee all matters relating to issues arising under DIMA and DAMI's code of ethics; establishment of an internal compliance controls committee having overall compliance oversight responsibility of DIMA and DAMI; engagement of an independent compliance consultant to conduct a comprehensive review of the DIMA and DAMI's supervisory compliance and other policies and procedures designed to prevent and detect breaches of fiduciary duty, breaches of the code of ethics and Federal Securities Law violations by DIMA and DAMI and their employees; and within 120 days and in 2008, DIMA and DAMI shall undergo a compliance review by an independent third party. DIMA and DAMI were ordered to pay, jointly and severally, $17.2 million in disgorgement. The entire amount is to be distributed to the affected DWS Scudder Funds. DIMA and DAMI were ordered to pay, jointly and severally, $17.2 million in disgorgement. The entire amount is to be distributed to the affected DWS Scudder Funds. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 15-20 04/23/2015 U.S. Commodity Futures Trading Commission ("CFTC") The Registrant has not been the subject of this matter: Date Initiated: 4/23/2015. Deutsche Bank AG ("DBAG"), Deutsche Banks Securities Inc.'s ("DBSI's") Indirect Parent, agreed to settle charges of manipulation, attempted manipulation and false reporting relating to USD, GBP, JPY and CHF Libor and Euribor. Without admitting or denying the allegations, DBAG agreed to pay the fine of $800,000,000.00 which was paid on 5/1/15. DBAG was ordered to pay a fine of $800,000,000.00. The fine was paid on 5/1/15. DBAG was ordered to pay a fine of $800,000,000.00. The fine was paid on 5/1/15. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-17730 12/16/2016 Securities and Exchange Commission The Registrant has not been the subject of this matter: Date Initiated: 12/16/2016. The Order instituting Administrative and Cease-and-Desist Proceedings (the "Order") issued by the SEC against Deutsche Bank Securities Inc. ("DBSI") relates to one of DBSI's "Smart Order Routers" which routes primarily to dark pools. The Order alleged that a component of the Smart Order Router "was not fully operating" from January 2012 to February 2014 due to a "coding error". The Order also alleged certain deficiencies in DBSI's Form ATS filings. The disposition of the Action is final as of the Date of the Order, December 16, 2016. Monetary penalty of $18,500,000 was paid on December 19, 2016. The Order also requires DBSI to "Cease and Desist from committing or causing any violations and any future violations of Section 17(A)(2) of the Securities Act and Rule 301(B)(2) of Regulations ATS". The disposition of the Action is final as of the Date of the Order, December 16, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 3-19100 03/11/2019 SECURITIES AND EXCHANGE COMMISSION THE SEC ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE BETWEEN JANUARY 1, 2014 AND JUNE 11, 2018. THE SEC ALLEGED THAT DBSI RECEIVED 12B-1 FEES FROM THESE CLIENTS THAT IT WOULD NOT HAVE COLLECTED HAD SUCH CLIENTS BEEN INVESTED IN AVAILABLE LOWER-COST SHARE CLASSES. THE SEC ALSO ALLEGED THAT DBSI FAILED TO DISCLOSE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES DBSI, WITHOUT ADMITTING/DENYING, ENTERED INTO SETTLEMENT WITH THE SEC & AGREED TO: A CENSURE, CEASE & DESIST VIOLATING SECTIONS 206(2) & 207 OF ADVISERS ACT, PAY $2,971,462.85 IN DISGORGEMENT & INTEREST, & UNDERTAKINGS. DEUTSCHE BANK TRUST COMPANY AMERICAS (DBTCA), A CONTROL AFFILIATE OF THE REGISTRANT ADMINISTRATIVE PROCEEDING FILE NO. 3-19154 04/25/2019 SECURITIES AND EXCHANGE COMMISION WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, DBTCA CONSENTED TO THE ENTRY OF THE SEC'S ORDER. THE ORDER FOUND THAT DBTCA OMITTED TO DISCLOSE TO CLIENTS WHOSE ASSETS WERE ALLOCATED, IN PART, TO HEDGE FUNDS THAT DBTCA ONLY SELECTED FOR RECOMMENDATION HEDGE FUNDS THAT SHARED MANAGEMENT FEES, ALSO KNOWN AS RETROCESSIONS, WITH DBTCA. DBTCA DISCLOSED TO CLIENTS WHO INVESTED IN HEDGE FUNDS THE EXISTENCE AND AMOUNT OF THE RETROCESSION THAT DBTCA RECEIVED. WITHOUT ADMITTING/DENYING, DBTCA CONSENTED TO THE ENTRY OF A CEASE-AND-DESIST ORDER AND TO PAY CIVIL MONEY PENALTY OF $500,000, WHICH WAS PAID TO THE U.S. TREASURY ON MAY 8 2019. THE SEC ISSUED THE SETTLED ORDER FULLY RESOLVING THIS MATTER ON APR 25 2019. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant FILE NO. 3-19373 08/22/2019 SECURITIES AND EXCHANGE COMMISION THE SEC ALLEGED THAT DEUTSCHE BANK AG ("DBAG") PROVIDED EMPLOYMENT TO THE RELATIVES OF FOREIGN GOVERNMENT OFFICIALS AS A PERSONAL BENEFIT TO THOSE OFFICIALS IN ORDER TO INFLUENCE THEM TO ASSIST DBAG IN OBTAINING OR RETAINING BUSINESS OR OTHER BENEFITS BETWEEN 2006 AND 2014. THE SEC ALLEGED THAT DBAG'S 2010 ASIA-PACIFIC HIRING POLICY DID NOT APPLY TO ALL CATEGORIES OF HIRES AND WAS NOT EFFECTIVELY ENFORCED BY DBAG TO DETECT AND PREVENT ITS EMPLOYEES FROM OFFERING TEMPORARY EMPLOYMENT TO CANDIDATES REFERRED BY CURRENT OR POTENTIAL CLIENTS TO DETECT AND PREVENT CORRUPT HIRING PRACTICES. THE SEC ALLEGED THAT DBAG EMPLOYEES CREATED FALSE BOOKS AND RECORDS THAT CONCEALED THESE HIRING PRACTICES AND FAILED TO ACCURATELY DOCUMENT AND RECORD CERTAIN RELATED EXPENSES. THE SEC ALSO ALLEGED THAT DBAG FAILED TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNTING CONTROLS AROUND ITS HIRING PRACTICES SUFFICIENT TO PROVIDE REASONABLE ASSURANCES THAT ITS EMPLOYEES DID NOT VIOLATE ANTI-BRIBERY LAWS. DBAG, WITHOUT ADMITTING/DENYING, ENTERED INTO SETTLEMENT WITH THE SEC & AGREED TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PAY $16,178,850 IN DISGORGEMENT & INTEREST, & UNDERTAKINGS. Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 374988 02/25/1999 NASD The Registrant has not been the subject of this matter: The NASD alleged failure to DBSI to establish written supervisory procedures reasonably designed to achieve compliance with the SEC Quote Rule (violation of NASD Conduct Rule 2110) and failure to enforce its (DBSI) written supervisory procedures relating to books and records (violation of NASD Conduct Rule 3010). The current status is: closed on February 25, 1999. A fine of $7,500.00 has been paid. The current status is: closed on February 25, 1999. A fine of $7,500.00 has been paid. Deutsche Morgan Grenfell Inc. (DMGI), a Control Affiliate of the Registrant SEC Unknown 01/16/1992 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: The SEC alleged violation of Rule 15c of the Securities and Exchange Act of 1934 and 17 C.F.R. Part 404 with respect to certain records relating to its distribution of certain unsecured debt securities of one or more Government Sponsored Enterprises by DMGI. The current status is: closed on January 16, 1992. Without admitting to or denying the allegations or findings, DMGI consented to the entry of an Order Making Findings and imposing Sanctions with respect to certain records relating to its distribution of certain unsecured debt securities of one or more Government Sponsored Enterprises. Without admitting to or denying the allegations or findings, DMGI consented to the entry of an Order Making Findings and imposing Sanctions with respect to certain records relating to its distribution of certain unsecured debt securities. Deutsche Asset Management Inc. (DeAM Inc.), a Control Affiliate of the Registrant Admin. Proceeding File No. 3-11226 08/19/2003 United States Securities and Exchange Commission. The Registrant has not been the subject of this matter: On August 19, 2003, the Securities and Exchange Commission ("SEC") entered an administrative cease-and-desist order against Deutsche Asset Management Inc. ("DeAM Inc."), an investment adviser under common control with Registrant. The administrative proceeding was titled In the Matter of Deutsche Asset Management, Inc., Admin. Proceeding File No. 3-11226. Under the terms of the Order, the SEC made findings, without admission or denial by DeAM Inc., that DeAM Inc. violated Section 206(2) of the Investment Advisers Act of 1940 (the "Advisers Act") for voting client proxies in connection with a contested merger without first disclosing the circumstances of its investment banking affiliate's work on the proposed merger and the fact that this affiliate had intervened in the voting process. Based on these findings, the Order censured DeAM Inc., required that DeAM Inc. cease and desist from committing violations of Section 206(2) of the Advisers Act, and required that DeAM Inc. pay a civil money penalty in the amount of $750,000. The civil money penalty was paid on August 22, 2003. The SEC made findings, without admission or denial by DeAM Inc., censured DeAM Inc., required that DeAM Inc. cease and desist from committing certain violations and pay a civil money penalty in the amount of $750,000. DB Investment Managers, Inc. (DBIM), a Control Affiliate of the Registrant Docket/Case Number: 3-11927 05/23/2005 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: On three occasions from January 1, 2001 to May 31, 2004, DBIM sold securities within five business days before the pricing of three separate public offerings and then covered the sales (which were technically short sales) with securities purchased in the offerings, in alleged violation of rule 105 of Regulation M. These transactions occurred in three of the funds managed by DBIM. The funds made profits on these transactions that totaled $15,585. The current status is closed on 5/23/2005. The Securities and Exchange Commission ("SEC") administrative proceeding and order are final. The civil money penalty and the disgorgement and prejudgment interest will be paid. DBIM was ordered to cease and desist from committing or causing any violations and any future violations of Rule 105 of Regulation M, pay disgorgement and prejudgment interest and comply with certain undertakings. DBIM was ordered to comply with its undertakings to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of Regulation M, review those policies and procedures annually and require the chief compliance officer to administer these policies and procedures. These compliance measures have been instituted. Total amount of civil money penalty: $15,585. Total amount of disgorgement and prejudgment interest: $17,574. Portion of these amounts levied against DBIM: 100%. Date paid: within 30 days of the order. Portion of penalty waived: 0%. DBIM was ordered to cease and desist, pay disgorgement and prejudgment interest and comply with certain undertakings. Deutsche Investment Management Americas Inc. (DIMA) and others (see Description of the Action), Control Affiliates of the Registrant. Docket/Case Number: 34-54529. 09/28/2006 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: The SEC alleged that DIMA and DeAM failed to disclose potential conflicts of interest to the fund boards and to shareholders relating to Scudder Distributors, Inc.'s use of certain funds' brokerage commissions to reduce revenue sharing costs to broker-dealer firms with whom it had arrangements to market and distribute Scudder Fund shares. The SEC ordered DIMA, DeAM and Scudder Distributors Inc. ("SDI") to pay disgorgement, prejudgment interest, and a civil penalty in the amount of $19,329,729. DIMA, DeAM and SDI agreed to pay the fine and perform various undertakings. The current status is closed on 09/28/2006. DIMA, DeAM and SDI, were ordered to pay jointly and severally, disgorgement, prejudgment interest and civil penalties in the total amount of $19,329,729. $17,800,000 of the settlement is to be distributed to the funds listed in the SEC order based upon the amount of brokerage commissions from each fund used to satisfy revenue sharing agreements with broker-dealers who sold fund shares. The amount over $17,800,000 represents fines and penalties. DIMA, DeAM and SDI, undertook to make additional disclosures in the fund prospectuses and statements of information, adopt or modify relevant policies and procedures, and provide reporting to the fund boards. The current status is closed on 09/28/2006. DIMA, DeAM and SDI, were ordered to pay jointly and severally, disgorgement, prejudgment interest and civil penalties in the total amount of $19,329,729 and undertook certain matters. Scudder Kemper Investments, Inc. (Scudder Kemper), a Control Affiliate of the Registrant, and Gary P. Johnson Docket/Case Number: 3-10121 12/22/1999 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: Scudder Investments Service Company, formerly known as Kemper Service Company ("KSvC"); Scudder Distributors, Inc., formerly known as Kemper Distributors Inc. ("KDI"); Deutsche Investment Management Americas Inc., formerly, Scudder Kemper Investments, Inc. ("Scudder Kemper"): and Scudder Investor Services, Inc. are wholly owned, indirect and/or direct subsidiaries of Deutsche Bank Americas Holding Corp. On December 22, 1999, Scudder Kemper Investments, Inc. ("Scudder Kemper"), and Gary P. Johnson, the former head of the derivatives trading desk in Scudder Kemper's Boston office, consented to the filing of an administrative order by the Securities and Exchange Commission (the "Order"), without admitting or denying the findings contained in the Order. See In the Matter of Scudder Kemper Investments, Inc. and Gary Paul Johnson, Investment Advisers Act of 1940 Release No. 1848; Investment Company Act of 1940 Release No. 24218. The SEC alleged in the Order that the activities giving rise to the administrative proceeding arose from the actions of a former trader at Scudder Kemper's Boston derivatives trading desk, who violated applicable trading limits established by portfolio managers in certain institutional accounts, including registered investment companies, managed by Scudder Kemper during a period from July 1997 through October 9, 1998. The Order states that the trader concealed his activities by miscoding order tickets, forging portfolio manager signatures on order tickets and in many instances, by not submitting order tickets at all. On the date of the Order, the SEC also instituted administrative proceedings against Michael T. Sullivan, the former trader. Michael Sullivan, in settling the proceedings, was barred from association with any investment adviser and investment company for five years, with the right to reapply thereafter. Upon discovering the trader's misconduct, Scudder Kemper halted the trading program and cooperated fully with the SEC in its investigation of the misconduct. Scudder Kemper has reimbursed the losses in all affected accounts. Prior to the date of the Order, Scudder Kemper adopted enhanced supervisory controls and procedures to address the issues giving rise to the Order. The Order notes that the SEC considered the remedial acts promptly undertaken by Scudder Kemper and Gary Johnson and the cooperation afforded the SEC staff. The Order alleges that as a result of the trader's misconduct, losses of more than $16 million were incurred. The SEC alleged that Mr. Johnson and Scudder Kemper failed to supervise the trader and, through the trader's actions, failed accurately to maintain certain required books and records under the Investment Advisers Act of 1940 and the Investment Company Act of 1940. The Order suspended Mr. Johnson from association with the investment adviser for a period of three months, from acting in a supervisory capacity with any investment adviser for nine months and fined Mr. Johnson. The Order censured Scudder Kemper, ordered it to comply with certain provision of the Investment Advisers Act and the Investment Company Act, fined Scudder Kemper $250,000 and required Scudder Kemper to perform various undertakings. Without admitting or denying the findings, the Order censured Scudder Kemper, ordered it to comply with provision of the Investment Advisers Act and the Investment Company Act, fined it $250,000 and required Scudder Kemper to perform various undertakings. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-12514 01/19/2007 United States Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi). Deutsche Bank Trust Company Americas (DBTCA), a Control Affiliate of the Registrant Docket/Case Number: 3-12526 01/09/2007 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: Amended Filing Date: 01/09/2007. On January 9, 2007, Deutsche Bank Trust Company Americas ("DBTCA") settled an administrative action with the SEC. The action alleged that between January 2003 and June 2004, DBTCA and two other firms each failed to conduct auctions for auction rate securities according to procedures set forth in issuers' and broker-dealers' disclosure documents. Specifically, all three firms allegedly accepted new or revised bids after the submission deadline and allowed broker-dealers to submit bids to prevent failed auctions. DBTCA and another firm also allegedly allowed bids to prevent all-hold auctions. The SEC alleged that by engaging in these practices, the firms caused violations of Section 17(A)(2) of the Securities Act of 1933. Without admitting or denying the SEC's allegations, DBTCA and the other firms consented to the entry of an order which (1) requires each firm to cease and desist from committing or causing any violations and future violations of section 17(A)(2) of the Securities Act; (2) requires each firm to provide certain disclosures of its material and current auction practices and procedures; and (3) requires each firm, not later than six months after the date of order, to have its CEO or General Counsel certify that it has implemented procedures in accordance with the auction procedures disclosed in the disclosure documents and any supplemental disclosures related to auction rate securities area. In addition, the firms have undertaken to make payments which are based upon their relative market share and their conduct. DBTCA's payment will be $750,000. Without admitting or denying the SEC's allegations, DBTCA and the other firms consented to an order. In addition, the firms have undertaken to make payments which are based upon their relative market share and their conduct. DBTCA will pay $750,000. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: File No. 3-10957 12/03/2002 United States Securities and Exchange Commission The Registrant has not been the subject of this matter: The SEC alleged that DBSI failed to comply with certain aspects of the record-keeping requirements of Section 17(a) of the Exchange Act and Rule 17a-4 during the period from 1999 to (at least) 2001, in that it failed to preserve for three years, and/or to preserve in an accessible place for two years, all electronic mail communications (including interoffice memoranda) received and sent by its agents and employees that related to its business as a member of an exchange or as a broker or dealer. Resolution date: December 3, 2002. Within 90 days of the issuance of the order, unless otherwise extended by the staff of the Commission for good cause shown, DBSI undertook and agreed to inform the Commission in writing that it had completed its review and that it had established systems and procedures reasonably designed to achieve compliance with those laws, regulations, and rules concerning the preservation of electronic mail communications. DBSI pursuant to Section 21c of the Exchange Act was ordered to cease and desist from committing or causing any violations and any future violations of Section 17(a) and Rule 17a-4. In addition, DBSI paid a civil monetary penalty of $1,650,000.00 on December 11, 2002, in the manner and to the parties described in the final order. Without admitting or denying the findings of the SEC's administrative proceeding, DBSI consented to pay the fine and comply with the final order. DBSI was ordered to cease from committing or causing certain violations. Without admitting or denying the findings of the SEC's proceeding, DBSI paid a monetary penalty and agreed to inform the Commission in writing regarding certain actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CAF020064 11/22/2002 National Association of Securities Dealer, Inc. The Registrant has not been the subject of this matter: The NASD alleged that DBSI (A) failed to keep electronic communications for three years and/or failed to preserve electronic mail communications for the first two years, in an accessible place in violation of section 17(a) of the Exchange Act, Rule 17a-4 thereunder, and NASD Rule 3110, and (B) had inadequate supervisory systems and procedures that were not reasonably designed to achieve compliance with section 17 (a), Rule 17a-4 thereunder and NASD Rule 3110 in violation of NASD Rule 3010. Resolution date: November 22, 2002. DBSI undertook to review its procedures regarding the preservation of electronic mail communications for compliance with the federal securities laws and the rules of the NASD and the Exchange. Within 90 days of the issuance of the order, unless otherwise extended by the staff of the NASD for good cause shown, DBSI undertook and agreed to inform the NASD in writing that it had completed its review and that it had established systems and procedures reasonably designed to achieve compliance with those laws, regulations, and rules concerning the preservation of electronic mail communications. DBSI paid a civil monetary penalty of $1,650,000.00 on December 11, 2002, in the manner and to the parties described in the final order. Without admitting or denying to the allegations of the NASD's AWC, DBSI consented to the sanctions. DBSI paid a civil monetary penalty of $1,650,000.00 in the manner and to the parties described in the final order. Without admitting or denying to the allegations of the NASD's AWC, DBSI consented to the sanctions, and undertook certain actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 02-223 11/15/2002 New York Stock Exchange The Registrant has not been the subject of this matter: The NYSE alleged that DBSI violated Rule 440 and SEA section 17(a) and SEC Reg. 17a-4 by failing to preserve for a period of three years, and/or preserve in an accessible place for two years, electronic communications relating to the business of the firm and violated exchange Rule 342 by failing to reasonably supervise and control the activities of its employees to assure compliance with Exchange rules and Federal securities laws relating to retention of electronic communications. Resolution date: November 15, 2002. Within 90 days of the execution of the stipulation and consent, DBSI undertook and agreed to inform the Exchange in writing that it had completed its review and that it had systems and procedures in place reasonably designed to achieve compliance with those laws and rules concerning the preservation of electronic mail communications. The NYSE's Division of Enforcement maintained discretion, upon showing good cause, to extend the deadline for compliance with the undertaking. DBSI paid a fine of $1,650,000.00 on December 11, 2002, in the manner and to the parties described in the final order. Without admitting or denying the findings of the NYSE's Hearing Panel, DBSI consented to the penalty. DBSI paid a fine of $1,650,000.00 in the manner and to the parties described in the final order. Without admitting or denying the findings of the NYSE's Hearing Panel, DBSI consented to the penalty and undertook certain actions. Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management, Inc. (DAMI) Control Affiliates of the Registrant Docket/Case Number: 3-12513 12/21/2006 United States Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v) In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi) Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CFTC Docket No. 15-11 12/22/2014 Commodity Futures Trading Commission ("CFTC") The Registrant has not been the subject of this matter: Date Initiated: 12/22/2014. The CFTC alleged that Deutsche Bank Securities Inc. ("DBSI") violated CFTC Rule 1.25(B)(3)(I)(F) relating to concentration limits on the investment of customer funds, CFTC Rule 1.10(B)(1)(I) and (II) relating to the timely filing of accurate monthly focus reports and year-end financial statements, CFTC Rule 1.35(A)(1) and (B)(1) relating to the retention of order tickets for certain block trades, and CFTC Rule 166.3 relating to certain systems and controls relevant to the other alleged violations. On October 24, 2014, DBSI submitted an offer of settlement for $3,000,000,00 without admitting or denying the CFTC's allegations. The CFTC's accepted DBSI's offer of settlement effective December 22, 2014. DBSI paid the $3,000,000.00 on December 31, 2014. The CFTC accepted DBSI's offer of settlement effective December 22, 2014. DBSI paid the $3,000,000.00 on December 31, 2014. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 15-20 04/23/2015 U.S. Commodity Futures Trading Commission ("CFTC") In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v.). In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi.). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant SEC File No. 3-16557 05/26/2015 U.S. Securities and Exchange Commission ("SEC") The Registrant has not been the subject of this matter: Date Initiated: 5/26/2015. On May 26, 2015, the U.S. Securities and Exchange Commission ("SEC") issued a cease and desist order in a settled administrative proceeding against Deutsche Bank AG. The matter related to the manner in which DBAG valued "GAP Risk" associated with Certain Leveraged Super Senior ("LLS") synthetic CDO positions during Q4 2008 and Q1 2009, which was the height of the financial crisis. GAP Risk is the risk of loss that can result if the present value of a trade falls below the value of collateral for the trade posted by the counterparty. During the two quarters at issue, DBAG did not adjust its value of the LSS Trades to account for Gap Risk, essentially assigning a zero value for Gap Risk. The SEC found that although there was no standard industry model to value Gap Risk and the valuation of these instruments was complex, DBAG did not reasonably adjust the value of the LSS Trades for Gap Risk during these periods, resulting in misstatements of its financial statements for the two quarters at issue. The SEC also found that DBAG failed to maintain adequate systems and controls over the valuation process. The SEC found violations of Section 13(A) (Requirement to file accurate periodic reports with the SEC), 13(B)(2)(A) (Requirement to maintain accurate books and records), and 13(B)(2)(B) (Requirement to maintain reasonable internal accounting controls). DBAG paid a 55MN penalty and neither admitted nor denied the findings. Without admitting or denying the allegations, DBAG agreed to pay the fine of $55,000,000.00 which was paid on June 9, 2015. DBAG was ordered to pay a fine of $55,000,000.00. The fine was paid on June 9, 2015. DBAG was ordered to pay a fine of $55,000,000.00. The fine was paid on June 9, 2015. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 15-40 09/30/2015 Commodity Futures Trading Commission ("CFTC") The Registrant has not been the subject of this matter: Date Initiated: 9/30/2015. CFTC alleged that DBAG failed to properly report cancellations of SWAP transactions in all asset classes, which in the aggregate included between tens of thousands and hundreds of thousands of reporting violations and errors and omissions it its SWAP reporting. CFTC alleged that DBAG was aware of problems relating to its cancellation messages since its reporting obligations began on December 31, 2012, but failed to provide timely notice to its SDR and did not diligently investigate, address and remediate the problems until it was notified by the Division of Enforcements Investigation in June 2014. CFTC alleged that, because of DBAG's reporting failures, misinformation was disseminated to the market through the real time public tape and to the CFTC. CFTC alleged that DBAG's reporting failures resulted in part due to deficiencies with its SWAPS supervisory system. CFTC alleged that DBAG did not have an adequate system to supervise all activities related to Compliance with the SWAPS reporting requirements until at least sometime between April and July of 2014. DBAG agreed to pay a $2.5 million civil monetary penalty and comply with undertakings to improve its internal controls to ensure the accuracy and integrity of its SWAPS reporting. The fine was paid on October 5, 2015. DBAG agreed to pay a $2.5 million civil monetary penalty and comply with undertakings to improve its internal controls to ensure the accuracy and integrity of its SWAPS reporting. The fine was paid on October 5, 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding 3-17622 10/12/2016 U. S. Securities and Exchange Commission ("SEC") The Registrant has not been the subject of this matter: Date Initiated: 10/12/2016. The SEC alleged that between January 2012 through December 2014, Deutsche Bank Securities Inc. ("DBSI") failed to establish, maintain, and enforce policies and procedures reasonably designed to prevent its equity research analysts from misusing material, nonpublic information by, among other things, disclosing analysts' as yet unpublished views and analyses that appeared in subsequent DBSI research reports, certain changes of estimates by analysts, and short term trading recommendations that were inconsistent with the analysts' personally held views. Lastly, the SEC alleged that DBSI also failed to preserve, maintain, and timely produce to the SEC staff certain electronic communications that had been conducted on an internal DBSI messaging system. The SEC administrative order is final. The civil penalty was paid on October 18, 2016. The order imposes $9,500,000 of civil penalties. The portion levied against DBSI is 100%. Pursuant to the order the civil penalty was paid on October 18, 2016. The SEC administrative order is final. The civil penalty was paid on October 18, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-17730 12/16/2016 Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant CFTC Docket No. 18-06 01/29/2018 COMMODITY FUTURES TRADING COMMISSION ("CFTC") The registrant has not been the subject of this matter: Date Initiated: 01/29/2018. CFTC Docket No. 18-06. On January 29, 2018, Deutsche Bank, without admitting or denying the findings or conclusions therein, entered into a settlement with the CFTC. The CFTC approved the settlement in its order instituting proceedings pursuant to section 6(c) and (d) of the commodity exchange act, making findings and imposing remedial sanctions, including the following terms and conditions. Deutsche Bank agreed to pay a $30,000,000 civil monetary penalty, which was paid on February 2, 2018; to cease and desist from violating certain provisions of the CEA and CFTC regulations related to manipulation, spoofing, and supervision; and to comply with undertakings regarding, among other things, maintaining systems and controls reasonably designed to detect spoofing activity, and maintaining training of certain Deutsche Bank employees addressing spoofing, manipulation, and attempted manipulation. The firm was fined $30,000,000.00. without admitting or denying the allegations, DBAG and DBSI (together "Deutsche Bank") agreed to: (i) pay a $30,000,000 civil monetary penalty, assessed jointly and severally, which was paid on February 2, 2018; (ii) cease and desist from violating certain provisions of the Commodity Exchange Act ("CEA") and CFTC Regulations related to manipulation, spoofing, and supervision; and (iii) comply with undertakings regarding, among other things, maintaining systems and controls reasonably designed to detect spoofing activity, and maintaining training of certain deutsche bank employees addressing spoofing, manipulation, and attempted manipulation. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CFTC Docket No. 18-09 02/01/2018 COMMODITY FUTURES TRADING COMMISSION ("CFTC") The registrant has not been the subject of this matter: Date Initiated: 02/01/2018. Docket/Case number: CFTC Docket No. 18-09. the CFTC alleged that Deutsche Bank Securities Inc. ("DBSI"), by and through the acts of certain of its traders, attempted to manipulate the USD ISADAFIX benchmark rate from January 2007 through May 2012 by making false submissions to a U.S.-based unit of a leading interest rate swaps brokerage firm (the "swaps broker"), skewing the rates and spreads in the direction that could have moved the USD ISDAFIX setting to benefit DBSI's trading positions as well as by bidding, offering, and executing transactions in targeted interest rate products, including swap spreads and U.S. treasuries, at or near the critical 11:00 a.m. fixing time, with the intent to affect the reference rates and spreads captured by the swaps broker that the swaps broker disseminated to submitting banks, and thereby to affect the published USD ISDAFIX. On February 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with the CFTC. The CFTC approved the settlement in its order instituting proceedings pursuant to section 6(c) and (d) of the commodity exchange act, making findings, and imposing remedial sanctions ("order"), including the following terms and conditions. DBSI agreed to pay a $70,000,000 civil monetary penalty, which was paid on February 8, 2018; to cease and desist from violating certain provisions of the CEA and CFTC regulations related to attempted manipulation and false reporting; and to comply with undertakings regarding, among other things, maintaining systems and controls reasonably designed to detect improper communications and potentially manipulative conduct concerning interest-rate swap benchmarks, training and monitoring certain DBSI employees who are involved in the fixing of any benchmark based on interest-rate swaps, providing a report to the CFTC within 120 days of the date of entry 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 following the date of entry of the order, explaining how it has complied with the undertakings set forth in the order. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-18367 02/12/2018 UNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC") The Registrant has not been the subject of this matter: Date Initiated: 02/12/2018. Docket/Case Number: File No. 3-18367. on February 12, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with the sec. the sec approved the order instituting administrative proceedings, pursuant to section 15(b) of the exchange act of 1934, making findings, and imposing remedial sanctions, including the following terms and conditions. DBSI agreed to a censure; to pay a $750,000 civil monetary penalty, which was paid on February 16, 2018; to make remediation payments to customers in the aggregate amount of $3,729,743, which amount will be paid in accordance with the settlement with the sec; and to comply with certain undertakings regarding the process for making such remediation payments. on February 12, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with the sec. the sec approved the order instituting administrative proceedings, pursuant to section 15(b) of the exchange act of 1934, making findings, and imposing remedial sanctions, including the following terms and conditions. DBSI agreed to a censure; to pay a $750,000 civil monetary penalty, which was paid on February 16, 2018; to make remediation payments to customers in the aggregate amount of $3,729,743, which amount will be paid in accordance with the settlement with the sec; and to comply with certain undertakings regarding the process for making such remediation payments. without admitting or denying the allegations, DBSI agreed to: (i) a censure; (ii) pay a $750,000 civil monetary penalty, which was paid on February 16, 2018; (iii) make remediation payments to customers in the aggregate amount of $3,729,743, which amount will be paid in accordance with the settlement with the sec; and (iv) comply with certain undertakings regarding the process for making such remediation payments. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-18606 07/20/2018 United States Securities and Exchange Commission ("SEC") The SEC alleged that Deutsche Bank Securities, Inc. ("DBSI") failed to reasonably supervise its associated persons on its securities lending desk to prevent and detect violations of the antifraud provisions of the federal securities laws in connection with DBSI's securities lending transactions involving pre-released American Depositary Receipts ("ADRs") between April 2012 and June 2015. The SEC alleged that during this period DBSI's associated persons on its securities lending desk failed to take reasonable steps to ensure that DBSI did not receive ADRs from pre-release brokers who had not complied with their pre-release obligations requiring that they or their customers beneficially own the corresponding ordinary shares throughout the pendency of the pre-release transaction. The SEC alleged that DBSI failed to establish and implement supervisory policies and procedures that would be reasonably expected to prevent and detect the borrowing or lending of such ADRs. On July 20, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with the SEC. The SEC approved the settlement in its order instituting administrative proceedings, pursuant to Section 15(b)(4) of the Securities Exchange Act of 1934, making findings, and imposing remedial sanctions, including the following terms and conditions. DBSI agreed to a censure; to pay a $497,753.30 civil monetary penalty, which was paid on July 24, 2018, and to pay disgorgement of $995,506.60 and prejudgment interest of $155,006.02, which were paid on July 24, 2018. See above Deutsche Bank Trust Company Americas (DBTCA) File No. 3-18605 07/20/2018 United States Securities and Exchange Commission ("SEC") The SEC alleged that Deutsche Bank Trust Company Americas ("DBTCA") violated section 17(a)(3) of the Securities Act of 1933 ("Securities Act") with respect to the issuance of pre-released American Depositary Receipts ("ADRs"). the SEC alleged that, between June 2011 and September 2016, DBTCA at times pre-released ADRs to pre-release brokers in circumstances where DBTCA did not act reasonably in light of certain indications that pre-release brokers may not have been complying with their obligation that they or their counterparties actually beneficially own the corresponding number of ordinary shares, as they represented to DBTCA in their pre-release agreements. As a result of this conduct, the SEC alleged that DBTCA issued ADRs that in many instances were not backed by ordinary shares as required by the ADR facility. On July 20, 2018, DBTCA, without admitting or denying the findings or conclusions therein, entered into a settlement with the sec. the sec approved the order instituting cease-and-desist proceedings, pursuant to section 8a of the securities act of 1933, making findings, and imposing remedial sanctions and a cease-and-desist order, including the following terms and conditions. DBTCA agreed to pay a $22,229,000.54 civil monetary penalty, which was paid on July 24, 2018; to pay disgorgement of $44,458,001.08 and prejudgment interest of $6,597,826.59, which was paid on July 24, 2018; and to cease and desist from violating Section 17(a)(3) of the Securities Act. See above. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 3-19100 03/11/2019 SECURITIES AND EXCHANGE COMMISSION THE SEC ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE BETWEEN JANUARY 1, 2014 AND JUNE 11, 2018. THE SEC ALLEGED THAT DBSI RECEIVED 12B-1 FEES FROM THESE CLIENTS THAT IT WOULD NOT HAVE COLLECTED HAD SUCH CLIENTS BEEN INVESTED IN AVAILABLE LOWER-COST SHARE CLASSES. THE SEC ALSO ALLEGED THAT DBSI FAILED TO DISCLOSE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES DBSI, WITHOUT ADMITTING/DENYING, ENTERED INTO SETTLEMENT WITH THE SEC & AGREED TO: A CENSURE, CEASE & DESIST VIOLATING SECTIONS 206(2) & 207 OF ADVISERS ACT, PAY $2,971,462.85 IN DISGORGEMENT & INTEREST, & UNDERTAKINGS. DEUTSCHE BANK TRUST COMPANY AMERICAS (DBTCA), A CONTROL AFFILIATE OF THE REGISTRANT ADMINISTRATIVE PROCEEDING FILE NO. 3-19154 04/25/2019 SECURITIES AND EXCHANGE COMMISION WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS, DBTCA CONSENTED TO THE ENTRY OF THE SEC'S ORDER. THE ORDER FOUND THAT DBTCA OMITTED TO DISCLOSE TO CLIENTS WHOSE ASSETS WERE ALLOCATED, IN PART, TO HEDGE FUNDS THAT DBTCA ONLY SELECTED FOR RECOMMENDATION HEDGE FUNDS THAT SHARED MANAGEMENT FEES, ALSO KNOWN AS RETROCESSIONS, WITH DBTCA. DBTCA DISCLOSED TO CLIENTS WHO INVESTED IN HEDGE FUNDS THE EXISTENCE AND AMOUNT OF THE RETROCESSION THAT DBTCA RECEIVED. WITHOUT ADMITTING/DENYING, DBTCA CONSENTED TO THE ENTRY OF A CEASE-AND-DESIST ORDER AND TO PAY CIVIL MONEY PENALTY OF $500,000, WHICH WAS PAID TO THE U.S. TREASURY ON MAY 8 2019. THE SEC ISSUED THE SETTLED ORDER FULLY RESOLVING THIS MATTER ON APR 25 2019. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant FILE NO. 3-19373 08/22/2019 SECURITIES AND EXCHANGE COMMISION THE SEC ALLEGED THAT DEUTSCHE BANK AG ("DBAG") PROVIDED EMPLOYMENT TO THE RELATIVES OF FOREIGN GOVERNMENT OFFICIALS AS A PERSONAL BENEFIT TO THOSE OFFICIALS IN ORDER TO INFLUENCE THEM TO ASSIST DBAG IN OBTAINING OR RETAINING BUSINESS OR OTHER BENEFITS BETWEEN 2006 AND 2014. THE SEC ALLEGED THAT DBAG'S 2010 ASIA-PACIFIC HIRING POLICY DID NOT APPLY TO ALL CATEGORIES OF HIRES AND WAS NOT EFFECTIVELY ENFORCED BY DBAG TO DETECT AND PREVENT ITS EMPLOYEES FROM OFFERING TEMPORARY EMPLOYMENT TO CANDIDATES REFERRED BY CURRENT OR POTENTIAL CLIENTS TO DETECT AND PREVENT CORRUPT HIRING PRACTICES. THE SEC ALLEGED THAT DBAG EMPLOYEES CREATED FALSE BOOKS AND RECORDS THAT CONCEALED THESE HIRING PRACTICES AND FAILED TO ACCURATELY DOCUMENT AND RECORD CERTAIN RELATED EXPENSES. THE SEC ALSO ALLEGED THAT DBAG FAILED TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNTING CONTROLS AROUND ITS HIRING PRACTICES SUFFICIENT TO PROVIDE REASONABLE ASSURANCES THAT ITS EMPLOYEES DID NOT VIOLATE ANTI-BRIBERY LAWS. DBAG, WITHOUT ADMITTING/DENYING, ENTERED INTO SETTLEMENT WITH THE SEC & AGREED TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PAY $16,178,850 IN DISGORGEMENT & INTEREST, & UNDERTAKINGS. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2016050808901 11/08/2019 THE NASDAQ STOCK MARKET LLC WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DEUTSCHE BANK SECURITIES INC. ("DBSI") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT WHILE ACTING AS A DISTRIBUTION PARTICIPANT IT EXECUTED TRANSACTIONS IN A COVERED SECURITY DURING THE RESTRICTED PERIOD OF MARCH 30, 2016, IN VIOLATION OF RULE 101 OF REGULATION M ("RULE 101") PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT DURING THE PERIOD JANUARY 1, 2016 THROUGH MARCH 31, 2016, DBSI'S SUPERVISORY SYSTEM, INCLUDING ITS WRITTEN SUPERVISORY PROCEDURES, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 101, IN VIOLATION OF NASDAQ RULES 3010 AND 2010A. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI CONSENTED TO THE AWC AND TO PAY A FINE IN THE AMOUNT OF $2,500.00 Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CFTC DOCKET NO. 20-17 06/18/2020 COMMODITY FUTURES TRADING COMMISSION ("CFTC") THE CFTC ALLEGES THAT AT VARIOUS TIMES BETWEEN JANUARY AND DECEMBER 2013, BY AND THROUGH THE ACTS OF TWO TOKYO-BASED TRADERS, ONE IN U.S. TREASURIES AND ONE IN U.S. TREASURIES AND EURODOLLARS, DEUTSCHE BANK SECURITIES INC. ("DBSI") ENGAGED IN THE PRACTICE OF "SPOOFING" (BIDDING OR OFFERING WITH THE INTENT TO CANCEL THE BID OR OFFER BEFORE EXECUTION). ON JUNE 18, 2020, DBSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI AGREED TO CEASE AND DESIST FROM VIOLATING SECTION 4C(A)(5)(C) OF THE COMMODITY EXCHANGE ACT, AND PAY A CIVIL MONEY PENALTY OF $1,250,000, WHICH WAS TIMELY PAID ON JUNE 23, 2020. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant FILE NO. 3-20200 01/08/2021 UNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC") THE SEC ALLEGED THAT DEUTSCHE BANK AG ("DBAG") IMPROPERLY USED THIRD-PARTY INTERMEDIARIES, BUSINESS DEVELOPMENT CONSULTANTS (BDCS), AND FINDERS TO OBTAIN AND RETAIN GLOBAL BUSINESS FROM AT LEAST 2009 THROUGH 2016. THE SEC ALLEGED THAT DBAG LACKED SUFFICIENT INTERNAL ACCOUNTING CONTROLS RELATED TO THE USE AND PAYMENT OF BDCS DURING THE RELEVANT TIME PERIOD AND FAILED TO TAKE SUFFICIENT STEPS TO ADDRESS AND REMEDIATE KNOWN INTERNAL ACCOUNTING CONTROL FAILURES UNTIL 2016. THE SEC ALSO ALLEGED THAT PAYMENTS WERE INACCURATELY RECORDED AS LEGITIMATE BUSINESS EXPENSES IN DBAG'S BOOKS AND RECORDS, AND INVOLVED FALSIFIED INVOICES AND DOCUMENTATION. 1/8/21, SEC ENTERED AN ORDER REQUIRING DBAG TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT AND TO PAY DISGORGEMENT OF $35,145,619 & PREJUDGMENT INTEREST OF $8,184,003, PAID TIMELY ON 1/14/21. N Y Scudder Kemper Investments, Inc. (Scudder Kemper), a Control Affiliate of the Registrant, and Gary P. Johnson Docket/Case Number: 3-10121 12/22/1999 United States Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 3-12514 01/19/2007 United States Securities and Exchange Commission In reference the "Title of Action" noted above, please see response to question 10(c)(1)(v). In reference the "Title of Action" noted above, please see response to question 10(c)(1)(vi). Deutsche Bank Trust Company Americas (DBTCA), a Control Affiliate of the Registrant Docket/Case Number: 3-12526 01/09/2007 United States Securities and Exchange Commission In reference the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management, Inc. (DAMI) Control Affiliates of the Registrant Docket/Case Number: 3-12513 12/21/2006 United States Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v) In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi) Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CFTC Docket No. 15-11 12/22/2014 Commodity Futures Trading Commission ("CFTC") In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant SEC File No. 3-16557 05/26/2015 U.S. Securities and Exchange Commission ("SEC") In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 15-40 09/30/2015 Commodity Futures Trading Commission ("CFTC") In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank Securities Inc. (DBSI), a Controlled Affiliate of the Registrant Administrative Proceeding 3-17622 10/12/2016 U.S. Securities and Exchange Commission ("SEC") In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank Securities Inc. (DBSI), a Controlled Affiliate of the Registrant File No. 3-17730 12/16/2016 Securites and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(1)(vi). Y Bankers Trust Company NKA Deutsche Bank Trust Company Americas, a Control Affiliate of the Registrant 99 CR250JGK (S.D.N.Y., 1999) 03/11/1999 United States Attorney's Office in the Southern District of New York In reference to the "Title of Action" noted above, please see response to question 10(a)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(a)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1219988 08/31/2004 The California Department of Corporations The Registrant has not been the subject of this matter: The California Department of Corporations charged violations of Corporations Code Section 25218 and Title 10 of the Code of Regulations Section 260.218 for allegedly not adequately insulating research analysts from the influences of covered companies and investment banking; violations of Corporations Code Sections 25212(G) and 25218 and Title 10 of the California Code of Regulations Section 260.218.4 for allegedly not properly supervising its employees to prevent such influences; and violations of California Corporations Code Section 25241 and Section 260.241.1(B) of Title 10 of the California Code of Regulations for allegedly not promptly producing e-mail data. The current status is closed on August 31, 2004. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the California Department of Corporations, and to pay $87.5 million. The administrative consent order included undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings (including $3,001,328 paid to California on August 26, 2004); (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. Without admitting or denying the allegations, DBSI agreed to an administrative consent order (which included certain undertakings) with the California Dept. of Corps. and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: CO-2005-0011 03/31/2005 The Alabama Securities Commission The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Alabama Securities Commission charged violations of Alabama Securities Act 830-X-3-.13(1) & (3) for allegedly failing to establish and maintain adequate policies, systems and procedures for supervision and control of its employees; violations of Alabama Securities Act 8-6-3(I)7 for allegedly (I) failing to manage conflicts in an adequate or appropriate manner and (II) failing to make adequate disclosure; violations of Alabama Securities Act 830-X-2-.06(2) for allegedly issuing research reports that were not properly balanced, and/or contained exaggerated or unwarranted claims and opinions. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Alabama Securities Commission and to pay $87.5 million. The Alabama Securities Commission charged violations of Alabama Securities Act 830-X-3-.13(1) & (3) for allegedly failing to establish and maintain adequate policies, systems and procedures for supervision and control of the research and investment banking departments; violations of Alabama Securities Act 8-6-3(I)7 for allegedly (I) failing to manage conflicts in an adequate or appropriate manner and (II) failing to make adequate disclosure; violations of Alabama Securities Act 830-X-2-.06(2) for allegedly issuing research reports that were not based on principles of fair dealing and good faith, did not provide sound basis for evaluating facts, were not properly balanced, and/or contained exaggerated or unwarranted claims and opinions. The matter was resolved on 03/31/2005, including a $394,052 penalty paid to Alabama on 03/29/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Alabama Securities Commission and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: S-03578A-05-0000 03/01/2005 The Arizona Corporation Commission The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Arizona Corporation Commission charged violations of Arizona revised Statute 44-1961(A)(13) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an order to cease and desist, an order for administrative penalties and consent to same with the Arizona Corporation Commission, and to pay $87.5 million. The Arizona Corporation Commission charged violations of Arizona revised Statute 44-1961(A)(13) in connection with research analyst work, supervision and production of emails. The matter was resolved on 02/25/2005, including $454,619 penalty paid to the State of Arizona on 03/01/2005. Without admitting or denying the allegations, DBSI agreed to an order to cease and desist, an order for admin. penalties and consent to same with the Arizona Corp. Comm., and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : EN-10522 03/28/2005 The Commissioner of Securities of the State of Georgia The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Commissioner of Securities of the State of Georgia charged violations of O.C.G.A. 10-5-4 (A) (8) and 10-5-12(A)(1) and Rule and Regulation of the State of Georgia 590-4-2-.14 in connection with research analyst work, supervision and production of emails; violations of 10-5-4 (A)(11) and 10-5-12(A)(1) and Rule 590-4-2-.07 for allegedly failing to establish and maintain adequate policies, systems, and procedures for supervision and control of the research and investment banking departments. Without admitting or denying the allegations, DBSI agreed to a consent order with the Commissioner of Securities of the State of Georgia. The Commissioner of Securities of the State of Georgia charged violations of O.C.G.A. 10-5-4 (A) (8) and 10-5-12(A)(1) and Rule and Regulation of the State of Georgia 590-4-2-.14 in connection with research analyst work, supervision and production of emails; violations of 10-5-4 (A)(11) and 10-5-12(A)(1) and Rule 590-4-2-.07 for allegedly failing to establish and maintain adequate policies, systems, and procedures for supervision and control of the research and investment banking departments. The matter was resolved on 03/28/2005, including $394,052 penalty paid to the State of Georgia on 03/25/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Commissioner of Securities of the State of Georgia and a $394,052 penalty paid to the State of Georgia. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003E052 03/28/2005 The Kansas Office of the Securities Commissioner The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Kansas Office of the Securities Commissioner charged violations of K.S.A. 17-1254(M)(7), K.S.A. 17-1254(M)(12) and K.A.R. 81-3-1(D)(3) in connection with research work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a consent order with Kansas Office of the Securities Commissioner and pay $87.5 million. The Kansas Office of the Securities Commission charged violations of K.S.A. 17-1254(M)(7), K.S.A. 17-1254(M)(12) and K.A.R. 81-3-1(D)(3) in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/28/2005, including $287,500 penalty paid to the State of Kansas. Without admitting or denying the allegations, DBSI agreed to a consent order with Kansas Office of the Securities Commissioner and pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250895 03/15/2005 The Kentucky Office of Financial Institutions The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Kentucky Office of Financial Institutions charged violations of Kentucky revised statutes 292.530, 292.330(13)(A)7 and 292.330(A)9A in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Kentucky office of Financial Institutions and to pay $87.5 million. The Kentucky Office of Financial Institutions charged violations of Kentucky revised statutes 292.530, 292.330(13)(A)7 and 292.330(A)9.A in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/15/2005, including $358,136 penalty paid to the State of Kentucky on 03/28/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Kentucky Office of Financial Institutions and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-045-CON 03/16/2005 The Maine Office of Securities The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Maine Office of Securities charged violations of 10313(1)(G), 10313(1)(J) and 10313(6) of revised Maine Securities Act in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a consent order with the Maine Office of Securities and to pay $87.5 million. The Maine Office of Securities charged violations of 10313(1)(G), 10313(1)(J) and 10313(6) of revised Maine Securities Act in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/16/2005, including $287,500 penalty paid to the State of Maine. Without admitting or denying the allegations, DBSI agreed to a consent order with the Maine Office of Securities and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250903 04/01/2005 The Minnesota Department of Commerce The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Minnesota Department of Commerce charged violations of Minn. Stat. 80A.07, Subd. 1(7) and (10) (2004) and Minn. R. Ch. 2875.0910 (2003) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a consent order with the Minnesota Department of Commerce and to pay $87.5 million. The Minnesota Department of Commerce charged violations of Minn. Stat. 80A.07, Subd. 1(7) and (10) (2004) and Minn. R. Ch. 2875.0910 (2003) in connection with research analyst work, supervision and production of emails. The matter was resolved on 04/01/2005, including $435,909 penalty paid to the State of Minnesota. Without admitting or denying the allegations, DBSI agreed to a consent order with the Minnesota Department of Commerce and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250878 02/17/2005 The Nebraska Department of Banking and Finance The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Nebraska Department of Banking and Finance charged violations of Nebraska revised Statutes 8-1103(9)(A)(VII) for allegedly failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking; violations of Nebraska revised statutes 8-1103(9)(A)(XI) for allegedly failing to reasonably supervise its agents or employees; and violations of Nebraska revised statutes 8-1103(7)(A) and 48 NAC 4.010 for allegedly failing to preserve for a period of three years, and/or preserve in an accessible place for two years, certain books and records relating to its business. Without admitting or denying the allegations, DBSI agreed to a consent order with the Nebraska Department of Banking and Finance and to pay $87.5 million. The Nebraska Department of Banking and Finance charged violations of Nebraska revised Statutes 8-1103(9)(A)(VII) for allegedly failing to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking; violations of Nebraska revised statutes 8-1103(9)(A)(XI) for allegedly failing to reasonably supervise its agents or employees; and violations of Nebraska revised statutes 8-1103(7)(A) and 48 NAC 4.010 for allegedly failing to preserve for a period of three years, and/or preserve in an accessible place for two years, certain books and records relating to its business. The matter was resolved on 02/17/2005, including $287,500 penalty paid to the state of Nebraska on 03/04/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Nebraska Department of Banking and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 04-050-IG 03/31/2005 The North Carolina Department of the Secretary of State, Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The North Carolina Department of the Secretary of State, Securities Division charged violations of N.C.G.S. 78A-39(A)(2)(G) within the meaning of 18 NCAC 06.1414(A) and 18 NCAC 06.1414(B)(33) for allegedly failing to ensure that analysts who issued research were adequately insulated; violations of N.C.G.S. 78A-39(A)(2)(G)within the meaning of 18 NCAC 06.1414(A) and 18 NCAC 06.1414(B)(33) for allegedly failing to reasonably supervise its employees; violations of N.C.G.S. 78A-38 for allegedly breaching its obligation to comply with a reasonable regulatory request for documents. Without admitting or denying the allegations, DBSI agreed to a consent order with the North Carolina Department of the Secretary of State, Securities Division and to pay $87.5 million. The North Carolina Department of the Secretary of State, Securities Division charged violations of N.C.G.S. 78A-39(A)(2)(G) within the meaning of 18 NCAC 06.1414(A) and 18 NCAC 06.1414(B)(33) for allegedly failing to ensure that analysts who issued research were adequately insulated; violations of N.C.G.S. 78A-39(A)(2)(G)within the meaning of 18 NCAC 06.1414(A) and 18 NCAC 06.1414(B)(33) for allegedly failing to reasonably supervise its employees; violations of N.C.G.S. 78A-38 for allegedly breaching its obligation to comply with a reasonable regulatory request for documents. The matter was resolved on 03/31/2005, including $713,240 penalty paid to the State of North Carolina on 03/23/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the North Carolina Department of the Secretary of State and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250894 03/24/2005 The Ohio Department of Commerce, Division of Securities The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Ohio Department of Commerce, Division of Securities charged violations of Ohio revised code Chapter 1707 and the rules promulgated thereunder in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a settlement agreement with the Ohio Department of Commerce, Division of Securities and to pay $87.5 million. The Ohio Department of Commerce, Division of Securities charged violations of Ohio revised code Chapter 1707 and the rules promulgated thereunder in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/24/2005, including $1,005,988 penalty paid to the state of Ohio on 03/10/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Oregon Dept. of Cons. and Bus. Services, Div. of Fin. and Corp. Securities and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-05-0003 03/17/2005 The Oregon Department of Consumer and Business Services, Division of Finance The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Oregon Department of Consumer and Business Services, Division of Finance and Corporate Securities charged violations of ORS 59.135, ORS 59.195, ORS 59.205 and OAR Chapter 441, Division 205 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Oregon Department of Consumer and Business Services, Division of Finance and Corporate Securities and to pay $87.5 million. The Oregon Department of Consumer and Business Services, Division of Finance and Corporate Securities charged violations of ORS 59.135, ORS 59.195, ORS 59.205 and OAR Chapter 441, Division 205 in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/17/2005, including $303,166 penalty paid to the State of Oregon on 03/02/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Oregon Dept. of Cons. and Bus. Services, Div. of Fin. and Corp. Securities and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003-04-50 02/23/2005 Pennsylvania Securities Commission The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. Pennsylvania accepted applicant's offer of settlement in connection with the Pennsylvania Securities Commission's charge that if, in a contested proceeding under the Pennsylvania Securities Act of 1972 (70 P.S.1-510), it was proven that applicant engaged in conduct related to research analyst work, supervision and production of emails as alleged in the SEC complaint, there would be a basis under section 305(A)(IX), 70 P.S.1-305(A)(IX), for the Pennsylvania Securities Commission to suspend, revoke or condition the broker-dealer registration of applicant in the Commonwealth of Pennsylvania. Without admitting or denying the allegations, DBSI agreed to an order with the Pennsylvania Securities Commission and to pay $87.5 million. Pennsylvania accepted applicant's offer of settlement in connection with the Pennsylvania Securities Commission's charge that if, in a contested proceeding under the Pennsylvania Securities Act of 1972 (70 P.S.1-510), it was proven that applicant engaged in conduct related to research analyst work, supervision and production of emails as alleged in the SEC complaint (filed on or about 8/26/2004 by the U.S. Securities and Exchange Commission in the United States District Court for the Southern District of New York), there would be a basis under Section 305(A)(IX), 70 P.S.1-305(A)(IX), for the Pennsylvania Securities Commission to suspend, revoke or condition the broker-dealer registration of applicant in the Commonwealth of Pennsylvania. The matter was resolved on 02/23/2005, including $1,088,210 penalty paid to the State of Pennsylvania on 03/11/2005. Without admitting or denying the allegations, DBSI agreed to an order with the Pennsylvania Securities Commission and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-94 03/22/2005 The Rhode Island Department of Business Regulation, Securities Division` The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Rhode Island Department of Business Regulation, Securities Division charged violations of the Rhode Island Uniform Securities Act of 1990 7-212(B)(8), 7-11-212(B)(11), and 7-11-209(D)(1) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Rhode Island Department of Business Regulation, Securities Division and to pay $87.5 million. The Rhode Island Department of Business Regulation, Securities Division charged violations of the Rhode Island Uniform Securities Act of 1990 7-212(B)(8), 7-11-212(B)(11), and 7-11-209(D)(1) in connection with research analyst work, supervision and production of emails. The matter was resolved on 03/22/2005, including $287,500 penalty paid to the State of Rhode Island on 03/16/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Rhode Island Department of Business Regulation, Securities Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 5-004-S 03/05/2005 The Vermont Department of Banking, Insurance, Securities and Health Care The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Vermont Department of Banking, Insurance, Securities and Health Care Administration charged DBSI with violations of 9 V.S.A. 131 4221A(A)(8) for allegedly (I) permitting its investment banking department to exert improper influence over its research analysts, (II) issuing research that contained opinions that lacked a reasonable basis and/or contained exaggerated or unwarranted claims, and (III) failing to promptly produce required books and records; violations of 9 V.S.A. 131 4221A(A)(11) for allegedly failing to (I) reasonably supervise its employees to ensure that its research analysts were adequately insulated from pressures and influences from covered companies and investment banking and (II) establish, maintain and enforce written supervisory procedures. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Vermont Department of Banking, Insurance, Securities and Health Care Administration and to pay $87.5 million. The Vermont Department of Banking, Insurance, Securities and Health Care Administration charged violations of 9 V.S.A. 131 4221A(A)(8) for allegedly (I) permitting its investment banking department to exert improper influence over its research analysts, (II) issuing research that contained opinions that lacked a reasonable basis and/or contained exaggerated or unwarranted claims, and (III) failing to promptly produce required books and records; violations of 9 V.S.A. 131 4221A(A)(11) for allegedly failing to (I) reasonably supervise its employees to ensure that its research analysts were adequately insulated from pressures and influences from covered companies and investment banking and (II) establish, maintain and enforce written supervisory procedures. The matter was resolved on 03/05/2005, including $287,500 penalty paid to the state of Vermont on 03/18/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Vermont Department of Banking, Insurance, Securities and Health Care Admin. and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-04-251-04-CO01 03/25/2005 The Washington Department of Financial Institutions The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Washington Department of Financial Institutions charged violations of RCW 21.20.110(1)(G) for allegedly failing to ensure that research analysts who issue reports were adequately insulated from pressures and influences of covered companies and investment bankers; violations of RCW 21.20.110(I) for allegedly failing to reasonably supervise its employees to ensure that its analysts were adequately insulated from pressures and influences from covered companies and investment banking. Without admitting or denying the allegations, DBSI agreed to a consent order with the Washington Department of Financial Institutions. The Washington Department of Financial Institutions charged violations of RCW 21.20.110(1)(G) for allegedly failing to ensure that research analysts who issue reports were adequately insulated from pressures and influences of covered companies and investment bankers; violations of RCW 21.20.110(I) for allegedly failing to reasonably supervise its employees to ensure that its analysts were adequately insulated from pressures and influences from covered companies and investment banking. The matter was resolved on 03/25/2005, including $522,271 penalty paid to the state of Washington on 03/10/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Washington Department of Financial Institutions and a $522,271 penalty to the State of Washington. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-05026(LX) 03/29/2005 The Wisconsin Department of Financial Institutions The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Wisconsin Department of Financial Institutions charged violations of Wis. Stats. Sec. 551.34(1)(G) in connection with research analyst work, supervision and production of emails; violations of Wis. Stats. Sec. 551.34(1) (I) for allegedly failing to reasonable supervise its employees; and violations of Wis. Stats. 551.34(2) for allegedly failing to maintain and timely produce documents and materials (including emails). Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Wisconsin Department of Financial Institutions and to pay $87.5 million. The Wisconsin Department of Financial Institutions charged violations of Wis. Stats. Sec. 551.34(1)(G) in connection with research analyst work, supervision and production of emails; violations of Wis. Stats. Sec. 551.34(1)(I) for allegedly failing to reasonably supervise its employees; and violations of Wis. Stats. 551.34(2) for allegedly failing to maintain and timely produce documents and materials (including emails). The matter was resolved on 03/29/2005, including $475,269 penalty paid to the State of Wisconsin on 03/11/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Wisconsin Department of Financial Institutions and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: SEC-2003-00023 03/30/2005 The Commonwealth of Virginia State Corporation Commission The Registrant has not been the subject of this matter: The Commonwealth of Virginia State Corporation Commission charged violations of Virginia Securities Rule 21 VAC 5-20-260, Securities Rule 21 VAC 5-20-270 and Securities Rule 21 VAC 5-20-28(E)(12) in connection with research analyst work, supervision and production of emails. The current status is closed on March 30, 2005 (final order received from Virginia by DBSI's outside counsel on May 4, 2005). Without admitting or denying the allegations, DBSI agreed to a consent order with the Commonwealth of Virginia State Corporation Commission and to pay $87.5 million. The Commonwealth of Virginia State Corporation Commission charged violations of Virginia Securities Rule 21 VAC 5-20-260, Securities Rule 21 VAC 5-20-270 and Securities Rule 21 VAC 5-20-28(E)(12)in connection with research analyst work, supervision and production of emails. The DBSI agreement included undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings (including $627,219 paid to Virginia on 3/1/2005); (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. Without admitting or denying the allegations, DBSI agreed to a consent order including certain undertakings with the Commonwealth of Virginia State Corporation Commission and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-H-16 06/14/2005 The Colorado Division of Securities, Department of Regulatory Agencies The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Colorado Division of Securities, Department of Regulatory Agencies charged violations of CRS (2004) 11-51-407, 11-51-410(1)(G), and 11-51-410(1)(I) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a consent order with the Colorado Division of Securities, Department of Regulatory Agencies and to pay $87.5 million. The Colorado Division of Securities, Department of Regulatory Agencies charged violations of CRS (2004) 11-51-407, 11-51-410(1)(G), and 11-51-410(1)(I) in connection with research analyst work, supervision and production of emails. The matter was resolved on 06/14/2005, including $381,129 penalty paid to the State of Colorado on 06/10/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Colorado Division of Securities, Department of Regulatory Agencies and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0152-S-8/04 05/23/2005 The State of Florida Office of Financial Regulation The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Florida Office of Financial Regulation charged violations of sections 517.161(1)(A), 517.121, Florida Statutes and Rule 69W-600.013(1)(P), Florida Administrative Code in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Florida Office of Financial Regulation and to pay $87.5 million. The State of Florida Office of Financial Regulation charged violations of sections 517.161(1)(A), 517.121, Florida Statutes and Rule 69W-600.013(1)(P), Florida Administrative Code in connection with research analyst work, supervision and production of emails. The matter was resolved on 05/23/2005, including $1,416,180 penalty paid to the State of Florida on 05/10/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Florida Office of Financial Regulation and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: S-05-023-05-C001 06/23/2005 The Arkansas Securities Department The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Arkansas Securities Department charged violations of Ark Code Ann 23-42-308(A)(2)(G) and 23-42-308(A)(2)(J) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Arkansas Securities Department and to pay $87.5 million. The Arkansas Securities Department charged violations of Ark Code Ann 23-42-308(A)(2)(G) and 23-42-308(A)(2)(J) in connection with research analyst work, supervision and production of emails. The matter was resolved on 06/23/2005, including $287,500 penalty paid to the State of Arkansas on 06/16/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Arkansas Securities Department and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. C05-V-005 07/01/2005 The Commonwealth of Puerto Rico Commissioner of Financial Institutions The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Commonwealth of Puerto Rico Commissioner of Financial Institutions charged violations of Section 864 (A)(G) of Act. No. 60 and Section 26.1 of Regulation 6078 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Commonwealth of Puerto Rico Commissioner of Financial Institutions and to pay $87.5 million. The Commonwealth of Puerto Rico Commissioner of Financial Institutions charged violations of Section 864 (A)(G) of Act. No. 60 and Section 26.1 of Regulation 6078 in connection with research analyst work, supervision and production of emails. The matter was resolved on 07/01/2005, including $337,476 penalty paid to the Commonwealth of Puerto Rico on 07/06/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Commonwealth of Puerto Rico Commissioner of Financial Institutions and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 2005-7-11 07/15/2005 The Idaho Department of Finance The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Idaho Department of Finance charged violations of Idaho Code 30-1413(7) and IDAPA 12.01.08.119 and 12.01.08.124 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Idaho Department of Finance and to pay $87.5 million. The Idaho Department of Finance charged violations of Idaho Code 30-1413(7) and IDAPA 12.01.08.119 and 12.01.08.124 in connection with research analyst work, supervision and production of emails. The matter was resolved on 07/15/2005, including $287,500 penalty paid to the State of Idaho on 07/14/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Idaho Department of Finance and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1266565 07/11/2005 The New Jersey Office of the Attorney General, Division of Consumer Affairs The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The New Jersey Office of the Attorney General, Division of Consumer Affairs, Bureau of Securities charged violations of N.J.S.A. 49:3-58(A)(2)(XI) for allegedly failing to adequately supervise its employees; N.J.S.A. 49:3-58(A)(2)(VII) for allegedly failing to (I) manage conflicts of interest appropriately, (II) disclose payments made and received for research coverage, and (IV) publishing exaggerated or unwarranted research on investment banking clients; and N.J.S.A. 49:3-68 for allegedly failing to produce email documents. Without admitting or denying the allegations, DBSI agreed to a consent order with the New Jersey Office of the Attorney General, Division of Consumer Affairs, Bureau of Securities and to pay $87.5 million. The New Jersey Office of the Attorney General, Division of Consumer Affairs, Bureau of Securities charged violations of N.J.S.A. 49:3-58(A)(2)(XI) for allegedly failing to adequately supervise its employees; N.J.S.A. 49:3-58(A)(2)(VII) for allegedly failing to (I) manage conflicts of interest appropriately, (II) disclose payments made and received for research coverage, and (IV) publishing exaggerated or unwarranted research on investment banking clients; and N.J.S.A. 49:3-68 for allegedly failing to produce email documents. The matter was resolved on 07/11/2005, including $745,585 penalty paid to the State of New Jersey on 06/27/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the New Jersey Office of the Attorney General, Division of Consumer Affairs, Bureau of Securities and pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 05-3-1 08/22/2005 The State of Delaware, Department of Justice, Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Delaware, Department of Justice, Securities Division charged violations of 6 Del. C. Secs. 7315(A), 7316(A)(7) and 7316(A)(10) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Delaware, Department of Justice, Securities Division and to pay $87.5 million. The State of Delaware, Department of Justice, Securities Division charged violations of 6 Del. C. Secs. 7315(A), 7316(A)(7) and 7316(A)(10) in connection with research analyst work, supervision and production of emails. The matter was resolved on 08/22/2005, including $287,500 penalty paid to the State of Delaware on 08/16/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Delaware, Department of Justice, Securities Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: SEC.CO 05-02 06/21/2005 The District of Columbia Department of Insurance, Securities and Banking The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The District of Columbia Department of Insurance, Securities and Banking charged violations of D.C. Official Code 31-5602.07(A)(9) for allegedly enabling the Investment Banking Department to exert influence over research analysts, issuing research reports affected by conflicts of interest, making payments for research coverage, and receiving payments for research without disclosing receipt of those payments; violations of D.C. Official Code 31-5602.07(A)(12) for allegedly failing to establish and maintain adequate policies and procedures to detect improper influences and manage conflicts of interest. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the District of Columbia Department of Insurance, Securities and Banking, and to pay $87.5 million. The District of Columbia Department of Insurance, Securities and Banking charged violations of D.C. Official Code 31-5602.07(A)(9) for allegedly enabling the Investment Banking Department to exert influence over research analysts, issuing research reports affected by conflicts of interest, making payments for research coverage, and receiving payments for research without disclosing receipt of those payments; violations of D.C. Official Code 31-5602.07(A)(12) for allegedly failing to establish and maintain adequate policies and procedures to detect improper influences and manage conflicts of interest. The matter was resolved on 06/21/2005, including $287,500 penalty paid to the District of Columbia on 04/11/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the District of Columbia Department of Insurance, Securities and Banking, and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 105-185-JN 08/11/2005 The Nevada Secretary of State, Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Nevada Secretary of State, Securities Division charged violations of NRS 90.420(1)(H), NRS 90.420(1)(K), NAC 90.342, NAC 90.321 and NASD Conduct Rule 3010 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Nevada Secretary of State, Securities Division and to pay $87.5 million. The Nevada Secretary of State, Securities Division charged violations of NRS 90.420(1)(H), NRS 90.420(1)(K), NAC 90.342, NAC 90.321 and NASD Conduct Rule 3010 in connection with research analyst work, supervision and production of emails. The matter was resolved on 08/11/2005, including $287,500 penalty paid to the State of Nevada on 08/09/2005. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Nevada Secretary of State, Securities Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-02 07/26/2005 The State of Wyoming Secretary of State The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Wyoming Secretary of State charged violations of Wyo. Stat. 17-4-106(A)(II)(G) and 17-4-106(B)(II)(A) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Wyoming Secretary of State and to pay $87.5 million. The State of Wyoming Secretary of State charged violations of Wyo. Stat. 17-4-106(A)(II)(G) and 17-4-106(B)(II)(A) in connection with research analyst work, supervision and production of emails. The matter was resolved on 07/26/2005, including $287,500 penalty paid to the State of Wyoming on 07/14/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Wyoming Secretary of State and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-0021 CO 08/11/2005 The Indiana Office of the Secretary of State, Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Indiana Office of the Secretary of State, Securities Division charged violations of Indiana Code 23-2-1-11(A)(6) and 710 Ind. Admin. Code 1-17-1(W) for allegedly failing to ensure that research analysts were insulated from covered companies and investment banking and Indiana Code 23-2-1-11(A)(14) and 710 Indiana Administrative Code 1-17-1(V) for allegedly failing to supervise its employees. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Indiana Office of the Secretary of State, Securities Division and to pay $87.5 million. The Indiana Office of the Secretary of State, Securities Division charged violations of Indiana Code 23-2-1-11(A)(6) and 710 Ind. Admin. Code 1-17-1(W) for allegedly failing to ensure that research analysts were insulated from covered companies and investment banking and Indiana Code 23-2-1-11(A)(14) and 710 Indiana Administrative Code 1-17-1(V) for allegedly failing to supervise its employees. The matter was resolved on 08/11/2005, including $538,784 penalty paid to the State of Indiana on 08/16/2005. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Indiana Office of the Secretary of State, Securities Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 02-11-06-S 07/01/2005 The Office of the Mississippi Secretary of State, Business Regulation The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Office of the Mississippi Secretary of State, Business Regulation and Enforcement Division charged violations of Miss. Code Ann. 75-71-321(A)(F) (Rev. 2000) in connection with research analyst work, supervision and production of emails and Miss. Code Ann. 75-71-321(B)(A) (Rev. 2000) for allegedly failing to reasonably supervise its employees. Without admitting or denying the allegations, DBSI agreed to a consent order with the Office of the Mississippi Secretary of State, Business Regulation and Enforcement Division and to pay $87.5 million. The Office of the Mississippi Secretary of State, Business Regulation and Enforcement Division charged violations of Miss. Code Ann. 75-71-321(A)(F) (Rev. 2000) in connection with research analyst work, supervision and production of emails and Miss. Code Ann. 75-71-321(B)(A) (Rev. 2000) for allegedly failing to reasonably supervise its employees. The matter was settled on 07/01/2005, including $287,500 penalty paid to the state of Mississippi on 07/16/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Office of the Mississippi Secretary of State, Business Regulation and Enforcement Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1273373 08/26/2005 The State of North Dakota Securities Department The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of North Dakota Securities Department charged violations of Section 10-04-11(C) N.D.C.C. in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of North Dakota Securities Department and to pay $87.5 million. The State of North Dakota Securities Department charged violations of Section 10-04-11(C) N.D.C.C. in connection with research analyst work, supervision and production of emails. The matter was resolved on 08/26/2005, including $287,500 penalty paid to the State of North Dakota on 08/23/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of North Dakota Securities Department and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1274034 08/25/2005 The Utah Division of Securities, Department of Commerce The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Utah Division of Securities, Department of Commerce charged violations of Utah Code Ann. 61-1-6(2)(G) for allegedly enabling conflicts of interest to develop and failing to manage such conflicts, issuing reports affected by such conflicts, making payments for research, and receiving payment for research and violations of Utah Code Ann. 61-1-6(2)(J) for allegedly failing to establish and maintain adequate policies and procedures for avoiding and managing conflicts of interest; violations of 61-1-5(S) and R164-6-1G(C)(30) of the Utah Administrative Code for allegedly failing to produce emails. Without admitting or denying the allegations, DBSI agreed to a consent order with the Utah Division of Securities, Department of Commerce and to pay $87.5 million. The Utah Division of Securities, Department of Commerce charged violations of Utah Code Ann. 61-1-6(2)(G) for allegedly enabling conflicts of interest to develop and failing to manage such conflicts, issuing reports affected by such conflicts, making payments for research, and receiving payment for research and violations of Utah Code Ann. 61-1-6(2)(J) for allegedly failing to establish and maintain adequate policies and procedures for avoiding and managing conflicts of interest; violations of 61-1-5(S) and R164-6-1G(C)(30) of the Utah Administrative Code for allegedly failing to produce emails. The matter was resolved on 08/25/2005, including $287,500 penalty paid to the State of Utah on 08/09/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the Utah Division of Securities, Department of Commerce and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1276422 09/30/2005 The West Virginia Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The West Virginia Securities Division charged violations of West Virginia Code 32-2-204 for (1) allegedly failing to reasonably supervise its agents or employees and (2) for allegedly failing to ensure that analysts were adequately insulated from influences of covered companies and investment banking. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the West Virginia Securities Division and to pay $87.5 million. The West Virginia Securities Division charged violations of West Virginia Code 32-2-204 for (1) allegedly failing to reasonably supervise its agents or employees and (2) for allegedly failing to ensure that analysts were adequately insulated from influences of covered companies and investment banking. The matter was resolved on 09/30/2005, including $287,500 penalty paid to the State of West Virginia on 10/10/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the West Virginia Securities Division and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: SEU-2005-036-B 10/17/2005 The State of Hawaii Department of Commerce and Consumer Affairs The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Hawaii Department of Commerce and Consumer Affairs charged violation of: H.R.S. 485-15(7) for allegedly failing to ensure analysts were adequately insulated from pressures and influences from covered companies and investment banking; 485-16 for allegedly failing to promptly produce copies of email communications requested by regulators; and 485-15(10) for allegedly failing to reasonably supervise its employees to ensure that analysts were adequately insulated from pressures and influences from covered companies and investment banking. Without admitting or denying the allegations, DBSI agreed to a consent order and consent to entry of administrative order with the State of Hawaii Department of Commerce and Consumer Affairs and to pay $87.5 million. The State of Hawaii Department of Commerce and Consumer Affairs charged violation of: H.R.S. 485-15(7) for allegedly failing to ensure analysts were adequately insulated from pressures and influences from covered companies and investment banking; 485-16 for allegedly failing to promptly produce copies of email communications requested by regulators; and 485-15(10) for allegedly failing to reasonably supervise its employees to ensure that analysts were adequately insulated from pressures and influences from covered companies and investment banking. The matter was resolved on 10/17/2005, including $287,500 penalty paid to the State of Hawaii on 10/10/2005. Without admitting or denying the allegations, DBSI agreed to a consent order and consent to entry of administrative order with the State of Hawaii Department of Commerce and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-17-05-144I 11/02/2005 The Montana State Auditor's Office Securities Department The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Montana State Auditor's Office Securities Department charged DBSI with violations of MCA 30-10-201(13)(K) for allegedly failing to reasonably supervise its employees, MCA 30-10-201(12) for allegedly failing to keep required books and records, MCA 30-10-201(13)(G) for allegedly failing to ensure analysts were adequately insulated from pressures and influences from covered companies and investment banking, and MCA 30-10-201(13)(G) in connection with the foregoing. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Montana State Auditor's Office Securities Department and to pay $87.5 million. The Montana State Auditor's Office Securities Department charged DBSI with violations of MCA 30-10-201(13)(K) for allegedly failing to reasonably supervise its employees, MCA 30-10-201(12) for allegedly failing to keep required books and records, MCA 30-10-201(13)(G) for allegedly failing to ensure analysts were adequately insulated from pressures and influences from covered companies and investment banking, and MCA 30-10-201(13)(G) in connection with the foregoing. The matter was resolved on 11/02/2005, including $287,500 penalty paid to the State of Montana on 10/01/2005. Without admitting or denying the allegations, DBSI agreed to a consent agreement and order with the Montana State Auditor's Office Securities Department and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 05-010-M 11/04/2005 The State of Michigan Office of Financial and Insurance Services The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Michigan Office of Financial and Insurance Services charged DBSI with violations of MCL 451.604(A)(1)(G) and (A)(2) for alleged failures relating to just and equitable principles of trade; the reasonable supervision of its employees to ensure adequate insulation between its research analysts and investment banking; the establishment, maintenance, and enforcement of written procedures; and the keeping of required books and records. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Michigan Office of Financial and Insurance Services and to pay $87.5 million. The State of Michigan Office of Financial and Insurance Services charged DBSI with violations of MCL 451.604(A)(1)(G) and (A)(2) for alleged failures relating to just and equitable principles of trade; the reasonable supervision of its employees to ensure adequate insulation between its research analysts and investment banking; the establishment, maintenance, and enforcement of written procedures; and the keeping of required books and records. The matter was resolved on 11/04/2005, including $880,634 penalty paid to the State of Michigan on 10/24/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Michigan Office of Financial and Insurance Services and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: CO-2005-7083-S 12/07/2005 The State of Connecticut Department of Banking The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Connecticut Department of Banking charged DBSI with violations of Section 36B-4(B) of the Connecticut Uniform Securities Act (the "Act") for allowing conflicts of interest to develop and failing to manage these conflicts, issuing research reports that were affected by conflicts, and making and receiving payments in connection with certain transactions and failing to disclose such payments; violations of Section 36B-31-6F(B) of the Regulations of Connecticut State Agencies promulgated under the Act (the "Regulations") for failing to establish and maintain systems to detect and prevent and manage conflicts; and violations of Section 36B -14 of the Act and Section 36B-31-14F of the Regulations for failing to produce electronic mail in a timely manner. Without admitting or denying the allegations, DBSI agreed to a consent order with the State of Connecticut Department of Banking and to pay $87.5 million. The State of Connecticut Department of Banking charged DBSI with violations of Section 36B-4(B) of the Connecticut Uniform Securities Act (the "Act") for allowing conflicts of interest to develop and failing to manage these conflicts, issuing research reports that were affected by conflicts, and making and receiving payments in connection with certain transactions and failing to disclose such payments; violations of Section 36B-31-6F(B) of the Regulations of Connecticut State Agencies promulgated under the Act (the "Regulations") for failing to establish and maintain systems to detect and prevent and manage conflicts; and violations of Section 36B -14 of the Act and Section 36B-31-14F of the Regulations for failing to produce electronic mail in a timely manner. The matter was resolved on 12/07/2005, including $301,763 penalty paid to the State of Connecticut on 11/16/2005. Without admitting or denying the allegations, DBSI agreed to a consent order with the State of Connecticut Department of Banking and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 04CV06909 01/31/2006 The State of South Dakota Division of Securities The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of South Dakota Division of Securities charged DBSI with violations of Chapter 47-31B under 47-31B-412(D)(9) and 47-31B-412(13) in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of South Dakota Division of Securities and to pay $87.5 million. The State of South Dakota Division of Securities charged DBSI with violations of Chapter 47-31B under 47-31B-412(D)(9) and 47-31B-412(13) in connection with research analyst work, supervision and production of emails. The matter was resolved on 01/31/2006, including $287,500 penalty paid to the State of South Dakota on 01/27/2006. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of South Dakota Division of Securities and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 06025 06/16/2006 The Securities Division of the Attorney General of the State of South Carolina The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Securities Division of the Attorney General of the State of South Carolina charged DBSI with violations of South Carolina Act 35-1-412(D)(13), 35-1-412(D)(9), and 35-1-411(D) in connection with alleged conflicts of interest with respect to its research analysts, issuance of research reports affected by conflicts of interest, making payments for research, failure to disclose receipt of payments for research, and failure to establish and maintain adequate policies, systems and procedures for supervision and control to detect and prevent such violations. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the Securities Division of the Attorney General of the State of South Carolina. DBSI was subject to a cease and desist order, and paid $355,499 to South Carolina on 6/13/2006. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. The Securities Division of the Attorney General of the State of South Carolina charged DBSI with violations of South Carolina Act 35-1-412(D)(13), 35-1-412(D)(9), and 35-1-411(D) in connection with alleged conflicts of interest with respect to its research analysts, issuance of research reports affected by conflicts of interest, making payments for research, failure to disclose receipt of payments for research, and failure to establish and maintain adequate policies, systems and procedures for supervision and control to detect and prevent such violations. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the Sec. Div. of the Attorney General of South Carolina. DBSI was subject to a cease and desist order and paid $355,499 to South Carolina. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 05-005 06/26/2006 The Tennessee Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Tennessee Securities Division charged DBSI with violations of Tennessee Code Annotated 48-2-112(A)(2)(G), 48-2-112(A)(2)(J), and 48-2-111 in connection with alleged conflicts of interest with respect to its research analysts and investment banking business, the alleged failure to establish and maintain adequate policies and procedures to manage these conflicts of interest, and the alleged failure to promptly produce e-mail communications. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the Tennessee Securities Division. DBSI was subject to a cease and desist order, and paid $504,120 to Tennessee on 5/30/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. The Tennessee Securities Division charged DBSI with violations of Tennessee Code Annotated 48-2-112(A)(2)(G), 48-2-112(A)(2)(J), and 48-2-111 in connection with alleged conflicts of interest with respect to its research analysts and investment banking business, the alleged failure to establish and maintain adequate policies and procedures to manage these conflicts of interest, and the alleged failure to promptly produce e-mail communications. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the Tennessee Securities Division. DBSI was subject to a cease and desist order, and paid $504,120 to Tennessee on 5/30/06. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: IC06-CDO-07 05/31/2006 The Texas State Securities Board The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Texas State Securities Board charged DBSI with violations of 115.5 and 115.10 of the Rules and Regulations of the Texas State Securities Board for allegedly engaging in inequitable practices in the sale of securities as specified in section 14.A(3) of the Texas Securities Act, in connection with research analyst work, supervision and production of e-mails. Without admitting or denying the allegations, DBSI agreed to the entry of an order and findings of fact and conclusions of law by the Texas State Securities Board. DBSI was subject to a cease and desist order, and paid $1,847,656 to Texas on 5/30/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. The Texas State Securities Board charged DBSI with violations of 115.5 and 115.10 of the Rules and Regulations of the Texas State Securities Board for allegedly engaging in inequitable practices in the sale of securities as specified in section 14.A(3) of the Texas Securities Act, in connection with research analyst work, supervision and production of e-mails. Without admitting or denying the allegations, DBSI agreed to the entry of an order and findings of fact and conclusions of law by the Texas State Securities Board. DBSI was subject to a cease and desist order, and paid $1,847,656 to Texas on 5/30/06. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE NO. 0600247 07/20/2006 The Illinois Securities Department The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Illinois Securities Department charged DBSI with violations of 8.E(1)(B) of the Illinois Securities Law of 1953, as amended, (the "Act") in connection with alleged inappropriate influence by investment banking over research analysts, failure to manage such conflicts, publication of exaggerated, unwarranted, and unreasonable ratings on certain stocks, receipt and making of payments that included research coverage and the failure to disclose those payments. DBSI also was charged with violations of 8.E(1)(E)(IV) of the Act in connection with the alleged failure to establish and maintain adequate policies and procedures, and the alleged failure to fully and completely respond to e-mail production requests. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the State of Illinois Secretary of State, Securities Department. DBSI was subject to a cease and desist order, and paid $1,100,459 to Illinois on 7/12/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. The Illinois Securities Department charged DBSI with violations of 8.E(1)(B) of the Illinois Securities Law of 1953, as amended, (the "Act") in connection with alleged inappropriate influence by investment banking over research analysts, failure to manage such conflicts, publication of exaggerated, unwarranted, and unreasonable ratings on certain stocks, receipt and making of payments that included research coverage and the failure to disclose those payments. DBSI also was charged with violations of 8.E(1)(E)(IV) of the Act in connection with the alleged failure to establish and maintain adequate policies and procedures, and the alleged failure to fully and completely respond to e-mail production requests. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with the State of Illinois Sec'ty. of State, Sec. Dept. DBSI was subject to a cease and desist order, and paid $1,100,459 to Illinois. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1328168 10/19/2006 The State of Louisiana Office of Financial Institutions Securities Division The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Louisiana Office of Financial Institutions Securities Division charged DBSI with violations of the Louisiana Securities Law in connection with alleged inappropriate influence by investment banking over research analysts, failure to manage such conflicts, failure to establish and maintain adequate policies and procedures, and failure to promptly produce requested e-mail communications. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative order by the Office of Financial Institutions Securities Division. DBSI was subject to a cease and desist order, and paid $395,990 to Louisiana on 8/02/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative order by the Office of Financial Institutions Securities Division. DBSI was subject to a cease and desist order, and paid $395,990 to Louisiana on 8/02/06. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No.05-058 10/12/2006 The State of Oklahoma Department of Securities The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The state of Oklahoma Department of Securities charged DBSI with violations of Predecessor Act and/or the rules of the Oklahoma Securities Commission and the Administrator of the Department of Securities in connection with alleged inappropriate influence by investment banking over research analysts, failure to manage such conflicts, failure to establish and maintain adequate policies and procedures, and failure to promptly produce requested e-mail communications. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with State of Oklahoma Department of Securities. DBSI was subject to a cease and desist order, and paid $305,758 to Oklahoma on 8/02/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. The State of Oklahoma Department of Securities charged DBSI with violations of Predecessor Act and/or the rules of the Oklahoma Securities Commission and the Administrator of the Department of Securities in connection with alleged inappropriate influence by investment banking over research analysts, failure to manage such conflicts, failure to establish and maintain adequate policies and procedures, failure to promptly produce requested e-mail communications. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative consent order with State of Oklahoma Department of Securities. DBSI was subject to a cease and desist order, and paid $305,758 to Oklahoma on 8/02/06. Deutsche Bank Securities Inc. (DBSI), Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management, Inc. (DAMI), Affiliates Occurrence 1337345 01/31/2007 NYAG The Registrant has not been the subject of this matter: Initiation date: 12/21/2006. Deutsche Investment Management Americas Inc. ("DIMA"), and Deutsche Asset Management, Inc. ("DAMI") serve as investment advisors to the DWS Scudder Funds. The NYAG alleged DIMA and DAMI breached their fiduciary duty to certain DWS Scudder Funds by failing to effectively limit trading activity in DWS Scudder Funds. The NYAG also alleged that DIMA and DAMI breached their fiduciary duty to certain DWS Scudder Funds by entering into market timing arrangements with investors. The NYAG alleged that Deutsche Bank Securities Inc. ("DBSI"), through the activity of one of its registered representatives, facilitated market timing and a form of late trading by a client. The NYAG alleged that the former registered representative received and entered orders to purchase, redeem or exchange mutual fund shares after 4:00 P.M. eastern time market close on certain occasions where customer orders received before 4:00 P.M. were blocked by fund companies as market timing trades. The customer orders entered into after 4:00 P.M. served as substitute orders for those that had been previously received and blocked before 4:00 P.M. Without admitting or denying the allegations, DIMA, DAMI, and DBSI agreed to pay, jointly and severally, $102.3 million in disgorgement. DIMA and DAMI also agreed to pay $20 million in a civil penalty. The entire amount of $123.3 million is to be distributed for the benefit of the shareholders of the affected DWS Scudder Funds. DIMA and DAMI are subject to certain undertakings regarding the conduct of their business in the future, including: formation of a code of ethics oversight committee to oversee all matters relating to issues arising under DIMA's and DAMI's code of ethics; establishment of an internal compliance controls committee having overall compliance oversight responsibility of DIMA and DAMI; engagement of an independent compliance consultant to conduct a comprehensive review of DIMA and DAMI's supervisory, compliance, and other policies and procedures designed to prevent and detect breaches of fiduciary duty, breaches of the code of ethics, and Federal Securities law violations by DIMA and DAMI and their employees; and commencing in 2008, DIMA and DAMI shall undergo a compliance review by an independent third party. The fine will be placed into escrow on or about January 31, 2007. Without admitting or denying the allegations, DIMA, DAMI, and DBSI agreed to pay, $102.3 million in disgorgement. DIMA and DAMI also agreed to pay $20 million in a civil penalty. The entire amount of $123.3 million is to be distributed. Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management, Inc. (DAMI), Affiliates Occurrence 1339522 01/04/2007 Illinois Securities Department The Registrant has not been the subject of this matter: Initiation date: 12/28/2006. On December 19, 2006, Deutsche Bank AG London Branch ("DB London") received notice that the Comision Nacional Del Mercado ("CNMV") received approval to sanction DB London in respect of an equity placement (block trade) executed in shares of Spanish company Ebro Puleva in February 2004. The CNMV alleged that, pursuant, to prospectus describing the placement, DB London imposed upon itself an obligation not to carry out any market sound or wall crossing activities prior to the close of the Madrid market and approval of the short prospectus by the CNMV on the date of the transaction. The CNMV argued that DB London breached this obligation by approaching three investors to determine market interest prior to the market close. DIMA and DAMI are subject to certain undertakings regarding the conduct of its business in the future, including: formation of a code of ethics oversight committee to oversee all matters relating to issues arising under DIMA and DAMI's code of ethics; formation of a code of ethics oversight committee to oversee all matters relating to issues arising under DIMA and DAMI's code of ethics; establishment of an internal compliance controls committee having overall compliance oversight responsibility of DIMA and DAMI; engagement of an independent compliance consultant to conduct a comprehensive review of DIMA and DAMI's supervisory compliance and other policies and procedures designed to prevent and detect breaches of fiduciary duty, breaches of the code of ethics and Federal Securities law violations by DIMA and DAMI and their employees; and within 120 days and in 2008, DIMA and DAMI shall undergo a compliance review by an independent third party. DIMA and DAMI were ordered to pay, jointly and severally, $2 million to the Illinois Securities Department Audit and Enforcement Fund and $4 million to the Illinois Securities Department Investors Education Fund. The first payment of $3 million (consisting of $2 million to the Illinois Securities Department Audit and Enforcement Fund and $1 million to the Illinois Securities Department Investors Education Fund) were made on January 4, 2007. Three payments of $1 million each to the Illinois Securities Department Investors Education Fund are due on December 3, 2007, December 1, 2008 and December 1, 2009. DIMA and DAMI were ordered to pay, jointly and severally, $2 million to the Illinois Securities Department Audit and Enforcement Fund and $4 million to the Illinois Securities Department Investors Education Fund. The first payment was made 1/4/07. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: Securities Division No. 2002-0894 01/30/2007 Securities Commissioner of Maryland The Registrant has not been the subject of this matter: Initiation date: 10/26/2006. In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Securities Commissioner of Maryland charged DBSI with violations of Section 11-412(A)(7) of the Maryland Securities Act in connection with alleged creation and/or maintenance of inappropriate influence by Investment Banking over research analysts, the imposition of and failure to manage conflicts of interest for its research analysts, issuance of exaggerated or unwarranted research, inappropriate use of research coverage, and failure to disclose compensation for inappropriately issuing and receiving research reports. DBSI was also charged with violations of Section 11-412(A)(10) for allegedly failing to establish and enforce written supervisory procedures reasonably designed to ensure that analysts were not unduly influenced by investment banking. Without admitting or denying the allegations, DBSI consented to the entry of an administrative consent order by the Securities Commissioner. DBSI was subject to a cease and desist order, and paid $469,315 to the Securities Division of the Office of the Attorney General of the State of Maryland on 12/8/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. The matter was resolved on 01/30/2007. Without admitting or denying the allegations, DBSI consented to the entry order by the Securities Commissioner. DBSI paid $469,315 to the Securities Division of the Office of the Attorney General of the State of Maryland on 12/8/06. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1339443 12/01/2006 Attorney General of the State of New York The Registrant has not been the subject of this matter: Initiation date: 10/26/2006. In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Attorney General of the State of New York charged DBSI with violations of the General Business Law of the State of New York (The "Martin Act") in connection with alleged creation of conflicts of interest for its research analysts as a result of its research structure, alleged failure to establish and maintain adequate policies and procedures reasonably designed to manage these conflicts of interest, alleged publication of exaggerated or unwarranted research, and alleged failure to promptly produce copies of E-mail communications. Without admitting or denying the allegations, DBSI agreed to enter into an assurance of discontinuance with the Attorney General of the State of New York. DBSI was subject to a cease and desist order, and paid $1,681,482 to the New York State Department of Law on 11/16/2006. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. The matter was resolved on 12/01/2006. Without admitting or denying the allegations, DBSI agreed to enter into an assurance of discontinuance with the Attorney General of the State of New York. DBSI paid $1,681,482 to the New York State Department of Law on 11/16 2006. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NJ Bureau of Securities Action 6/3/09 06/03/2009 Bureau of Securities, State of New Jersey ("NJ Bureau of Securities") The Registrant has not been the subject of this matter: Initiation date 6/3/2009. The NJ Bureau of Securities alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Pursuant to a consent order executed on June 3, 2009, DBSI agreed to pay a penalty of $1,057,350.69 to New Jersey and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. DBSI also agreed to pay $15,000 to the North American Securities Administrators Association ("NASAA") as reimbursement for costs associated with NASAA'S assistance on NJ's investigation. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "August 31 Term Sheet"). The August 31 Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $1,057,350.69 penalty imposed by New Jersey is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI consented to the Bureau Chief making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business in violation of N.J.S.A 49:3-58(A)(2)(VII); and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct, in violation of its duties under N.J.S.A. 49:3-58(A)(2)(XI). Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $1,057,350.69 to New Jersey, and also agreed to pay $15,000 to the North American Securities Administrators Association. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NY Investor Protection Bureau Action 6/3/09 06/03/2009 Attorney General of the State of New York, Investor Protection Bureau ("NYAG") The Registrant has not been the subject of this matter: Initiation date 6/3/2009. The Assurance of Discontinuance ("AOD") entered into between DBSI and the NYAG on June 3, 2009 alleged that DBSI misled certain investors as to the risks related to, and the liquidity of, Auction Rate Securities ("ARS"). Pursuant to the AOD, DBSI agreed to pay a penalty of $678,282.50 to New York and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The AOD finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and the NYAG and that resulted in a Term Sheet (the "August 31 Term Sheet"). The August 31 Term Sheet required a total penalty of $15,000,000, and the $678,282.50 penalty imposed by the NYAG is New York's pro-rata share of the total penalty amount. The AOD requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the AOD. Without admitting or denying the allegations of the NYAG, DBSI agreed to certain relief as described above. The AOD stated that the acts and practices of DBSI as described in the AOD violated: (1) The Martin Act, Article 23-A of the NY General Business Law, (2) Section 349 of the NY General Business Law, and (3) Section 63(12) of the NY Executive Law. Without admitting or denying the allegations of the NYAG, in accordance with the August 31, 2008 Term Sheet, DBSI agreed to a penalty of $15,000,000 and the $678,282.50 penalty imposed by the NYAG is New York's pro-rata share of the total penalty amount. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEC-2009-39 08/03/2009 Montana Securities Department ("Department") The Registrant has not been the subject of this matter: Initiation date 8/3/2009. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business in violation of Mont. Code Ann. Section 30-10-201(13)(G); and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct, in violation of its duties under Mont. Code Ann. Section 30-10-201(13)(K). Pursuant to a Consent Agreement and Final Order ("Order") entered by the Commissioner of Securities and Insurance on August 3, 2009, DBSI agreed to pay a penalty of $30,000.00 to the Investor Protection Trust on behalf of the State of Montana and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000.00 penalty imposed by the Department is its pro-rata share of the total penalty amount. The Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Order. Without admitting or denying the allegations in the Order, DBSI agreed to pay a penalty of $30,000.00 to the Investor Protection Trust on behalf of the State of Montana. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant I09-181 08/03/2009 Securities Division, Office of the Secretary of State, Nevada ("the Division") The Registrant has not been the subject of this matter: Initiation date 8/3/2009. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Consent Order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. NRS 90.420(1)(H) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. NRS 90.420(1)(1) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a Consent Order entered by the Division on August 3, 2009, DBSI agreed to pay a penalty of $199,478.53 to the Nevada State General Fund for credit to the Secretary of State's Operating General Fund Budget account and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Consent Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $199,478.53 penalty imposed by the Division is its pro-rata share of the total penalty amount. The Consent Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Consent Order. Without admitting or denying the allegations in the Consent Order, pursuant to a Consent Order entered by the Division on August 3, 2009, DBSI agreed to pay a penalty of $199,478.53 to the Nevada State General Fund. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant S-03578A-09-0314 08/20/2009 Arizona Corporation Commission ("Commission") The Registrant has not been the subject of this matter: Initiation date 8/20/2009. The Commission alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Order, DBSI consented to the Commission making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business in violation of A.R.S. Section 44-1961(A)(13); and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct, in violation of its duties under A.R.S. Section 44-1961(A)(12). Pursuant to an order for administrative penalties and consent to same ("Order") entered by the Commission on August 20, 2009, DBSI agreed to pay a penalty of $115,823.35 to the State of Arizona and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $115,823.35 penalty imposed by the State of Arizona is its pro-rata share of the total penalty amount. The Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Order. Without admitting or denying the allegations in the Order, DBSI agreed to pay a penalty of $115,823.35 to the State of Arizona. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. CO-2009-0037 11/05/2009 Alabama Securities Commission ("The Commission") The Registrant has not been the subject of this matter: Initiation date 11/5/2009. The Commission alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Administrative Consent Order, DBSI consented to the Commission making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the Securities Business. Code of Alabama 8-6-3(J)(7) allows the Division, through its Administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Code of Alabama 8-6-3(J)(10) allows the Commission, through its Administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to an Administrative Consent Order entered by the Commission on November 5, 2009, DBSI agreed to a payment of $18,853.36 to the Alabama Securities Commission and $20,000 to the State of Alabama and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Administrative Consent Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. The Administrative Consent Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Consent Order. Without admitting or denying the allegations in the Administrative Consent Order, DBSI agreed to a payment of $18,853.36 to the Alabama Securities Commission and $20,000 to the State and to take certain measures with respect to current and former clients. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 11/06/2009 North Dakota Securities Department ("The Department") The Registrant has not been the subject of this matter: Initiation date 11/6/2009. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Consent Order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. N.D.C.C. section 10-4-11(1)(C) allows the Department, through its Administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. N.D.C.C. . section 10-4-11(1)(M) allows the Department, through its Administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a Consent Order entered by the Department on November 6, 2009, DBSI agreed to pay a penalty of $30,000 to the North Dakota Securities Department and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Consent Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Department is its pro-rata share of the total penalty amount. The Consent Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Consent Order. Without admitting or denying the allegations in the Consent Order, DBSI agreed to pay a penalty of $30,000 to the North Dakota Securities Dept. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 09-7-1 11/05/2009 Division of Securities, Dept. of Justice, State of Delaware ("The Division") The Registrant has not been the subject of this matter: Initiation date 11/5/2009. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Consent Order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. 6 Del. C. section 7316(A)(7) allows the Division, through its Administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. 6 Del. C. section 7316(A)(10) allows the Division, through its Administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a Consent Order entered by the Division on November 5, 2009, DBSI agreed to pay a penalty of $33,075.19 to the State of Delaware and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Consent Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $33,075.19 penalty imposed by the Division is its pro-rata share of the total penalty amount. The Consent Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Consent Order. Without admitting or denying the allegations in the Consent Order, DBSI agreed to pay a penalty of $33,075.19 to the State of Delaware and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 90-2525 11/23/2009 Division of Securities, Office of State Auditor, West Virginia (The "Division") The Registrant has not been the subject of this matter: Initiation date 11/23/2009. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of Auction Rate Securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the Consent Order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. West Virginia Code Section 32-2-204 allows the Division, through its Administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) In connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. West Virginia Code Section 32-4-407 allows the Division, through its Administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a Consent Order entered by the Division on November 23, 2009, DBSI agreed to pay a penalty of $30,000 to the West Virginia Securities Division and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The Consent Order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a Term Sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. The Consent Order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the Consent Order. Without admitting or denying the allegations in the Consent Order, DBSI agreed to pay a penalty of $30,000 to the West Virginia Securities Div. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/01/2009 Minnesota Department of Commerce, Market Assurance Division ("The Division") The Registrant has not been the subject of this matter: Initiation date 12/1/2009. The Market Assurance Division of the Department of Commerce, State of Minnesota ("the Division") alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Minn. Stat. sections 80a.07, Subd. 1(7) and 80a.67(d)(13) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Minn. Stat. sections 80a.07, Subd. 1(10) and 80a.67(d)(9) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a consent order entered by the Division on December 1, 2009, DBSI agreed to pay a penalty of $534,460.63 to the Minnesota Department of Commerce and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $534,460.63 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $534,460.63 to the Minnesota Dept. of Commerce and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08 Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/02/2009 Michigan Office of Fin. & Ins. Reg. of Dept. of Energy, Labor, and Econ. Growth The Registrant has not been the subject of this matter: Initiation date 12/2/2009. The Office of Financial and Insurance Regulation of the Department of Energy, Labor, and Economic Growth of the State of Michigan ("the Office") alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Office making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. MCL 451.604(A)(1)(G) allows the Office, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. MCL 451.604(A) (2) allows the Office, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a consent order entered by the Office on December 2, 2009, DBSI agreed to pay a penalty of $27,650.45 to the state of Michigan and $3,072.27 to the Michigan Investor Protection Trust and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,722.72 penalty imposed by the Office is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $27,650.45 to Michigan and $3,072.27 to the Michigan Investor Protection Trust and to take certain measures with respect to current and former ARS clients. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-195-09-CO01 12/01/2009 State of Washington Division of Securities, Dept. of Financial Institutions The Registrant has not been the subject of this matter: Initiation date 12/1/2009. The Division of Securities of the Department of Financial Institutions, State of Washington ("the Division") alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. RCW 21.20.110(1)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. RCW 21.20.110(1)(J) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a consent order entered by the Division on December 1, 2009, DBSI agreed to pay a penalty of $154,308.35 to the Washington Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $154,308.35 to Washington Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/04/2009 Office of Commissioner of Financial Institutions, Commonwealth of Puerto Rico The Registrant has not been the subject of this matter: Initiation date 12/4/2009. The Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico ("the Office") alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 204(A)(2)(G) of Act No. 60 allows the Office, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 204(A)(2)(J) of Act No. 60 allows the Office, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to a consent order entered by the Office on December 4, 2009, DBSI agreed to pay a penalty of $30,000 to the Secretary of the Treasury of the Commonwealth of Puerto Rico and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Office is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $30,000 to the Secretary of the Treasury of Puerto Rico and to take measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07-10 12/15/2009 Commission of Securities of the Commonwealth of Pennsylvania ("The Commission") The Registrant has not been the subject of this matter: Initiation date 12/15/2009. The Commission alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the order, DBSI consented to the Commission making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. 70 P.S. Section 305(A)(IX) allows the Commission, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. 70 P.S. Section 305(A)(VII) allows the Commission, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the findings of fact, conclusions of law, and order entered by the Commission on December 15, 2009, DBSI agreed to pay a penalty of $344,384.49 to the Commonwealth of Pennsylvania and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The findings of fact, conclusions of law, and order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $344,384.49 penalty imposed by the Commission is its pro-rata share of the total penalty amount. The order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the order. Without admitting or denying the allegations in the order, DBSI agreed to pay a penalty of $344,384.49 to the Commonwealth of Pennsylvania and to take certain measures with respect to current and former clients that purchased ARS before 2/13/2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-0140 CO 01/08/2010 Division of Securities Office of Secretary of State of Indiana ("The Division") The Registrant has not been the subject of this matter: Initiation date 1/8/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Ind. Code section 23-19-4-12(D)(13) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Ind. Code section 23-19-4-12(D)(9) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to findings of fact, conclusions of law, and consent order entered by the Division on January 8, 2010, DBSI agreed to pay a penalty of $36,504.51 to the Indiana Secretary of State Securities Division and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The findings of fact, conclusions of law, and consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $36,504.51 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations, DBSI agreed to pay a penalty of $36,504.51 to the Indiana Secretary of State Securities Division and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant KSC No. 2010-5641 01/08/2010 Office of the Securities Commissioner of the State of Kansas (the "Office") The Registrant has not been the subject of this matter: Initiation date 1/8/2010. The Office alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Office making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. K.S.A. 17-12A412(D)(13) allows the Office, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. K.S.A. 17-12A412 (D)(9) allows the Office, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Office on January 8, 2010, DBSI agreed to pay a penalty of $30,903.40 to the Office of the Kansas Securities Commissioner and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,903.40 penalty imposed by the Office is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $30,903.40 to the Office of Kansas Sec. Comm. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NC File No. 09SEC48 01/13/2010 Div. of Sec. Dept. of the Secretary of State, North Carolina ("The Division") The Registrant has not been the subject of this matter: Initiation date 1/13/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS.Without admitting or denying the allegations in the administrative order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. N.C.G.S. 78A-39(A)(2)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. N.C.G.S. 78A-39(A1)(2)(A) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative order entered by the Division on January 13, 2010, DBSI agreed to pay a penalty of $92,568.01 to the North Carolina Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $92,568.01 penalty imposed by the Division is its pro-rata share of the total penalty amount. The administrative order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the administrative order. Without admitting or denying the allegations in the administrative order DBSI agreed to pay a penalty of $92,568.01 to the No. Carolina Sec. of St. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Agency Case No. 2010-AH-002 01/11/2010 Dept. of Fin. Inst. Public Protection Cabinet of Kentucky ("The Department") The Registrant has not been the subject of this matter: Initiation date 1/11/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. KRS 292.330(13)(A)7 allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. KRS 292.330(13)(A)9A allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on January 11, 2010, DBSI agreed to pay a penalty of $355,386.70 to the Kentucky State Treasurer and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $355,386.70 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $355,386.70 to the Kentucky State Treasurer and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. 2005-0008 05/23/2005 The Commonwealth of Massachusetts Office of the Secretary of the Commonwealth The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The Commonwealth of Massachusetts Office of the Secretary of the Commonwealth Securities Division charged violations of Massachusetts General Laws Chapter 110A, the Massachusetts Uniform Securities Act, 203A and 204 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Commonwealth of Massachusetts Office of the Secretary of the Commonwealth Securities Division and to pay $87.5 million. The Commonwealth of Massachusetts Office of the Secretary of the Commonwealth Securities Division charged violations of Massachusetts General Laws Chapter 110A, the Massachusetts Uniform Securities Act, 203A and 204 in connection with research analyst work, supervision and production of emails. The matter was resolved on 05/23/2005, including $562,586 penalty paid to the Commonwealth of Massachusetts on 03/07/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the Commonwealth of Massachusetts Office of the Secretary of the Commonwealth and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. 1000048 05/16/2005 The State of Iowa Insurance Division, Securities Bureau The Registrant has not been the subject of this matter: In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Iowa Insurance Division, Securities Bureau charged violations of Iowa Code Section 502.412(4)(I)(2005), Iowa Code Section 502.412(M)(2005) and Iowa Administrative Code Section 191-50.3 in connection with research analyst work, supervision and production of emails. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Iowa Insurance Division, Securities Bureau and to pay $87.5 million. The State of Iowa Insurance Division, Securities Bureau charged violations of Iowa Code Section 502.412(4)(I)(2005), Iowa Code Section 502.412(M)(2005) and Iowa Administrative Code Section 191-50.3 in connection with research analyst work, supervision and production of emails. The matter was resolved on 05/16/2005, including $287,500 penalty paid to the State of Iowa on 05/11/2005. Without admitting or denying the allegations, DBSI agreed to an administrative consent order with the State of Iowa Insurance Division, Securities Bureau and to pay $87.5 million with certain offsets to be paid in related actions. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-024-09-CO07 01/13/2010 Department of Securities of the State of Arkansas ("The Department") The Registrant has not been the subject of this matter: Initiation date 1/13/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Ark. Code Ann. section 23-42-308(A)(2)(G) allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Ark. Code Ann. section 23-42-308(A)(2)(J) allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on January 13, 2010, DBSI agreed to pay a penalty of $35,781.78 ($3,578.17 to the Arkansas State Fund at the Investor Protection Trust and $32,203.61 to the Department) and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $35,781.78 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $35,781.78 and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 09-076 01/12/2010 Office of Securities, Dept. of Prof. and Fin. Reg. of Maine (the "Office") The Registrant has not been the subject of this matter: Initiation date 1/12/2010. The Office alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Office making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. 32 M.R.S.A. section 16412(4)(M) allows the Office, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. 32 M.R.S.A. section 16412(4)(I) allows the Office, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Office on January 12, 2010, DBSI agreed to pay a penalty of $37,407.91 to the Treasurer of the State of Maine and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008.The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $37,407.91 penalty imposed by the Office is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $37,407.91 to the Treasurer of the St. of Maine and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-10-04 01/14/2010 Division of Securities Office of the Sec. of St. of Missouri (the "Division") The Registrant has not been the subject of this matter: Initiation date 1/14/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS.Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 409.4-412(D)(13), RSMO allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 409.4-412(D)(13), RSMO allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on January 14, 2010, DBSI agreed to pay a penalty of $42,466.97 to the Missouri Securities Division and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $42,466.97 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $42,466.97 to the Missouri Securities Division and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No 10-6-14 01/20/2010 Division of Securities of the Dept. of Reg. Agen. Dept. of State of Colorado The Registrant has not been the subject of this matter: Initiation date 1/20/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. C.R.S. section 11-51-410(1)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. C.R.S. section 11-51-410(1)(G)(I) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on January 20, 2010, DBSI agreed to pay a penalty of $184,843.39 to the Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $184,843.39 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the findings and consent order, DBSI agreed to pay a penalty of $184,843.39 to the Division of Sec. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant E-2009-0066 01/26/2010 Division of Sec. of Dept. of State of Com. of Massachusetts ("The Division") The Registrant has not been the subject of this matter: Initiation date 1/26/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Mass. Gen. L. Ch. 110A. section 204(A)(2)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Mass. Gen. L. Ch. 110A. section 204(A)(2)(J) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative consent order entered by the Division on January 26, 2010, DBSI agreed to pay a penalty of $3,210,161.72 to the Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $3,210,161.72 penalty imposed by the Division is its pro-rata share of the total penalty amount. The administrative consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the findings and consent order, DBSI agreed to pay a penalty of $3,210,161.72 to the Division of Sec. and take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. S-09-0039 01/27/2010 Division of Finance and Corporate Securities, State of Oregon ("The Division") The Registrant has not been the subject of this matter: Initiation date 1/27/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the order assessing civil penalty and consent to entry of order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. ORS 59.205(2) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. ORS 59.205(13) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the order assessing civil penalty and consent to entry of order entered by the Division on January 27, 2010, DBSI agreed to pay a penalty of $40,298.80 to the State of Oregon and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The order assessing civil penalty and consent to entry of order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $40,298.80 penalty imposed by the Division is its pro-rata share of the total penalty amount. The order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations, DBSI agreed to pay a penalty of $40,298.80 to the State of Oregon and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No. 09-142 02/01/2010 Department of Securities of the State of Oklahoma ("The Department") The Registrant has not been the subject of this matter: Initiation date 2/1/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Oklahoma Securities Commission Rule 660:11-5-42 allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Oklahoma Securities Commission Rule 660:11-5-42 allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on February 1, 2010, DBSI agreed to pay a penalty of $37,407.91 to the Oklahoma Securities Department and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $37,407.91 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $37,407.91 to the Oklahoma Securities Department and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 03/05/2010 Department of Banking and Finance of the State of Nebraska ("The Department") The Registrant has not been the subject of this matter: Initiation date 3/5/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Neb. Rev. Stat. Section 8-1103(9)(A)(VII) allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Neb. Rev. Stat. Section 8-1103(9)(A)(XI) allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the findings of fact, conclusions of law, and consent order entered by the Department on March 5, 2010, DBSI agreed to pay a penalty of $74,086.10 to the Nebraska Department of Banking and Finance and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The findings of fact, conclusions of law, and consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $74,086.10 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the findings, DBSI agreed to pay a penalty of $74,086.10 to the Nebraska Dept. of Banking and Fin. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09-053-059 03/10/2010 Division of Securities of Dept. of Reg. and Lic. of New Mexico ("The Division") The Registrant has not been the subject of this matter: Initiation date 3/10/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. NMSA Section 58-13B-16A(2)(H) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. NMSA Section 58-13B-16A(2)(K) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on March 10, 2010, DBSI agreed to pay a penalty of $51,862.37 to the Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $51,862.37 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $51,862.37 to the Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 09090 03/11/2010 Div. of Sec. Off. of the Attny Gen. of the St. of So. Carolina ("The Division") The Registrant has not been the subject of this matter: Initiation date 3/11/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the administrative consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. The South Carolina Uniform Securities Act of 2005 allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. The South Carolina Uniform Securities Act of 2005 allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative consent order entered by the Division on March 11, 2010, DBSI agreed to pay a penalty of $33,252.25 to the Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $33,252.25 penalty imposed by the Division is its pro-rata share of the total penalty amount. The administrative consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the administrative consent order. Without admitting or denying the allegations in the admin. cons. order, on 3/11/10, DBSI agreed to pay a penalty of $33,252.25 to the Div. of Sec. and take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. SEC-2009-00074 04/16/2010 State Corporation Commission of the Commonwealth of Virginia (The "Commission") The Registrant has not been the subject of this matter: Initiation date 4/16/2010. The Commission alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Commission making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Commission Rules 21 VAC 5-20-280 A 3 and E 12 allow the Commission, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Commission Rules 21 VAC 5-20-260 A and B allow the Commission, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Commission on April 16, 2010, DBSI agreed to pay a penalty of $214,475.04 to the Treasurer of the Commonwealth of Virginia and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $214,475.04 penalty imposed by the Commission is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $214,475.04 to the Commonwealth of Virginia and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEU-2008-73 04/13/2010 Department of Commerce and Cons. Aff. of the State of Hawaii ("The Department") The Registrant has not been the subject of this matter: Initiation date 4/13/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. HRS Section 485-15(7) allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. HRS Section 485-15(10) allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on April 13, 2010, DBSI agreed to pay a penalty of $33,071.57 to the Hawaii Department of Commerce and Consumer Affairs - Compliance Resolution Fund, and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $33,071.57 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $33,071.57 to the Hawaii Department of Commerce and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09 04/09/2010 Division of Securities Off. of Sec. of St., State of Wyoming ("The Division") The Registrant has not been the subject of this matter: Initiation date 4/9/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. W.S. Section 17-4-106(A)(II)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. W.S. Section 17-4-106(B)(II) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on April 9, 2010, DBSI agreed to pay a penalty of $79,325.84 to the Wyoming Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $79,325.84 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $79,325.84 to the Wyoming Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. IC10-CAF-11 04/08/2010 State Securities Board of the State of Texas ("The Board") The Registrant has not been the subject of this matter: Initiation date 4/8/2010. The Board alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Board making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 115.10(B)(1) of the Board rules allows the Board, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 115.10(B)(1) of the Board rules allows the Board, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Board on April 8, 2010, DBSI agreed to pay a penalty of $827,886.15 to the Texas State Securities Board and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $827,886.15 penalty imposed by the Board is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $827,886.15 to the Texas State Securities Board and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09148(EX) 04/08/2010 Division of Securities Dept. of Fin. Inst. of St. of Wisconsin (The "Division") The Registrant has not been the subject of this matter: Initiation date 4/8/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Wis. Stats. Section 551.34(1)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Wis. Stats. Section 551.34(1)(J) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on April 8, 2010, DBSI agreed to pay a penalty of $44,454.46 to the Wisconsin Department of Financial Institutions and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $44,454.46 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $44,454.46 to the Wisconsin Dept. of Fin. Inst. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07 04/08/2010 Bureau of Securities of Dept. of Fin. of the State of Idaho ("The Department") The Registrant has not been the subject of this matter: Initiation date 4/8/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Idaho Code Section 30-14-412(D)(13) allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Idaho Code Section 30-14-412(D)(9) allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on April 8, 2010, DBSI agreed to pay a penalty of $30,000 to the Idaho Department of Finance and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $30,000 to the Idaho Department of Finance and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09-0225 05/10/2010 Div. of Sec. and Char. of Off. of Mississippi Sec. of State (the "Division") The Registrant has not been the subject of this matter: Initiation date 5/10/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Miss. Code Ann. Section 75-71-321(A)(F) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Miss. Code Ann. Section 75-71-321(B)(A) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on May 10, 2010, DBSI agreed to pay a penalty of $30,000 to the Mississippi Office of the Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $30,000 to the Mississippi Off. of Sec. of St. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-018 (SI-2008-010) 05/10/2010 Div. of Sec. of Dept. of Comm. and Ins. of St. of Tennessee (the "Division") The Registrant has not been the subject of this matter: Initiation date 5/10/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Tenn. Code Ann. Section 48-2-112(A)(2)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Tenn. Code Ann. Section 48-2-112(A)(2)(J) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on May 10, 2010, DBSI agreed to pay a penalty of $468,512.16 to the Tennessee Department of Commerce and Insurance and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $468,512.16 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $468,512.16 to the Tenn. Dept. of Comm. and Ins. and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. OFI-2010-006 06/07/2010 Louisiana Office of Fin. Inst., Commissioner of Securities (the "Commissioner") The Registrant has not been the subject of this matter: Initiation date 6/7/2010. The Commissioner alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Commissioner making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. LSA-R.S. 51:712A(2) allows the Commissioner to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. LSA-R.S. 51:712A allows the Commissioner to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Commissioner on June 7, 2010, DBSI agreed to pay a penalty of $30,000 to the Louisiana Commissioner of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Commissioner is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $30,000 to the Louisiana Comm. of Securities and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 67154 06/14/2010 Div. of Securities of the Office of Sec. of State, St. of Iowa ("The Division") The Registrant has not been the subject of this matter: Initiation date 6/14/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Iowa Code Section 502.412(4)(M) (2009) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Iowa Code Section 502.412(4)(I) (2009) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on June 14, 2010, DBSI agreed to pay a penalty of $31,445.45 to the Iowa Insurance Division and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $31,445.45 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $31,445.45 to the Iowa Insurance Division and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. CO-10-7799-S 08/09/2010 Department of Banking of the State of Connecticut ("The Department") The Registrant has not been the subject of this matter: Initiation date 8/9/2010. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 36B-15(A)(2)(H) of the Connecticut Uniform Securities Act allows the Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 36B-31-6(F)(B) of the regulations of Connecticut state agencies enacted pursuant to the Connecticut Uniform Securities Act allows the Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Department on August 9, 2010, DBSI agreed to pay a penalty of $343,481.09 to the Treasurer of the State of Connecticut and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $343,481.09 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $343,481.09 to the Treas. of St. of Connecticut and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 08-10 08/12/2010 Div. of Banking and Ins. Off. of Lt. Gov. of US Virgin Islands ("The Division") The Registrant has not been the subject of this matter: Initiation date 8/12/2010. There were no affected investors from the Virgin Islands. The Division stated that it had jurisdiction over this matter pursuant to Chapter 23, 9VIC, Sections 602(1) and 661(A). The Division found that the relief was appropriate and in the public interest. DBSI did not admit or deny the allegations in the administrative consent order. There were no affected investors from the Virgin Islands. The Division stated that it had jurisdiction over this matter pursuant to Chapter 23, 9VIC, Sections 602(1) and 661(A). The Division found that the relief was appropriate and in the public interest. Pursuant to the administrative consent order entered by the Division on August 12, 2010, DBSI agreed to pay a penalty of $30,000 to the Virgin Islands Division of Banking and Insurance. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. DBSI did not admit or deny the allegations in the administrative consent order, and agreed to pay a penalty of $30,000 to the Virgin Islands Division of Banking and Insurance. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Securities Division No. 2009-0311 09/22/2010 Division of Securities of Office of Attny General of Maryland ("The Division") The Registrant has not been the subject of this matter: Initiation date 9/22/2010. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 11-412(A)(7) of the Maryland Securities Act allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 11-412(A)(7) of the Maryland Securities Act allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on September 22, 2010, DBSI agreed to pay a penalty of $718,212.94 to the Maryland Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $718,212.94 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the findings of fact and consent order, DBSI agreed to pay $718,212.94 to the Maryland Div. of Sec. and take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 10-15-S 12/23/2010 Dept of Commerce, Community & Econ Dev, Div of Bnkng & Securities, St of Alaska The Registrant has not been the subject of this matter: Initiation date 12/23/2010. The Department of Commerce, Community, and Economic Development, Division of Banking and Securities of the State of Alaska (the "Division") alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the findings of fact, conclusions of law, and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. A.S. 45.55.060(A)(7) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) In connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. A.S. 45.55.060(B)(1) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative consent order entered by the Division on December 23, 2010, DBSI agreed to pay a penalty of $30,000 to the State of Alaska and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $30,000 penalty imposed by the Division is its pro-rata share of the total penalty amount. The administrative consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the findings of fact and consent order, DBSI agreed to pay a penalty of $30,000 to Alaska and to take certain measures with respect to current and former clients that purchased ARS before 2/13/2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0441-S-07/09 02/01/2011 Office of Financial Regulation of the State of Florida (the "Office") The Registrant has not been the subject of this matter: Initiation date: 2/1/2011. The Office alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent agreement and final order, DBSI consented to the Office making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 517.161 (1)(H) of the Florida statutes and Rule 69W-600.013(1)(H)(1) of the Florida Administrative Code allows the Office, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 517.161(1)(H) of the Florida statutes and Rule 69W-600.013(1)(H)(1) of the Florida Administrative Code allows the Office, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent agreement and final order entered by the Office on February 1, 2011, DBSI agreed to pay a penalty of $509,165.32 to the Department of Financial Services of the State of Florida and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent agreement and final order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $509,165.32 penalty imposed by the Office is its pro-rata share of the total penalty amount. The consent agreement and final order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Pursuant to the consent agree. and final 2/1/11 order, DBSI agreed to pay a penalty of $509,165.32 to the Dept. of Fin. Serv. of the St. of Florida and to take certain measures with respect to current and former clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 11-013 03/21/2011 Division of Securities of the Dept. of Commerce of St. of Ohio ("The Division") The Registrant has not been the subject of this matter: Initiation date: 3/21/2011. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. ORC Sections 1707.19(A)(4),(9) allow the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. ORC Sections 1707.19(A)(4),(9) and Ohio Administrative Code Rule 1301:6-3-19(B)(9) allow the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the consent order entered by the Division on March 21, 2011, DBSI agreed to pay a penalty of $110,583.61 to the Ohio Division of Securities' Investor Education and Enforcement Expense Fund and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $110,583.61 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the consent order, DBSI agreed to pay a penalty of $110,583.61 to the Ohio Div. of Sec. Inv. Ed. and Enf. Exp. Fd. and to take certain measures with respect to clients that purchased ARS before 2/13/2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. SB-CO-10-11 05/11/2011 Department of Insurance, Sec. and Bank. District of Columbia ("The Department") The Registrant has not been the subject of this matter: Initiation date: 5/11/2011. The Department alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the administrative consent order, DBSI consented to The Department making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. D.C. Code section 31-5602.07(A)(9) allows The Department, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. D.C. Code section 31-5602.07(A)(12) allows The Department, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative consent order entered by The Department on May 11, 2011, DBSI agreed to pay a penalty of $125,399.43 to the DC Department of Insurance, Securities and Banking and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $125,399.43 penalty imposed by The Department is its pro-rata share of the total penalty amount. The administrative consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the administrative consent order. Without admitting or denying the allegations in the administrative consent order, DBSI agreed to pay a penalty of $125,399.43 to the DC Dept. of Ins., Sec. and Bank. and take certain measures with respect to clients that purchased ARS before 2/13/2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ENSC-10059 09/21/2011 Division of Securities of the Off. of Sec. of St. of Georgia ("The Division") The Registrant has not been the subject of this matter: Initiation date: 9/21/2011. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the administrative consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Section 10-5-4 (A)(8) of the Georgia Securities Act of 1973 allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Section 10-5-4(A)(11) of the Georgia Securities Act of 1973 allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the administrative consent order entered by the Division on September 21, 2011, DBSI agreed to pay a penalty of $146,719.76 to the Georgia Office of the Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The administrative consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $146,719.76 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the administrative consent order, DBSI agreed to pay a penalty of $146,719.76 to the Georgia Office of Sec. of St. and to take certain measures with respect to clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. SD-11-0088 10/27/2011 Division of Securities of the Dept. of Commerce of St. of Utah ("The Division") The Registrant has not been the subject of this matter: Initiation date 10/27/2011. The Division alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS"), and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the stipulation and consent order, DBSI consented to the Division making the following conclusions of law: (1) in connection with (I) the misrepresentation of ARS to clients, (II) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (III) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business. Utah Code Ann. Section 61-1-6(2)(A)(II)(G) allows the Division, through its administrator, to take action against DBSI if it has engaged in unethical or dishonest practices in the securities business; and (2) in connection with the failure to (I) provide adequate training to agents concerning ARS, (II) create and maintain adequate written supervisory procedures concerning ARS, (III) ensure accurate disclosure of ARS characteristics to clients by its agents, and (IV) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct. Utah Code Ann. Section 61-1-6(2)(A)(II)(J) allows the Division, through its administrator, to take action against DBSI if it has failed to reasonably supervise its representatives or employees. Pursuant to the stipulation and consent order entered by the Division on October 27, 2011, DBSI agreed to pay a penalty of $188,095.65 to the Utah Division of Securities and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The stipulation and consent order finalized the terms of a settlement that had been reached in August 2008 between DBSI's parent and NASAA and that resulted in a term sheet (the "Term Sheet"). The Term Sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $188,095.65 penalty imposed by the Division is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedure for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Without admitting or denying the allegations in the stipulation and consent order, DBSI agreed to pay a penalty of $188,095.65 to the Utah Division of Securities and to take certain measures with respect to clients that purchased ARS before 2/13/08. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 1100301 07/16/2012 Illinois Secretary of State, Securities Department (The "Department") The Registrant has not been the subject of this matter: Date Initiated: 7/16/2012. The Department alleged that Deutsche Bank Securities Inc. ("DBSI") (1) engaged in dishonest and unethical conduct in the securities business with respect to the marketing and sale of auction rate securities ("ARS") and (2) failed to reasonably supervise its agents with respect to the marketing and sale of ARS. Without admitting or denying the allegations in the consent order, DBSI consented to the Department making the following conclusions of law: (1) in connection with (i) the misrepresentation of ARS to clients, (ii) the failure to adequately disclose to clients the effect of DBSI's role as underwriter and broker-dealer for ARS issues, and (iii) the use of supporting bids to artificially prevent failed ARS auctions and failing to adequately disclose the practice to clients, DBSI engaged in dishonest and unethical conduct in the securities business, in violation of section 8.E(1)(b) of the Illinois Securities Act ("Act"); and (2) in connection with the failure to (i) provide adequate training to agents concerning ARS; (ii) create and maintain adequate supervisory procedures concerning ARS; (iii) ensure accurate disclosure of ARS characteristics to clients by its agents; and (iv) ensure adequate disclosure of conflicts of interest concerning ARS to clients by its agents, DBSI failed to reasonably supervise, and establish and enforce procedures necessary to detect and prevent such conduct, in violation of its duties under section 8.E(1)(e)(i) of the act. The activities cited in the consent order are grounds, pursuant to the act, for the initiation of administrative proceedings, and, pursuant to the act, to impose such other remedial measures as may be necessary in the public interest. Pursuant to the consent order entered by the Department on July 16, 2012, DBSI agreed to pay a penalty of $535,364.03 to the Illinois Secretary of State and to take certain measures with respect to current and former clients that purchased ARS before February 13, 2008. The consent order finalized the terms of a settlement that had been reached in august 2008 between DBSI's parent and NASAA that resulted in a term sheet (the "term sheet"). The term sheet required a total penalty of $15,000,000 to NASAA member jurisdictions, and the $535,364.03 penalty imposed by the Department is its pro-rata share of the total penalty amount. The consent order requires that DBSI offer to purchase at par certain ARS from eligible investors; reimburse eligible investors that sold ARS below par; participate in a special arbitration procedures for consequential damages claims by eligible investors; work to provide liquidity solutions for institutional investors not part of the ARS buy back; and provide other relief as described in the consent order. Pursuant to the consent order entered by the Dept., without admitting or denying the allegations, DBSI agreed to pay a penalty of $535,364.03 and to take certain measures with respect to current and former clients that purchased ARS before Feb. 13, 2008. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Reference #150018 04/23/2015 Financial Conduct Authority ("FCA") The Registrant has not been the subject of this matter: Date Initiated: 4/23/2015. Deutsche Bank AG was found to have violated FCA Business Principles 3, 5, 11 - Management and Control; - Market Conduct, and relations with regulators in relation to conduct in connection with Libor and Euribor submissions and for misleading the FCA during the course of its review. Without admitting or denying the allegation, DBAG agreed to pay the fine of $226,800,000.00 (GBP). The fine was paid on 5/5/15. DBAG was ordered to pay a fine of $226,800,000.00 (GBP). The fine was paid on 5/5/15. DBAG was ordered to pay a fine of $226,800,000.00 (GBP). The fine was paid on 5/5/15. Deutsche Bank AG (DBAG) including DBAG (NY Branch), a Control affiliate of the Registrant None 11/03/2015 New York State Department of Financial Services and Federal Reserve The Registrant has not been the subject of this matter: Date Initiated: 11/3/2015. The FED investigated whether DBAG was intentionally altering or removing information identifying U.S.-sanctioned parties in USD wire transfer instructions sent to or through the United States, or improperly using cover payments, in order to avoid possible rejection or blocking of those transfers by U.S. banks, in violation of U.S. sanctions and other laws and regulations. The NYSDFS investigated whether DBAG was intentionally altering or removing information identifying U.S.-sanctioned parties in USD wire transfer instructions sent to or through the United States, or improperly using cover payments, in order to avoid possible rejection or blocking of those transfers by U.S. banks, in violation of New York State laws, including laws requiring financial institutions to maintain accurate books and records. DBAG agreed to pay $258 million in penalties and comply with remedial measures to improve compliance with U.S. sanctions and anti-money laundering laws. The FED penalty was paid on November 3, 2015. The NYSDFS penalty was paid on November 5, 2015. 1-year monitorship---Termination of six non-U.S. based employees---Prohibition on three non-U.S. based employees from having responsibilities related to USD processing/U.S. operations/compliance---No rehire provision for 10 former employees. DBAG agreed to pay $258 million in penalties and comply with remedial measures to improve compliance with U.S. sanctions and anti-money laundering laws. The FED penalty was paid on November 3, 2015. The NYSDFS penalty was paid on November 5, 2015. DBAG agreed to pay $258 million in penalties and comply with remedial measures to improve compliance with U.S. sanctions and anti-money laundering laws. The FED penalty was paid on November 3, 2015. The NYSDFS penalty was paid on November 5, 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Agreement #16-143 12/15/2016 Attorney General of the State of New York The Registrant has not been the subject of this matter: Date Initiated: 12/15/2016. The settlement agreement between the NYAG and Deutsche Bank Securities Inc. (DBSI") relates to one of the DBSI's "Smart Order Routers" which routes primarily to dark pools. The NYAG alleged that a component of the smart order router "was not fully operating" from January 2012 to February 2014 due to a "coding error." The NYAG also alleged certain deficiencies in DBSI's Form ATS filings. The disposition of the action is final as of the date of the settlement agreement, December 15, 2016. Monetary penalty of $18,500,000 was paid on January 3, 2017. The settlement agreement also requires DBSI to "comply with, and cease and desist from engaging in any actions in further violation of Federal and New York state Securities laws." The disposition of the action is final as of the date of the settlement agreement, December 15, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-06-49 11/03/2006 State of Missouri Commissioner of Securities The Registrant has not been the subject of this matter: Initiation date: 10/26/2006. In the item noted below, the DBSI agreements include, undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI agreed to pay: (I) $50 million, offset by $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. The State of Missouri Commissioner of Securities charged DBSI with violations of Sections 409.204(A)(2)(G) and 409.204(A)(2)(J) of the Missouri revised statutes in connection with alleged failure to ensure that analysts who issued research were adequately insulated from pressures and influences from covered companies and investment banking and alleged failure 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. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative order by the Commissioner of Securities. DBSI was subject to a cease and desist order, and paid $495,785 to the Secretary of State of the State of Missouri on 10/27/06. This amount is part of a global settlement previously disclosed by DBSI on 10/13/04. Additionally, under the global settlement, DBSI agreed to undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. This amount is part of a global settlement disclosed by DBSI on 10/13/04. The matter was resolved on 11/03/2006. Without admitting or denying the allegations, DBSI agreed to the entry of an administrative order by the Commissioner of Securities. DBSI paid $495,785 to the Secretary of State of the State of Missouri on 10/27/06. Deutsche Bank AG (DBAG) including DBAG (NY Branch), a Control affiliate of the Registrant N/A 04/23/2015 New York State Department of Financial Services The Registrant has not been the subject of this matter: Date Initiated: 4/23/2015. Deutsche Bank AG including Deutsche Bank AG New York Branch, were found to have engaged in unsafe and unsound banking practices and agreed to pay $600 million, ordered to terminate the employment of seven individuals (six employees based in the UK and one based in Frankfurt) and to install a monitor for a period of two years, which will oversee the Bank's compliance programs. Without admitting or denying the allegations, DBAG and DBAG (NY Branch) agreed to pay the fine of $600,000,000.00. The fine was paid on 5/1/15. DBAG was ordered to pay a fine of $600,000,000.00. The fine was paid on 5/1/15. DBAG was ordered to pay a fine of $600,000,000.00. The fine was paid on 5/1/15. Deutsche Bank AG (DBAG) including DBAG (NY Branch), a Control affiliate of the Registrant N/A 06/20/2018 New York State Department of Financial Services On June 20, 2018, the New York State Department of Financial Services ("DFS"), DBAG and DBAG's New York Branch (collectively, "the bank") entered into a consent order ("order"). although the order recognized the bank's "extraordinary cooperation" with the DFS and institution of "wide-ranging reforms to address improper conduct in its fx trading business", the DFS found that the bank "fail[ed] to implement effective controls over its fx business" to ensure that the bank's fx activities complied with safe and sound banking practices and applicable internal policies, which prevented the bank from detecting and addressing improper conduct by certain of its fx traders and salespersons from 2007 to 2013. As a result of this conduct, the DFS found that the bank engaged in unsafe, unsound, and improper conduct. the bank consented to the entry of the order on June 20, 2018 by the DFS, pursuant to which the bank: (a) shall pay a civil monetary penalty of $205,000,000, which the bank paid on June 22, 2018; (b) shall not rehire or retain certain former employees involved in the misconduct described in the order; (c) shall submit written plans to improve senior management oversight and the compliance risk management program, an enhanced written internal controls and compliance program, and an enhanced written internal audit program to the DFS within 90 days of the order; (d) for sub-section c, shall promptly implement the approved plans and programs within 10 days of approval by the DFS and thereafter fully comply with them; and (e) shall submit written progress reports to the DFS at the point of 12 and 24 months after execution of the order. See above. Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1219988 08/31/2004 The California Department of Corporations In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant N/A 01/30/2017 Financial Conduct Authority ("FCA") The Registrant has not been the subject of this matter: Date Initiated: 1/30/2017. On January 30, 2017, the Financial Conduct Authority ("FCA") entered a final notice under Principle 3 (Management and Control) and Senior Management Arrangements, Systems and Controls (SYSC) Rules 6.1.1 R and 6.3.1 R between January 1, 2012 and December 31, 2015 (the relevant period). Specifically, the FCA found that with respect to DBAG, the AML control framework was substantially inadequate, and the risks raised were highlighted by certain trading arranged by Deutsche Bank's Russia based subsidiary (DB Moscow) and booked to Deutsche Bank's trading books in London. The FCA found that the way these trades were conducted in combination with their scale and volume were highly suggestive of financial crime. The FCA found that the suspicious securities trades, which it referred to as "Mirror Trades," were used by customers of Deutsche Bank and DB Moscow that were connected to each other to transfer more than USD 6 billion from Russia, through Deutsche Bank in the UK, to overseas bank accounts. The orders for both sides of the mirror trades were received by DB Moscow, which executed both sides at the same time. The FCA found that DBAG breached Principle 3 and SYSC Rules 6.1.1 R and 6.3.1 R in that, during the relevant period, in its Corporate Banking & Securities division business, (1)its Customer Due Diligence ("CDD") and Enhanced Due Diligence ("EDD") was inadequate in that it failed to obtain sufficient information about its customers to inform the risk assessment process and to provide a basis for transaction monitoring; (2) its culture failed to instill a sense of responsibility in the front office business for the identification and management of non-financial risks, particularly in the London front office, which failed to appreciate that it was ultimately responsible for Deutsche Bank's KYC obligations; (3) it used flawed AML customer and country risk rating methodologies which meant that customers were assigned inappropriate risk ratings; (4) its AML policies and procedures were deficient; (5) it AML IT infrastructure was inadequate and failed to provide a single authoritative repository of KYC information; (6) it lacked automated AML systems for detecting suspicious trades and lacked an effective systems for monitoring money flows associated with transactions; and (7) it failed to provide adequate oversight of trades booked in the UK by the Moscow front office as well as other Non-UK transactions. DBAG consented to the entry of the final notice on January 30, 2017 by the FCA, pursuant to which DBAG shall pay a civil monetary penalty of 163,076,224 (pound sterling), which DBAG paid on February 1, 2017. The Order required DBAG to pay a financial penalty in the amount of 163,076,224 (pound sterling), which the bank paid on February 1, 2017. DBAG consented to the entry of the final notice on January 30, 2017 by the FCA, pursuant to which DBAG shall pay a civil monetary penalty of 163,076,224 (pound sterling), which DBAG paid on February 1, 2017. Deutsche Bank AG (DBAG) including DBAG (NY Branch), a Control Affiliate of the Registrant N/A 01/30/2017 New York State Department of Financial Services ("DFS") The Registrant has not been the subject of this matter: Date Initiated: 1/30/2017. On January 30, 2017, the New York State Department of Financial Services ("DFS"), DBAG and DBAG's New York Branch entered into a Consent Order under New York Banking Law Sections 33, 44 and 44-A. Specifically, the DFS found that DBAG suffered from serious compliance deficiencies that allowed certain bank traders and offshore entities to improperly and covertly transfer more than $10 billion out of Russia, by using the services of Deutsche Bank operations in Moscow, London and New York to convert rules into dollars through security trades that had no discernable economic purpose. The DFS found that DBAG and DBAG's New York Branch conducted their banking business in an unsafe and unsound manner, in violation of New York Banking Laws 44 and 44-A, failed to maintain an effective money laundering program, in violation of 3 N.Y.C.R.R. Section 116.2, and failed to maintain and make available true and accurate books, accounts and records reflecting all transactions and actions, in violation of New York Banking Law Section 200-C. DBAG and DBAG's New York Branch consented to the entry of the Order on January 30, 2017 by the DFS, pursuant to which DBAG and DBAG's New York Branch: (a) shall pay a civil and monetary penalty of $425 million, which DBAG paid on February 3, 2017; and (b) engage an independent monitor within 60 days of the Order to conduct a comprehensive review of existing BSA/AML compliance programs, policies and procedures in place at the bank that pertain to or affect activities conducted by or through (a) Deutsche Bank Trust Company Americas and (b) DBAG's New York Branch recommend corrective actions, and oversee the implementation of corrective actions the DFS deems necessary. The Order requires DBAG to engage an independent monitor with 60 days of the Order to conduct a comprehensive review of existing Bank Secrecy Act ("BSA")/Anti-Money Laundering ("AML") compliance programs, policies and procedures in place at the bank that pertain to or affect activities conducted by or through (a) Deutsche Bank Trust Company Americas and (b) DBAG's New York Branch. The independent monitor must submit to DBAG a written report on its findings and recommendations. Sixty days thereafter, DBAG must submit to the DFS a written action plan to improve and enhance its BSA/AML compliance programs, after which the DFS will determine which recommendations DBAG should implement. The independent monitor will thereafter oversee the implementation of the recommendations, assess DBAG's compliance with the corrective measures, and submit additional reports or recommendations as necessary. The Order required DBAG to pay a civil money penalty in the amount of $425 million, which the Firm paid on February 3, 2017. DBAG and DBAG's New York Branch consented to the entry of the Order on January 30, 2017 by the DFS, pursuant to which DBAG and DBAG's New York Branch: (a) shall pay a civil monetary penalty of $425 million, which DBAG paid on February 3, 2017. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: CO-2005-0011 03/31/2005 The Alabama Securities Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: S-03578A-05-0000 03/01/2005 The Arizona Corporation Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003E052 03/28/2005 The Kansas Office of the Securities Commissioner In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250895 03/15/2005 The Kentucky Office of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-045-CON 03/16/2005 The Maine Office of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250903 04/01/2005 The Minnesota Department of Commerce In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250878 02/17/2005 The Nebraska Department of Banking and Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 04-050-IG 03/31/2005 The North Carolina Department of the Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : EN-10522 03/28/2005 The Commissioner of Securities of the State of Georgia In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250894 03/24/2005 The Ohio Department of Commerce, Division of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-05-0003 03/17/2005 TheOregon Department of Consumer and Business Services, Division of Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003-04-50 02/23/2005 Pennsylvania Securities Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-94 03/22/2005 The Rhode Island Department of Business Regulation, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 5-004-S 03/05/2005 The Vermont Department of Banking, Insurance, Securities and Health Care In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-04-251-04-CO01 03/25/2005 The Washington Department of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-05026(LX) 03/29/2005 The Wisconsin Department of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : SEC-2003-00023 03/30/2005 The Commonwealth of Virginia State Corporation Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-H-16 06/14/2005 The Colorado Division of Securities, Department of Regulatory Agencies. In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0152-S-8/04 05/23/2005 The State of Florida Office of Financial Regulation In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No.1000048 05/16/2005 The State of Iowa Insurance Division, Securities Bureau In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No.2005-0008 05/23/2005 The Commonwealth of Massachusetts Office of the Secretary of the Commonwealth In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-05-023-05-C001 06/23/2005 The Arkansas Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. C05-V-005 07/01/2005 The Commonwealth of Puerto Rico Commissioner of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2005-7-11 07/15/2005 The Idaho Department of Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1266565 07/11/2005 The New Jersey Office of the Attorney General, Division of Consumer Affairs In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 05-3-1 08/22/2005 The State of Delaware, Department of Justice, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : SEC.CO 05-02 06/21/2005 The District of Columbia Department of Insurance, Securities and Banking In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No.105-185-JN 08/11/2005 The Nevada Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi. In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-02 07/26/2005 The State of Wyoming Secretary of State In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-0021 CO 08/11/2005 The Indiana Office of the Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 02-11-06-S 07/01/2005 The Office of the Mississippi Secretary of State, Business Regulation In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1273373 08/26/2005 The State of North Dakota Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1274034 08/25/2005 The Utah Division of Securities, Department of Commerce In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1276422 09/30/2005 The West Virginia Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : SEU-2005-036-B 10/17/2005 The State of Hawaii Department of Commerce and Consumer Affairs In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-17-05-144I 11/02/2005 The Montana State Auditor's Office Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 05-010-M 11/04/2005 The State of Michigan Office of Financial and Insurance Services In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : CO-2005-7083-S 12/07/2005 The State of Connecticut Department of Banking In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 04CV06909 01/31/2006 The State of South Dakota Division of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 06025 06/16/2006 The Securities Division of the Attorney General of the State of South Carolina In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 05-005 06/26/2006 The Tennessee Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : IC06-CDO-07 05/31/2006 The Texas State Securities Board In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE NO. 0600247 07/20/2006 The Illinois Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1328168 10/19/2006 The State of Louisiana Office of Financial Institutions Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No.05-058 10/12/2006 The State of Oklahoma Department of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Scudder Investor Services, Inc. (SISI), a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: IC05-CAF-11 04/22/2005 State of Texas Securities Commissioner The Registrant has not been the subject of this matter: Scudder Investments Service Company, formerly known as Kemper Service Company ("KSvC"); Scudder Distributors, Inc., formerly known as Kemper Distributors Inc. ("KDI"); Deutsche Investment Management Americas Inc., formerly, Scudder Kemper Investments, Inc. ("Scudder Kemper"): and SISI are wholly owned, indirect and/or direct subsidiaries of Deutsche Bank Americas Holding Corp. Initiation date: April 22, 2005. SISI did not timely submit to the State of Texas Securities Commissioner the information concerning the change in its designated officer as reflected on its certificate of registration, with the fee. The current status is closed on April 22, 2005. SISI paid a monetary fine of $700. Pursuant to Section 14.A(6) of the Texas Securities Act, SISI was thereby reprimanded. The current status is closed on April 22, 2005. SISI paid a monetary fine of $700. Pursuant to Section 14.A(6) of the Texas Securities Act, SISI was thereby reprimanded. Deutsche Bank Securities Inc. (DBSI) Deutsche Investment Management Americas Inc. (DIMA) and Deutsche Asset Management, Inc. (DAMI), Affiliates Occurrence 1337345 01/31/2007 NYAG In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Investment Management Americas, Inc. (DIMA) and Deutsche Asset Management Inc. (DAMI), Control Affiliates of the Registrant Occurrence 1339522 01/04/2007 Illinois Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: Securities Division No. 2002-0894 01/30/2007 Securities Commissioner of Maryland In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-06-49 11/03/2006 State of Missouri Commissioner of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1339443 12/01/2006 Attorney General of the State of New York In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Morgan Grenfell Inc.(DMGI), a Control Affiliate of the Registrant Occurrence 182248 04/02/1996 State of Florida Department of Banking and Finance The Registrant has not been the subject of this matter: Initiation date: March 31, 1995. The State of Florida Department of Banking and Finance, Division of Securities and Investor Protection alleged violation of Section 517.12(5) in that DMGI's Florida branch office was not registered with the Florida Department of Banking and Finance, Division of Securities and Investor Protection because of failure to timely renew the Florida branch office application before March 31, 1995. The current status is: settled on 4/2/96. Without admitting or denying violation of Section 517.12(5) of the Florida Statutes, DMGI agreed to pay a fine of $16,500. Settled on 4/2/96. Without admitting or denying violation of Section 517.12(5) of the Florida Statutes, DMGI agreed to pay a fine of $16,500. Deutsche Bank AG (London), a Control Affiliate of the Registrant Occurrence 1463434 06/01/2009 London Stock Exchange ("LSE") The Registrant has not been the subject of this matter: Initiation date 4/22/2009. LSE alleged that Deutsche Bank AG quoted prices on an ETF that were half the value of that last traded. As a result the ETF was suspended and the closing auction delayed. DB London accepted the fine and has proactively developed and implemented a new quoting system with more sophisticated logic to prevent similar violations. The fine imposed was 25,000 GBP. The fine imposed was 25,000 GBP. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NY Investor Protection Bureau Action 6/3/09 06/03/2009 Attorney General of the State of New York, Investor Protection Bureau ("NYAG") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEC-2009-39 08/03/2009 Montana Securities Department ("Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant I09-181 08/03/2009 Securities Division, Office of the Secretary of State, Nevada ("the Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant S-03578A-09-0314 08/20/2009 Arizona Corporation Commission ("Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. CO-2009-0037 11/05/2009 Alabama Securities Commission ("The Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 11/06/2009 North Dakota Securities Department ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 09-7-1 11/05/2009 Division of Securities, Dept. of Justice, State of Delaware ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 90-2525 11/23/2009 Division of Securities, Office of State Auditor, West Virginia (The "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/01/2009 Minnesota Department of Commerce, Market Assurance Division ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/02/2009 Michigan Office of Fin. & Ins. Reg. of Dept. of Energy, Labor, and Econ. Growth In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-195-09-CO01 12/01/2009 State of Washington Division of Securities, Dept. of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/04/2009 Office of Commissioner of Financial Institutions, Commonwealth of Puerto Rico In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07-10 12/15/2009 Commission of Securities of the Commonwealth of Pennsylvania ("The Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-0140 CO 01/08/2010 Division of Securities Office of Secretary of State of Indiana ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant KSC No. 2010-5641 01/08/2010 Office of the Securities Commissioner of the State of Kansas (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Agency Case No. 2010-AH-002 01/11/2010 Dept. of Fin. Inst. Public Protection Cabinet of Kentucky ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NC File No. 09SEC48 01/13/2010 Div. of Sec. Dept. of the Secretary of State, North Carolina ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-024-09-CO07 01/13/2010 Department of Securities of the State of Arkansas ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 09-076 01/12/2010 Office of Securities, Dept. of Prof. and Fin. Reg. of Maine (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-10-04 01/14/2010 Division of Securities Office of the Sec. of St. of Missouri (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No 10-6-14 01/20/2010 Division of Securities of the Dept. of Reg. Agen. Dept. of State of Colorado In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant E-2009-0066 01/26/2010 Division of Sec. of Dept. of State of Com. of Massachusetts ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. S-09-0039 01/27/2010 Division of Finance and Corporate Securities, State of Oregon ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No. 09-142 02/01/2010 Department of Securities of the State of Oklahoma ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NJ Bureau of Securities Action 6/3/09 06/03/2009 Bureau of Securities, State of New Jersey ("NJ Bureau of Securities") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 03/05/2010 Department of Banking and Finance of the State of Nebraska ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09-053-059 03/10/2010 Division of Securities of Dept. of Reg. and Lic. of New Mexico ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 09090 03/11/2010 Div. of Sec. Off. of the Attny Gen. of the St. of So. Carolina ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. SEC-2009-00074 04/16/2010 State Corporation Commission of the Commonwealth of Virginia (The "Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEU-2008-73 04/13/2010 Department of Commerce and Cons. Aff. of the State of Hawaii ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09 04/09/2010 Division of Securities Off. of Sec. of St., State of Wyoming ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. IC10-CAF-11 04/08/2010 State Securities Board of the State of Texas ("The Board") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09148(EX) 04/08/2010 Division of Securities Dept. of Fin. Inst. of St. of Wisconsin (The "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07 04/08/2010 Bureau of Securities of Dept. of Fin. of the State of Idaho ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-018 (SI-2008-010) 05/10/2010 Div. of Sec. of Dept. of Comm. and Ins. of St. of Tennessee (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09-0225 05/10/2010 Div. of Sec. and Char. of Off. of Mississippi Sec. of State (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. OFI-2010-006 06/07/2010 Louisiana Office of Fin. Inst., Commissioner of Securities (the "Commissioner") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 67154 06/14/2010 Div. of Securities of the Office of Sec. of State, St. of Iowa ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. CO-10-7799-S 08/09/2010 Department of Banking of the State of Connecticut ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 08-10 08/12/2010 Div. of Banking and Ins. Off. of Lt. Gov. of US Virgin Islands ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Securities Division No. 2009-0311 09/22/2010 Division of Securities of Office of Attny General of Maryland ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 10-15-S 12/23/2010 Dept of Commerce, Community & Econ Dev, Div of Bnkng & Securities, St of Alaska In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0441-S-07/09 02/01/2011 Office of Financial Regulation of the State of Florida (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 11-013 03/21/2011 Division of Securities of the Dept. of Commerce of St. of Ohio ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. SB-CO-10-11 05/11/2011 Department of Insurance, Sec. and Bank. District of Columbia ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ENSC-10059 09/21/2011 Division of Securities of the Off. of Sec. of St. of Georgia ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. SD-11-0088 10/27/2011 Division of Securities of the Dept. of Commerce of St. of Utah ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 1100301 07/16/2012 Illinois Secretary of State, Securities Department (The "Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Reference #150018 04/23/2015 Financial Conduct Authority ("FCA") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG) including DBAG (NY Branch), a Control Affiliate of the Registrant N/A 04/23/2015 New York State Department of Financial Services In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG) (New York Branch), a Control Affiliate of the Registrant None 11/03/2015 New York State Department of Financial Services and Federal Reserve In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Agreement #16-143 12/15/2016 Attorney General of the State of New York In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 17-009-B-FB; 17-009-CMP-FB 04/20/2017 Board of Governors of the Federal Reserve System The Registrant has not been the subject of this matter: Date Initiated: 4/20/2017. On April 20, 2017, the Board of Governors of the Federal Reserve System and DBAG entered into a Consent Order pursuant to Section 8 of the Federal Deposit Insurance Act (12 U.S.C. 1818) for failure to comply with Section 13 of the Bank Holding Company Act of 1956 (12 U.S.C. 1851) and the regulations thereunder (the "Volcker Rule"). Specifically, the Federal Reserve determined that, as a result of the deficiencies identified in the Order, DBAG had not implemented a compliance program reasonably designed to ensure and monitor compliance with Volcker Rule requirements and had engaged in unsafe or unsound banking practices and violated provisions of the Volcker Rule. DBAG consented to the entry of the Order on April 20, 2017 by the Federal Reserve, pursuant to which DBAG: (A) was required to pay a civil monetary penalty of $19.71 million, which DBAG paid on April 20, 2017; and (B) submit (1) a written plan to improve senior management's oversight of DBAG's compliance with Volcker Rule requirements and (2) an enhanced written internal controls and compliance risk management program to comply with the Volcker Rule, in each case acceptable to the Federal Reserve Bank of New York. The Order requires DBAG to submit, within 60 days of the date of the Order, (1) a written plan to improve senior management's oversight of DBAG's compliance with Volcker Rule requirements and (2) an enhanced written internal controls and compliance risk management program to comply with the Volcker Rule, in each case acceptable to the Federal Reserve Bank of New York. DBAG must fully implement each of the required written plan and written program within six months from the date on which DBAG is notified that the plan or program is acceptable to the Reserve Bank. The Order required DBAG to pay a civil monetary penalty in the amount of $19.71 million, which DBAG paid on April 20, 2017. DBAG consented to the entry of the Order on April 20, 2017 by the Federal Reserve, pursuant to which DBAG was required to pay a civil monetary penalty of $19.71 million, which DBAG paid on April 20, 2017. Deutsche Bank AG (DBAG), DBAG (NY Branch), DB USA Corporation, a Control Affiliate of the Registrant 17-008-B-FB; 17-008-CMP-FB; 17-008-B-HC; 17-008-CMP-HC; 17-008-B-FBR; 17-008-CMP 04/20/2017 Board of Governors of the Federal Reserve System The Registrant has not been the subject of this matter: Date Initiated: 4/20/2017. On April 20, 2017, the Board of Governors of the Federal Reserve System (The "FED"), DBAG, DB USA Corporation and DBAG's New York Branch (collectively, "The Bank") entered into a Consent Order. Although the FED acknowledged that the Bank "fully cooperated" with the FED and "has made and continues to make progress in implementing enhancements to its firm-wide compliance systems and controls", the FED found that during the review period from October 2008 through October 2013, the Bank lacked adequate governance, risk management, compliance and audit policies and procedures to ensure that the Bank's foreign exchange activities complied with safe and sound banking practices and applicable internal policies, which prevented the Bank from detecting and addressing unsafe and unsound conduct by certain of its FX traders. As a result of this conduct, the FED found that the Bank engaged in unsafe and unsound banking practices. The Bank consented to the entry of the Order on April 20, 2017 by the FED, pursuant to which the Bank: (A) shall pay a civil monetary penalty of $136,950,000, which the Bank paid on April 20, 2017; and (B) shall submit written plans to improve senior management oversight and the compliance risk management program, an enhanced written internal controls and compliance program, and an enhanced written internal audit program to the FED within 90 days of the Order; (C) shall conduct periodic monitoring by senior management, an annual review of compliance policies and procedures and their implementation and an appropriate risk-focused sampling of other key controls, and a firm-wide risk assessment to evaluate current potential conduct risks; (D) for subsections B&C, shall adopt and promptly implement the approved plans and programs within 10 days of approval by the FED and thereafter fully comply with them; and (E) shall submit quarterly written progress reports to the FED. The Order requires the Bank to implement improvements in its oversight, internal controls, risk management, and audit programs, and to conduct an annual review of compliance policies and procedures and a risk-focused sampling of other key controls. The Bank must submit to the FED written progress reports on a quarterly basis detailing the form and manner of all actions taken to secure compliance with the Order and the results thereof. The Order required the Bank to pay a civil monetary penalty in the amount of $136,950,000, which the Bank paid on April 20, 2017. The Bank consented to the entry of the Order on April 20, 2017 by the FED, pursuant to which the Bank shall pay a civil monetary penalty of $136,950,000, which the Bank paid on April 20, 2017. DEUTSCHE BANK AG, DEUTSCHE BANK AG (NEW YORK), DBTCA, Control Affiliate of the Registrant N/A 07/07/2020 New York State Department of Financial Services ("DFS") IN A CONSENT ORDER DATED JULY 7, 2020 (THE "CONSENT ORDER"), THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NY DFS") FOUND THAT DEUTSCHE BANK AG ("DBAG"), DBAG NEW YORK BRANCH (THE "NY BRANCH"), AND DEUTSCHE BANK TRUST COMPANY AMERICAS ("DBTCA," TOGETHER WITH DBAG AND THE NY BRANCH, "DEUTSCHE BANK" OR THE "BANK"), IN CONNECTION WITH THE BANK'S FORMER RELATIONSHIP WITH JEFFREY EPSTEIN AND FORMER CORRESPONDENT BANKING RELATIONSHIPS WITH DANSKE BANK A/S ESTONIA BRANCH ("DANSKE ESTONIA") AND THE FEDERAL BANK OF THE MIDDLE EAST LTD. ("FBME"), CONDUCTED BUSINESS IN AN UNSAFE AND UNSOUND MANNER AND FAILED TO MAINTAIN AN EFFECTIVE AND COMPLIANT ANTI-MONEY LAUNDERING PROGRAM. NY DFS FOUND THAT THE BANK FAILED TO ADEQUATELY MONITOR THE ACTIVITY OF MR. EPSTEIN AND HIS RELATED ENTITIES BETWEEN AUGUST 2013 AND DECEMBER 2018 DESPITE DEEMING MR. EPSTEIN A "HIGH RISK" CLIENT, THEREBY FAILING TO DETECT AND PREVENT SUSPICIOUS TRANSACTIONS. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH FBME (TERMINATED IN JULY 2014), NY DFS FOUND THAT THE HIGH-RISK NATURE OF THE RELATIONSHIP, THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, AND OTHER AML-RELATED ISSUES SHOULD HAVE PROMPTED THE BANK TO EXIT THE RELATIONSHIP BEFORE THE U.S. TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK NAMED FBME AS A FOREIGN FINANCIAL INSTITUTION OF PRIMARY MONEY LAUNDERING CONCERN IN JULY 2014. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH DANSKE ESTONIA (TERMINATED IN OCTOBER 2015), NY DFS FOUND THAT THE BANK CONTINUED ITS RELATIONSHIP WITH DANSKE ESTONIA DESPITE THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, THE HISTORY OF HIGH-RISK SCORES THE BANK ASSIGNED TO DANSKE ESTONIA, AND THE BANK'S DISCUSSIONS WITH DANSKE ESTONIA ABOUT DANSKE ESTONIA'S AML POLICIES AND CONTROLS. DB AGREED TO COOPERATE WITH AN INDEPENDENT MONITOR APPOINTED PURSUANT TO A PRIOR CONSENT ORDER WITH THE NY DFS, DATED 1/30/2017; PAY A CIVIL MONEY PENALTY OF $150,000,000, WHICH WAS TIMELY PAID ON 7/10/2020, AND TO COOPERATE WITH THE NY DFS CONSENT ORDER. N Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1219988 08/31/2004 The California Department of Corporations In reference to the Title of Action noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant N/A 01/30/2017 Financial Conduct Authority ("FCA") In reference to the "Court or body taking the Action and its location" noted above, please see response to question 10(d)(2)(v). In reference to the "Court or body taking the Action and its location" noted above, please see response to question 10(d)(2)(vi). Deutsche Bank AG (DBAG) including DBAG (NY Branch). a Control Affiliate of the Registrant N/A 01/30/2017 New York State Department of Financial Services ("DFS") In reference to the "Court or body taking the Action and its location" noted above, please see response to question 10(d)(2)(v). In reference to the 'Court or body taking the Action and its location" noted above, please see response to question 10(d)(2)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: CO-2005-0011 03/31/2005 The Alabama Securities Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: S-03578A-05-0000 03/01/2005 The Arizona Corporation Commission In reference to the Title of Action noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : EN-10522 03/28/2005 The Commissioner of Securities of the State of Georgia In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003E052 03/28/2005 The Kansas Office of the Securities Commissioner In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250895 03/15/2005 The Kentucky Office of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-045-CON 03/16/2005 The Maine Office of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250903 04/01/2005 The Minnesota Department of Commerce In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250878 02/17/2005 The Nebraska Department of Banking and Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 04-050-IG 03/31/2005 The North Carolina Department of the Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1250894 03/24/2005 The Ohio Department of Commerce, Division of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-05-0003 03/17/2005 The Oregon Department of Consumer and Business services, Division of Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 2003-04-50 02/23/2005 Pennsylvania Securities Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 05-94 03/22/2005 The Rhode Island Department of Business Regulation, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : 5-004-S 03/05/2005 The Vermont Department of Banking, Insurance, Securities and Health Care In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case # : S-04-251-04-CO01 03/25/2005 The Washington Department of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-05026(LX) 03/29/2005 The Wisconsin Department of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: SEC-2003-00023 03/30/2005 The Commonwealth of Virginia State Corporation Commission In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-H-16 06/14/2005 The Colorado Division of Securities, Department of Regulatory Agencies In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0152-S-8/04 05/23/2005 The State of Florida Office of Financial Regulation In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. 1000048 05/16/2005 The State of Iowa Insurance Division, Securities Bureau In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. 2005-0008 05/23/2005 The Commonwealth of Massachusetts Office of the Secretary of the Commonwealth In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: S-05-023-05-C001 06/23/2005 The Arkansas Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Matter No. C05-V-005 07/01/2005 The Commonwealth of Puerto Rico Commissioner of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 2005-7-11 07/15/2005 The Idaho Department of Finance In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1266565 07/11/2005 The New Jersey Office of the Attorney General, Division of Consumer Affairs In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 05-3-1 08/22/2005 The State of Delaware, Department of Justice, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: SEC.CO 05-02 06/21/2005 The District of Columbia Department of Insurance, Securities and Banking In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No.105-185-JN 08/11/2005 The Nevada Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-02 07/26/2005 The State of Wyoming Secretary of State In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-0021 CO 08/11/2005 The Indiana Office of the Secretary of State, Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 02-11-06-S 07/01/2005 The Office of the Mississippi Secretary of State, Business Regulation In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1273373 08/26/2005 The State of North Dakota Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1274034 08/25/2005 The Utah Division of Securities, Department of Commerce In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1276422 09/30/2005 The West Virginia Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: SEU-2005-036-B 10/17/2005 The State of Hawaii Department of Commerce and Consumer Affairs In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 05-17-05-144I 11/02/2005 The Montana State Auditor's Office Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 05-010-M 11/04/2005 The State of Michigan Office of Financial and Insurance Services In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: CO-2005-7083-S 12/07/2005 The State of Connecticut Department of Banking In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: 04CV06909 01/31/2006 The State of South Dakota Division of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 06025 06/16/2006 The Securities Division of the Attorney General of the State of South Carolina In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 05-005 06/26/2006 The Tennessee Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: IC06-CDO-07 05/31/2006 The Texas State Securities Board In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE NO. 0600247 07/20/2006 The Illinois Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1328168 10/19/2006 The State of Louisiana Office of Financial Institutions Securities Division In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No.05-058 10/12/2006 The State of Oklahoma Department of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: IC05-CAF-11 04/22/2005 State of Texas Securities Commissioner In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1339522 01/04/2007 Illinois Securities Department In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case #: Securities Division No. 2002-0894 01/30/2007 Securities Commissioner of Maryland In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-06-49 11/03/2006 State of Missouri Commissioner of Securities In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Occurrence 1339443 12/01/2006 Attorney General of the State of New York In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NJ Bureau of Securities Action 6/3/09 06/03/2009 Bureau of Securities, State of New Jersey ("NJ Bureau of Securities") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NY Investor Protection Bureau Action 6/3/09 06/03/2009 Attorney General of the State of New York, Investor Protection Bureau ("NYAG") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEC-2009-39 08/03/2009 Montana Securities Department ("Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant I09-181 08/03/2009 Securities Division, Office of the Secretary of State, Nevada ("the Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant S-03578A-09-0314 08/20/2009 Arizona Corporation Commission ("Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. CO-2009-0037 11/05/2009 Alabama Securities Commission ("The Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 11/06/2009 North Dakota Securities Department ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 09-7-1 11/05/2009 Division of Securities, Dept. of Justice, State of Delaware ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 90-2525 11/23/2009 Division of Securities, Office of State Auditor, West Virginia (The "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/01/2009 Minnesota Department of Commerce, Market Assurance Division ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/02/2009 Michigan Office of Fin. & Ins. Reg. of Dept. of Energy, Labor, and Econ. Growth In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-195-09-CO01 12/01/2009 State of Washington Division of Securities, Dept. of Financial Institutions In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 12/04/2009 Office of Commissioner of Financial Institutions, Commonwealth of Puerto Rico In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07-10 12/15/2009 Commission of Securities of the Commonwealth of Pennsylvania ("The Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-0140 CO 01/08/2010 Division of Securities Office of Secretary of State of Indiana ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant KSC No. 2010-5641 01/08/2010 Office of the Securities Commissioner of the State of Kansas (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Agency Case No. 2010-AH-002 01/11/2010 Dept. of Fin. Inst. Public Protection Cabinet of Kentucky ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NC File No. 09SEC48 01/13/2010 Div. of Sec. Dept. of the Secretary of State, North Carolina ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. S-09-024-09-CO07 01/13/2010 Department of Securities of the State of Arkansas ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 09-076 01/12/2010 Office of Securities, Dept. of Prof. and Fin. Reg. of Maine (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. AP-10-04 01/14/2010 Division of Securities Office of the Sec. of St. of Missouri (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No 10-6-14 01/20/2010 Division of Securities of the Dept. of Reg. Agen. Dept. of State of Colorado In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant E-2009-0066 01/26/2010 Division of Sec. of Dept. of State of Com. of Massachusetts ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. S-09-0039 01/27/2010 Division of Finance and Corporate Securities, State of Oregon ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ODS File No. 09-142 02/01/2010 Department of Securities of the State of Oklahoma ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Auction Rate Securities 03/05/2010 Department of Banking and Finance of the State of Nebraska ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09-053-059 03/10/2010 Division of Securities of Dept. of Reg. and Lic. of New Mexico ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 09090 03/11/2010 Div. of Sec. Off. of the Attny Gen. of the St. of So. Carolina ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. SEC-2009-00074 04/16/2010 State Corporation Commission of the Commonwealth of Virginia (The "Commission") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant SEU-2008-73 04/13/2010 Department of Commerce and Cons. Aff. of the State of Hawaii ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 09-09 04/09/2010 Division of Securities Off. of Sec. of St., State of Wyoming ("The Division")") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. IC10-CAF-11 04/08/2010 State Securities Board of the State of Texas ("The Board") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09148(EX) 04/08/2010 Division of Securities Dept. of Fin. Inst. of St. of Wisconsin (The "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 2009-07 04/08/2010 Bureau of Securities of Dept. of Fin. of the State of Idaho ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 09-018 (SI-2008-010) 05/10/2010 Div. of Sec. of Dept. of Comm. and Ins. of St. of Tennessee (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. S-09-0225 05/10/2010 Div. of Sec. and Char. of Off. of Mississippi Sec. of State (the "Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. OFI-2010-006 06/07/2010 Louisiana Office of Fin. Inst., Commissioner of Securities (the "Commissioner") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. 67154 06/14/2010 Div. of Securities of the Office of Sec. of State, St. of Iowa ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. CO-10-7799-S 08/09/2010 Department of Banking of the State of Connecticut ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Cause No. 08-10 08/12/2010 Div. of Banking and Ins. Off. of Lt. Gov. of US Virgin Islands ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Securities Division No. 2009-0311 09/22/2010 Division of Securities of Office of Attny General of Maryland ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 10-15-S 12/23/2010 Dept of Commerce, Community & Econ Dev, Div of Bnkng & Securities, St of Alaska In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Administrative Proceeding No. 0441-S-07/09 02/01/2011 Office of Financial Regulation of the State of Florida (the "Office") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. 11-013 03/21/2011 Division of Securities of the Dept. of Commerce of St. of Ohio ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Order No. SB-CO-10-11 05/11/2011 Department of Insurance, Sec. and Bank. District of Columbia ("The Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ENSC-10059 09/21/2011 Division of Securities of the Off. of Sec. of St. of Georgia ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket No. SD-11-0088 10/27/2011 Division of Securities of the Dept. of Commerce of St. of Utah ("The Division") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 1100301 07/16/2012 Illinois Secretary of State, Securities Department (The "Department") In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(1)(vi). Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 17-009-B-FB; 17-009-CMP-FB 04/20/2017 Board of Governors of the Federal Reserve System In reference to the "Title of Action" noted above, please see response to question 10(d)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(2)(vi). Deutsche Bank AG (DBAG), DBAG (NY Branch), DB USA Corporation, a Control Affiliate of the Registrant 17-008-B-FB; 17-008-CMP-FB; 17-008-B-HC; 17-008-CMP-HC; 17-008-B-FBR; 17-008-CMP 04/20/2017 Board of Governors of the Federal Reserve System In reference to the "Title of Action" noted above, please see response to question 10(d)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(d)(2)(vi). Deutsche Bank AG (DBAG), DB USA Corporation, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company Americas, a Control Affiliate of the 17-009-B-FB,17-009-B-FBR, 17-009-B-HC,17-009-B-SMB,17-009-CMP-FB,17-009-CMP-FBR, 05/30/2017 Board of Governors of the Federal Reserve System The Registrant has not been the subject of this matter: Date Initiated: 5/30/2017. On May 30, 2017, the Board of Governors of the Federal Reserve System, Deutsche Bank AG, Deutsche Bank AG's New York Branch, DB USA Corporation, and Deutsche Bank Trust Company Americas entered into an Order pursuant to 12 U.S.C. Section 1818(B) and 12 U.S. C. Section 1818 (I). Specifically, the Board of Governors of the Federal Reserve Board found that (A) the most recent examination of the BSA/AML program at DBTCA and the New York branch conducted by the Federal Reserve Bank of New York identified significant deficiencies in DBTCA's and the branch's risk management and compliance with BSA/AML requirements that resulted in a violation of the Regulatory Compliance Program requirement, and (B) deficiencies in DBTCA's transaction monitoring capabilities prevented DBTCA from properly assessing BSA/AML risk for billions of dollars in certain potentially suspicious transactions. Deutsche Bank AG, Deutsche Bank AG's New York Branch, DB USA Corporation, and Deutsche Bank Trust Company Americas consented to the entry of the Order signed on May 26, 2017 by the Board of Governors of the Federal Reserve Bank, pursuant to which Deutsche Bank (A) committed to pay a civil money penalty of $41 million, which Deutsche Bank paid on June 6, 2017; and (B) committed to affirmative obligations including the retention of independent third parties to review DBTCA's compliance with applicable BSA/AML requirements and to conduct a transaction review of DBTCA's foreign correspondent banking activity from July 1, 2016 to December 31, 2016; and the submission of several distinct written remediation plans and programs targeted at strengthening the bank's compliance, risk management, and monitoring. These obligations have various due dates beginning 30 days after the Order was signed. The Order imposes affirmative obligations including the retention of independent third parties to review DBTCA's compliance with applicable BSA/AML requirements and to conduct a transaction review of DBTCA's foreign correspondent banking activity from July 1, 2016 to December 31, 2016. The Order also requires certain Deutsche Bank entities to submit several distinct written remediation plans and programs targeted at strengthening the bank's compliance, risk management, monitoring, and reporting functions. The Order required DBAG to pay a civil money penalty in the amount of $41 million, which the Firm paid on June 6, 2017. Deutsche Bank AG, Deutsche Bank AG's New York Branch, DB USA Corporation, and Deutsche Bank Trust Company America consented to the entry of the Order signed on May 26, 2017 by the Board of Governors of the Federal Reserve Bank. Deutsche Bank AG (DBAG), DB USA Corporation, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company Americas, a Control Affiliate of the 17-009-B-FB,17-009-B-FBR, 17-009-B-HC,17-009-B-SMB,17-009-CMP-FB 08/02/2017 test test test DEUTSCHE BANK AG, DEUTSCHE BANK AG (NEW YORK), DBTCA, Control Affiliate of the Registrant N/A 07/07/2020 New York State Department of Financial Services ("DFS") IN A CONSENT ORDER DATED JULY 7, 2020 (THE "CONSENT ORDER"), THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NY DFS") FOUND THAT DEUTSCHE BANK AG ("DBAG"), DBAG NEW YORK BRANCH (THE "NY BRANCH"), AND DEUTSCHE BANK TRUST COMPANY AMERICAS ("DBTCA," TOGETHER WITH DBAG AND THE NY BRANCH, "DEUTSCHE BANK" OR THE "BANK"), IN CONNECTION WITH THE BANK'S FORMER RELATIONSHIP WITH JEFFREY EPSTEIN AND FORMER CORRESPONDENT BANKING RELATIONSHIPS WITH DANSKE BANK A/S ESTONIA BRANCH ("DANSKE ESTONIA") AND THE FEDERAL BANK OF THE MIDDLE EAST LTD. ("FBME"), CONDUCTED BUSINESS IN AN UNSAFE AND UNSOUND MANNER AND FAILED TO MAINTAIN AN EFFECTIVE AND COMPLIANT ANTI-MONEY LAUNDERING PROGRAM. NY DFS FOUND THAT THE BANK FAILED TO ADEQUATELY MONITOR THE ACTIVITY OF MR. EPSTEIN AND HIS RELATED ENTITIES BETWEEN AUGUST 2013 AND DECEMBER 2018 DESPITE DEEMING MR. EPSTEIN A "HIGH RISK" CLIENT, THEREBY FAILING TO DETECT AND PREVENT SUSPICIOUS TRANSACTIONS. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH FBME (TERMINATED IN JULY 2014), NY DFS FOUND THAT THE HIGH-RISK NATURE OF THE RELATIONSHIP, THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, AND OTHER AML-RELATED ISSUES SHOULD HAVE PROMPTED THE BANK TO EXIT THE RELATIONSHIP BEFORE THE U.S. TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK NAMED FBME AS A FOREIGN FINANCIAL INSTITUTION OF PRIMARY MONEY LAUNDERING CONCERN IN JULY 2014. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH DANSKE ESTONIA (TERMINATED IN OCTOBER 2015), NY DFS FOUND THAT THE BANK CONTINUED ITS RELATIONSHIP WITH DANSKE ESTONIA DESPITE THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, THE HISTORY OF HIGH-RISK SCORES THE BANK ASSIGNED TO DANSKE ESTONIA, AND THE BANK'S DISCUSSIONS WITH DANSKE ESTONIA ABOUT DANSKE ESTONIA'S AML POLICIES AND CONTROLS. DB AGREED TO COOPERATE WITH AN INDEPENDENT MONITOR APPOINTED PURSUANT TO A PRIOR CONSENT ORDER WITH THE NY DFS, DATED 1/30/2017; PAY A CIVIL MONEY PENALTY OF $150,000,000, WHICH WAS TIMELY PAID ON 7/10/2020, AND TO COOPERATE WITH THE NY DFS CONSENT ORDER. N N Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: NYSE DEC. 04-128 08/27/2004 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: August 2, 2004. The NYSE charged violations of NYSE Rules 401, 472, and 476(A)(6) in connection with alleged conflicts of interest resulting from investment banking influence over research analysts; the issuance of research reports affected by those conflicts of interest; payments to and from other securities firms and the receipt of payments from issuers for research; and the non-disclosure of such payments. The NYSE also charged violations of NYSE Rule 342 for allegedly not adequately supervising its research analysts in order to prevent conflicts of interest, as well as NYSE Rule 476(A)(11) for allegedly not promptly producing e-mail. The current status is closed on August 27, 2004. Without admitting or denying the allegations, DBSI agreed to a stipulation and consent with the NYSE, and to pay $87.5 million. The Stipulation and Consent included undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI has agreed to pay: (I) $50 million, offset in the amount of $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. Closed on August 27, 2004. Without admitting or denying the allegations, DBSI agreed to a stipulation and consent with the NYSE, and to pay $87.5 million. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CAF040062 08/20/2004 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Initiation date: August 20, 2004. The NASD charged violations of NASD Rules 2110, 2210(D)(1), and 2210(D)(2) in connection with alleged conflicts of interest resulting from investment banking influence over research analysts; the issuance of research reports affected by those conflicts of interest; payments to and from other securities firms and the receipt of payments from issuers for research; and the non-disclosure of such payments. The NASD also charged violations of NASD Rule 3010 for allegedly not adequately supervising its research analysts in order to prevent conflicts of interests, as well as NASD Rule 2110 for allegedly not promptly producing e-mail. The current status is closed on August 20, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent with the NASD and to pay $87.5 million. The WAC included undertakings with respect to the separation of research and investment banking; mandatory disclosures to be included in research reports and transparency of research analysts' ratings and projections; and the use of independent, third-party research services. DBSI has agreed to pay: (I) $50 million, offset in the amount of $25 million to be paid pursuant to agreements with state regulators in related proceedings; (II) $25 million to fund the provision of independent research to investors (payable over the next five years); (III) $5 million to promote investor education (payable over the next five years); and (IV) $7.5 million in connection with allegations concerning Section 17(B) of the Exchange Act. Closed on August 20, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent with the NASD and to pay $87.5 million. Deutsche Bank Securities, Inc.'s (DBSI or Firm) , a Control Affiliate of the Registrant 20080136798-01 12/14/2012 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/14/2012. FINRA alleged that during the period from January 1, 2008 through June 15, 2012, in 98 instances, Deutsche Bank Securities Inc.'s ("DBSI" or "firm") trade volume manually advertised by traders on Autex, Bloomberg and/or Reuters substantially exceeded the Firm's executed trade volume for the security involved. FINRA alleged that this conduct violated NASD Rule S 2110, 2210, 3310 and IM-3310. In addition, FINRA alleged that, during the period October 15, 2010 through June 15, 2012, the Firm's systems failed to accurately advertise trade volume. FINRA alleged that more than four billion shares, which comprised about four percent of the Firm's volume during the period, that were not eligible for advertisement were advertised. FINRA alleged that this conduct violated FINRA Rules 2010 and 5210 and NASD Rule 2210. Finally, FINRA alleged that the Firm failed to establish and implement a supervisory system that was reasonably designed to ensure compliance with regulatory requirements for accuracy in the Firm's advertisements of executed trade volume. FINRA alleged that this conduct violated NASD Rule 2010 (for the period prior to December 15, 2008), FINRA Rule 2010 (for the period on and after December 15, 2008) and NASD Rule 3010. In determining the sanctions in this matter, FINRA took into account that, upon receiving the FINRA staff's initial inquiry letter for this matter, the Firm (i) conducted an internal investigation, (ii) provided a written summation of the results of that investigation, and (iii) imposed disciplinary actions against some of the traders responsible for certain of the inflated advertisements. In addition, the Firm self-reported the remainder of the violations to the FINRA staff prior to FINRA becoming aware of the issues involved. Without admitting or denying FINRA's findings and without adjudication of any issue of law or fact, DBSI consented, solely for the purpose of this proceeding, to the entry of FINRA's findings with respect to allegations of violations of NASD and FINRA Rules (listed under allegations) as a result of overstating its advertised trade volume and failing to establish and implement appropriate supervisory procedures regarding advertised trade volume. DBSI also consented to the following sanctions: a censure and fine in the amount of $1.25 million; and an undertaking to revise the Firm's supervisory procedures relating to advertised trade volume. The fine was paid on 1/2/13. Without admitting or denying the findings and without adjudication of any issue of law or fact, DBSI consented to FINRA's findings, a censure, a fine of $1.25 mil. and an undertaking to revise the Firm's supervisory proced. relating to adver. trade vol. 1 Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140429134-01 12/15/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 12/15/2016. FINRA's allegations involve Deutsche Bank Securities Inc.'s ("DBSI") Alternative Trading System ("ATS"). FINRA alleged that DBSI "failed generally" to disclose certain services and features of the ATS to all ATS users equally and simultaneously, and thus all users "did not effectively "have "identical access" to all services and features of the ATS, as stated in DBSI's Form ATS filing. FINRA also alleged deficiencies in DBSI's Form ATS filing. Without admitting or denying the allegations, DBSI consented to the imposition of a censure, and undertaking, and a fine in the amount of $3,250,000.00. The fine was paid on December 19, 2016, and satisfaction of the undertaking is due to be completed within sixty business days after acceptance of the AWC (Acceptance of the AWC occurred on 12/15/2016). Monetary fine of $3,250,000.00 was paid on December 19, 2016. Without admitting or denying the allegations, DBSI consented to the imposition of a censure, an undertaking, and a fine in the amount of $3,250,000.00. The fine was paid on December 19, 2016. Y Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: File No. 3-10957 12/03/2002 United States Securities and Exchange Commission In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi) Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CFE File No. 17-0003 02/28/2017 CBOE Futures Exchange (CFE) The Registrant has not been the subject of this matter: Date Initiated: 2/28/2017. The CFE alleges that on January 19, 2016, DBSI did not report its open interest position adjustments in a timely manner for trade date January 19, 2016, in the January 2016 Volatility Index Futures contract, which expired January 20, 2016, leading to a misstatement of open interests. The CFE views this as a violation of CFE Rule 410A. DBSI neither admitted nor denied the rule violation upon which the penalty is based. The fine was paid on March 14, 2017. DBSI consented a fine of $15,000.00. The fine was paid on March 14, 2017. DBSI neither admitted nor denied the rule violation upon which the penalty is based. The fine was paid on March 14, 2017. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CAF020064 11/22/2002 National Association of Securities Dealer, Inc. In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi) Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 02-223 11/15/2002 New York Stock Exchange In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(v). In reference to the "Title of Action" noted above, please see response to question 10(c)(2)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: NYSE DEC. 04-128 08/27/2004 New York Stock Exchange In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CAF040062 08/20/2004 National Association of Securities Dealers, Inc. In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(vi). Deutsche Morgan Grenfell Inc. (DMGI), a Control Affiliate of the Registrant NASD Unknown 09/11/1991 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Initiation date: September 11, 1991. The National Association of Securities Dealers, Inc. alleged violation of Article III, Sections 1 and 41 with respect to the reporting of transactions in certain Non-NASDAQ over-the-counter securities by DMGI. The current status is: closed on September 11, 1991. DMGI consented to the entry of an Order Making Findings and Imposing Sanctions. Closed on September 11, 1991. DMGI consented to the entry of an Order Making Findings and Imposing Sanctions. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 01-148 09/26/2001 New York Stock Exchange, Inc. The Registrant has not been the subject of this matter: Date initiated: August 9, 2001. Description of the Action: Deutsche Bank Securities Inc. was alleged to have: violated SEC Reg. 240.15C2-8(C) by failing to provide preliminary prospectuses to customers who indicated interest in purchasing initial public offerings; violated Exchange Rule 410 by failing to include terms of the order on tickets transmitted to the floor; violated Exchange Rule 440 and SEC Reg. 240.17A-3(A)(6) by failing to maintain a memorandum of orders; violated Exchange Rule 440 and SEC Regs. 240-17A-3 and 17A-4 by failing to preserve required books and records; violated Exchange Rule 342.16 in that a branch failed to properly supervise and approve outgoing correspondence; and violated Exchange Rule 342 by failing to reasonably supervise and provide appropriate supervisory procedures to determine that delegated authority is being properly exercised. Disposition of the Proceeding: Resolution date: September 26, 2001. Without admitting or denying the allegations, the firm consented to the findings. A fine of $100,000 was paid on September 25, 2001. Resolution date: September 26, 2001. Without admitting or denying the allegations, the firm consented to the findings. A fine of $100,000 was paid on September 25, 2001. Deutsche Bank Alex Brown Inc., a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: CMS010156AWC 10/01/2001 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Alex. Brown is NKA Deutsche Bank Securities Inc. ("DBSI") which is the legal name for this US registered broker-dealer. Deutsche Bank Capital Corporation was the predecessor firm of Deutsche Bank Securities Inc. "Deutsche Bank Alex. Brown, a division of Deutsche Bank Securities Inc." is the marketing name for its retail brokerage activities. DBSI was formerly known as Deutsche Banc Alex. Brown, Inc. ("DBAB") and prior as DB Alex. Brown LLC ("Alex. Brown LLC"), and prior as BT Alex. Brown Incorporated ("BTAB"). BTAB succeeded to the business of Alex. Brown & Sons Incorporated ("Alex. Brown") and BT Securities Corporation ("BTSec"). Alex. Brown had earlier succeeded to the broker-dealer business of Alex. Brown & Sons, which had later been named Alex. Brown Partners, a Maryland Limited Partnership (the "partnership"). BTSec was the former FRA Section 20 subsidiary of Bankers Trust Corporation. Description of the Action: In connection with MRD Review #2000271404613, the NASDR alleged that Deutsche Bank Alex Brown Inc. ("DBAB") violated NASD Rule 4613. NASDR alleged that on ten occasions from July 1, 2000, to September 30, 2000, DBAB, a market maker in the subject securities, without making reasonable efforts to avoid a locked or crossed market by executing transactions with all market participants whose quotations would be locked or crossed, entered a bid or asked quotation in the NASDAQ Stock Market which caused a locked or crossed market condition to occur in each instance. Disposition of the Proceeding: Resolution Date: October 1, 2001. Without admitting or denying the allegations, DBAB agreed to a letter of Acceptance, Waiver, and Consent and to pay a fine of $3,000.00. The fine was paid on October 30, 2001. Resolution Date: October 1, 2001. Without admitting or denying the allegations, DBAB agreed to a letter of Acceptance, Waiver, and Consent and to pay a fine of $3,000.00. The fine was paid on October 30, 2001. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: CMS960225 02/06/1998 National Association of Securities Dealers, Inc. Market Regulation Committee The Registrant has not been the subject of this matter: Initiation date: January 10, 1997. Description of the Action: The complaint alleged violation of: NASD Marketplace Rules 4632, 4642, and 6130(D)(7), in that Deutsche Bank Securities Inc. ("DBSI") failed to timely and accurately report NASDAQ NMS and NASDAQ small cap transactions; Rule 6620 for DBSI's failure to timely and accurately report OTC equity securities transactions; and NASD Conduct Rule 2110 and 3110 for DBSI's failure to supervise. Disposition of the Proceeding: Resolution date: February 6, 1998. Without admitting or denying the allegations of the complaint, DBSI consented, for the purposes of this proceeding only, to the entry of findings of facts and violations consistent with the allegations of the complaint. DBSI was censured and fined $12,500.00. Resolution date: February 6, 1998. Without admitting or denying the allegations of the complaint, DBSI consented, for the purposes of this proceeding only, to the entry of findings of facts and violations. DBSI was censured and fined $12,500.00. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: CMS970066AWC 01/12/1998 National Association of Securities Dealers, Inc. Market Regulation Department The Registrant has not been the subject of this matter: Initiation date: January 10, 1997. Description of the Action: As a result of a routine examination of Deutsche Bank Securities Inc. ("DBSI"), the NASDR alleged violations of SEC Rule 17A-3 and NASD Conduct Rule 3110(E) for DBSI's failure to correctly prepare order memorandum. Disposition of the Proceeding: Resolution Date: January 12, 1998. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver, and Consent ("AWC") and to pay $2,500.00. In addition, DBSI agreed to implement and provide the NASD staff within sixty days of the AWC revised written supervisory procedures concerning recordkeeping. The fine was paid on February 4, 1998. Resolution Date: January 12, 1998. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver, and Consent ("AWC") and to pay $2,500.00. Deutsche Bank Capital Corporation (the predecessor firm of Deutsche Bank Securities Inc.), a Control Affiliate of the Registrant Docket/Case Number: CMS920065AWC 08/17/1992 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Date initiated: April 15, 1992. Description of the Action: Deutsche Bank Capital Corporation was alleged to have failed to report "0" trading volume on three NASDAQ securities. Disposition of the Proceeding: Resolution Date: August 17, 1992. Without admitting or denying the NASD's allegations, Deutsche Bank Capital Corporation agreed to a letter of Acceptance, Waiver and Consent and to pay $5,000.00. Resolution Date: August 17, 1992. Without admitting or denying the NASD's allegations, Deutsche Bank Capital Corporation agreed to a letter of Acceptance, Waiver and Consent and to pay $5,000.00. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: NASD-NY 1533 09/14/1992 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Initiation date: October 28, 1971. Description of the Action: The NASD alleged violations by predecessor of Deutsche Bank Securities Inc. of Article III, Section 1 of the Rules of Fair Practice, FR&W, regarding the sale of 100 shares of hot issues to restricted accounts. Disposition of the Proceeding: Resolution Date: September 14, 1992. The firm agreed to settle this matter without admitting or denying the NASD's allegation and paid the $1,000 fine. Resolution Date: September 14, 1992. The firm agreed to settle this matter without admitting or denying the NASD's allegation and paid the $1,000 fine. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: NASD-NY 1531 07/08/1972 National Association of Securities, Inc. The Registrant has not been the subject of this matter: Date initiated: October 28, 1971. Description of the Action: The NASD alleged violations by predecessor of Deutsche Bank Securities Inc. of Article III, Section 1 of the Rules of Fair Practice, regarding the restriction of use of intermediary brokers. Disposition of the Proceeding: Resolution Date: July 8, 1972. The firm agreed to settle this matter without admitting or denying the NASD's allegations and paid the $5,184.00 fine. Resolution Date: July 8, 1972. The firm agreed to settle this matter without admitting or denying the NASD's allegations and paid the $5,184.00 fine. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 02-EX-26 04/15/2003 Chicago Board of Trade The Registrant has not been the subject of this matter: Date initiated: March 19, 2003. Description of the Action: The Chicago Board of Trade ("CBOT") alleged that Deutsche Bank Securities Inc. ("DBSI") violated Regulations 285.05 and 545.02, in that the firm did not accurately calculate and/or reflect certain assets, liabilities, capital charges, margin requirements, and segregated and secured amounts on its July 31, 2002, financial statement, and Regulations 431.02 and 545.02, in that the firm did not meet the Exchange's requirements for maintaining a system for recording and aging outstanding margin calls. Disposition of the Proceeding: Resolution date: April 15, 2003. Without admitting or denying any violations of CBOT Regulations 285.05, 431.02, or 545.02, DBSI agreed to pay a fine of $10,000.00. The fine was paid on May 2, 2003. Resolution date: April 15, 2003. Without admitting or denying any violations of CBOT Regulations 285.05, 431.02, or 545.02, DBSI agreed to pay a fine of $10,000.00. The fine was paid on May 2, 2003. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 02-RFT-110 04/10/2003 Chicago Board of Trade The Registrant has not been the subject of this matter: Date initiated: March 28, 2003. Description of the Action: The Chicago Board of Trade ("CBOT") alleged that Deutsche Bank Securities Inc. ("DBSI") (f/k/a Deutsche Bank Futures Inc. ("DBFI")) violated CBOT Regulation 332.08. In twelve instances, failed to keypunch the updated order entry time for a cancel/replace order into the "time stamp in" field. In five instances, the incorrect order type was keypunched into the trade entry system. In four instances, the incorrect confirmation time was keypunched into the trade entry system. In one instance, the incorrect order entry time was keypunched into the trade entry system. Please note that DBFI merged with DBSI on November 1, 2002. Disposition of the Proceeding: Resolution date: April 10, 2003. Without admitting or denying any violation of CBOT Regulation 332.08, DBSI agreed to pay a fine of $1,500.00. The fine was paid on April 10, 2003. Resolution date: April 10, 2003. Without admitting or denying any violation of CBOT Regulation 332.08, DBSI agreed to pay a fine of $1,500.00. The fine was paid on April 10, 2003. Deutsche Banc Alex. Brown Inc. (DBAB), a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: CMS020072 04/29/2002 National Association of Securities Dealers, Inc. Chicago Board of Trade The Registrant has not been the subject of this matter: Alex. Brown is NKA Deutsche Bank Securities Inc. ("DBSI") which is the legal name for this US registered broker-dealer. Deutsche Bank Capital Corporation was the predecessor firm of Deutsche Bank Securities Inc. "Deutsche Bank Alex. Brown, a division of Deutsche Bank Securities Inc." is the marketing name for its retail brokerage activities. DBSI was formerly known as Deutsche Banc Alex. Brown, Inc. ("DBAB") and prior as DB Alex. Brown LLC ("Alex. Brown LLC"), and prior as BT Alex. Brown Incorporated ("BTAB"). BTAB succeeded to the business of Alex. Brown & Sons Incorporated ("Alex. Brown") and BT Securities Corporation ("BTSec"). Alex. Brown had earlier succeeded to the broker-dealer business of Alex. Brown & Sons, which had later been named Alex. Brown Partners, a Maryland Limited Partnership (the "partnership"). BTSec was the former FRA Section 20 subsidiary of Bankers Trust Corporation. Initiation date: August 9, 2001. Description of the Action: In connection with MRD Review #200130290, the NASDR alleged that DBAB violated NASD Rule 4613 (E)(1)(c). NASDR alleged that on 62 occasions from April 1, 2001 to June 30, 2001, DBAB, a market maker in the relevant securities, caused a locked/crossed market condition prior to the market opening by entering a bid (ask) quotation that locked/crossed another market maker's quotations without immediately thereafter sending through Selectnet to the market maker(s) whose quote(s) it locked or crossed a trade-or-move message(s) that was at the receiving market maker's quoted price and whose aggregate size was at least 5000 shares. Disposition of the Proceeding: Resolution date: April 29, 2002. Without admitting or denying the allegations, DBAB agreed to a letter of acceptance, waiver and consent and to pay a $20,000.00 fine. The fine was paid on May 17, 2002. Resolution date: April 29, 2002. Without admitting or denying the allegations, DBAB agreed to a letter of acceptance, waiver and consent and to pay a $20,000.00 fine. The fine was paid on May 17, 2002. Kemper Distributors Inc. (KDI), a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: CAF000012 05/11/2000 National Association of Securities Dealers Regulation The Registrant has not been the subject of this matter: Scudder Investments Service Company, formerly known as Kemper Service Company KSvC"); Scudder Distributors, Inc., formerly known as Kemper Distributors Inc. ("KDI"); Deutsche Investment Management Americas Inc., formerly, Scudder Kemper Investments, Inc. ("Scudder Kemper"): and Scudder Investor Services, Inc. are wholly owned, indirect and/or direct subsidiaries of Deutsche Bank Americas Holding Corp. On May 11, 2000, NASD Regulation ("NASDR") accepted a Letter of Acceptance, Waiver and Consent ("AWC") from Kemper Distributors Inc. ("KDI"). KDI consented, without admitting or denying the alleged violations, to the findings contained in AWC. NASDR alleged that during the period of June 1996 through December 1997, KDI violated NASD Conduct Rules 2110, 2210 and 3010 with respect to advertisements and sales literature concerning mutual funds underwritten and distributed by KDI. NASDR alleged that KDI failed to file or timely file certain advertisements and sales literature with the NASDR, did not obtain the approval of a registered principal of firm prior to the use of certain advertisements and sales literature, and published certain advertisements that did not convey the risks of fluctuating prices inherent in investing or accurately depict fund performance. NASDR alleged that KDI did not establish or maintain supervisory procedures designed to comply with NASD Conduct Rule 2210. Prior to the date of the AWC, KDI adopted new policies and procedures to address the issues giving rise to the AWC. NASDR fined KDI $100,000 and required KDI to pre-file with NASDR for six months all advertisements depicting mutual fund performance information through the use of graphs, bar charts or pie charts. KDI consented, without admitting or denying the alleged violations, to the findings contained in AWC. NASDR fined KDI $100,000 and required certain actions of KDI for six months. Deutsche Banc Alex. Brown Inc. (DB Alex. Brown), a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: CMS000104 06/06/2000 National Association of Securities Dealers, Inc. ("NASD") The Registrant has not been the subject of this matter: Alex. Brown is NKA Deutsche Bank Securities Inc. ("DBSI") which is the legal name for this US registered broker-dealer. Deutsche Bank Capital Corporation was the predecessor firm of Deutsche Bank Securities Inc. "Deutsche Bank Alex. Brown, a division of Deutsche Bank Securities Inc." is the marketing name for its retail brokerage activities. DBSI was formerly known as Deutsche Banc Alex. Brown, Inc. ("DBAB") and prior as DB Alex. Brown LLC ("Alex. Brown LLC"), and prior as BT Alex. Brown Incorporated ("BTAB"). BTAB succeeded to the business of Alex. Brown & Sons Incorporated ("Alex. Brown") and BT Securities Corporation ("BTSec"). Alex. Brown had earlier succeeded to the broker-dealer business of Alex. Brown & Sons, which had later been named Alex. Brown Partners, a Maryland Limited Partnership (the "partnership"). BTSec was the former FRA Section 20 subsidiary of Bankers Trust Corporation. Initiation date: June 6, 2000. The National Association of Securities Dealers, Inc. ("NASD") alleged failure to accept or decline in ACT transactions in eligible securities within 20 minutes after execution of such transactions; failure to display immediately customer limit orders, when the orders were at a price that would have improved its bid or offer in each such security related to those orders, or when the full size of each such order were priced equal to its bid or offer and the national best bid or offer and the orders represented more than a de minimis change in relation to the size associated with its bid or offer in each security; and, failure to establish, maintain, and enforce written supervisory procedures reasonably designed to achieve compliance with the applicable securities laws and regulations, and the rules of the NASD concerning trade reporting, ACT compliance, best execution, limit order protection interpretation, locked and crossed markets, books and records, SEC order execution rules and 21(A) report issues. The current status is closed on June 6, 2000. A fine of $25,000.00 has been paid. Without admitting or denying the allegations, DB Alex. Brown agreed to a letter of acceptance, waiver and consent to pay the fine. Closed on June 6, 2000. A fine of $25,000.00 has been paid. Without admitting or denying the allegations, DB Alex. Brown agreed to a letter of acceptance, waiver and consent to pay the fine. Deutsche Banc Alex. Brown Inc. (DB Alex. Brown), a Control Affiliate of the Registrant. See also Description of the Action Docket/Case Number: CMS000105 06/06/2000 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Alex. Brown is NKA Deutsche Bank Securities Inc. ("DBSI") which is the legal name for this US registered broker-dealer. Deutsche Bank Capital Corporation was the predecessor firm of Deutsche Bank Securities Inc. "Deutsche Bank Alex. Brown, a division of Deutsche Bank Securities Inc." is the marketing name for its retail brokerage activities. DBSI was formerly known as Deutsche Banc Alex. Brown, Inc. ("DBAB") and prior as DB Alex. Brown LLC ("Alex. Brown LLC"), and prior as BT Alex. Brown Incorporated ("BTAB"). BTAB succeeded to the business of Alex. Brown & Sons Incorporated ("Alex. Brown") and BT Securities Corporation ("BTSec"). Alex. Brown had earlier succeeded to the broker-dealer business of Alex. Brown & Sons, which had later been named Alex. Brown Partners, a Maryland Limited Partnership (the "partnership"). BTSec was the former FRA Section 20 subsidiary of Bankers Trust Corporation. Initiation date: June 6, 2000. The National Association of Securities Dealers, Inc. ("NASD") alleged that DB Alex. Brown, a market maker in securities, without making 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 ask quotation in the NASDAQ stock market which caused a locked or crossed market condition to occur. The current status is closed on June 6, 2000. A fine of $3,000.00 has been paid. Without admitting or denying the allegations, DB Alex. Brown agreed to a letter of acceptance, waiver and consent to pay the fine. Closed on June 6, 2000. A fine of $3,000.00 has been paid. Without admitting or denying the allegations, DB Alex. Brown agreed to a letter of acceptance, waiver and consent to pay the fine. Deutsche Banc Alex. Brown Inc. (DB Alex. Brown), a Control Affiliate of the Registrant. See also Description of the Action Exchange Hearing Panel Decision 99-490 08/13/1999 New York Stock Exchange The Registrant has not been the subject of this matter: Deutsche Banc Alex. Brown Inc. is NKA Deutsche Bank Securities Inc. ("DBSI") which is the legal name for this US registered broker-dealer. Deutsche Bank Capital Corporation was the predecessor firm of Deutsche Bank Securities Inc. "Deutsche Bank Alex. Brown, a division of Deutsche Bank Securities Inc." is the marketing name for its retail brokerage activities. DBSI was formerly known as Deutsche Banc Alex. Brown, Inc. ("DBAB") and prior as DB Alex. Brown LLC ("Alex. Brown LLC"), and prior as BT Alex. Brown Incorporated ("BTAB"). BTAB succeeded to the business of Alex. Brown & Sons Incorporated ("Alex. Brown") and BT Securities Corporation ("BTSec"). Alex. Brown had earlier succeeded to the broker-dealer business of Alex. Brown & Sons, which had later been named Alex. Brown Partners, a Maryland Limited Partnership (the "partnership"). BTSec was the former FRA Section 20 subsidiary of Bankers Trust Corporation. Initiation date: June 23,1999. DB Alex. Brown violated SEC Reg.240.15C3-1, SEC Reg.240.17A-11(B), and SEC Reg.240.17A-11(D), in addition, violated SEC Reg.240.17A-5, SEC Reg.240.8(C)1 and 240.15C3-3, SEC Reg.240.17A-3 and 240.17A-4. The above-mentioned relate to financial reporting books and records violations. DB Alex. Brown was also in violation of NYSE rules 325, 440 and 342. The current status is closed on August 13, 1999. A fine of $175,000.00 has been paid. The settlement concluded the matter. No further action is required. Closed on August 13, 1999. A fine of $175,000.00 has been paid. The settlement concluded the matter. No further action is required. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: HPD#: 03-221 03/09/2004 New York Stock Exchange, Inc. The Registrant has not been the subject of this matter: Initiation date: November 4, 2003. The New York Stock Exchange, Inc. ("NYSE") alleged and DBSI, a broker-dealer under common control with the Registrant, without admitting or denying guilt consented to findings: that DBSI violated substantive provisions, failed to reasonably supervise and control the actions of its employees, and failed to establish a separate system of follow up and review, to ensure compliance with exchange rules, with respect to (A) the calculation and reporting of short interest; (B) compliance by its registered employees with the registration and continuing education requirements; (C) the issuance of accurate monthly accounts statements to institutional customers of the firm; and (D) its financial operations, specifically relating to reconciliation of ledgers. Sanction: the hearing panel imposed (A) a censure (B) a fine of $725,000, and (C) an undertaking. The current status is: closed on March 9, 2004. Without admitting or denying the findings of the NYSE's hearing panel, DBSI consented to the penalty. Sanction: the hearing panel imposed (A) a censure (B) a fine of $725,000, and (C) an undertaking. The current status is: closed on March 9, 2004. Without admitting or denying the findings of the NYSE's hearing panel, DBSI consented to the penalty. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CMS030303 01/15/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: December 21, 2003. The NASD alleged that DBSI, a broker-dealer under common control with the Registrant, violated NASD Conduct Rule 2110 and NASD Marketplace Rules 4632 and 6620(A) - DBSI incorrectly designated as "PRP" through ACT one last sale report of a transaction in a NASDAQ National Market ("NNM") security; failed to report the correct number of shares through ACT in last sale reports of riskless principal transactions in NNM securities; failed to report the correct price through ACT in last sale reports of riskless principal transactions in NNM securities; double reported to ACT one last sale report of a transaction in a NNM security; failed to submit, for the offsetting, riskless portion of transactions in NNM securities either: (A) a clearing only report with a capacity indicator of riskless principal, if a clearing report is necessary to clear the transaction; or (B) a non-tape, non-clearing report with a capacity indicator of riskless principal, if a clearing report is not necessary to clear the transaction; failed within 90 seconds after execution, to transmit to ACT last sale reports of transactions in OTC equity securities; and failed within 90 seconds after execution, to transmit to ACT last sale reports of transactions in OTC equity securities and failed to designate through ACT such last reports as late. The current status is: closed on January 15, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and paid a fine of $9,000.00. Closed on January 15, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and paid a fine of $9,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 02-12 06/18/2004 American Stock Exchange The Registrant has not been the subject of this matter: Initiation date: April 1, 2004. The American Stock Exchange alleged that DBSI violated Exchange Rule 30 and Article V, Section 4(H) of the Exchange constitution, in that during the period February 1998 through May 2003, the firm filed with the exchange inaccurate reports of short interest positions in securities on the Exchange; DBSI violated Exchange Rule 320 and Article V, Section 4(H) of the Exchange constitution in that the firm failed to establish and maintain appropriate policies, systems, and procedures of supervision and control, including written supervisory procedures, designed to ensure compliance with short interest requirements of the Exchange. The current status is: closed on June 18, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure and fined $225,000 in total. DBSI was required to submit to the Exchange supervisory procedures to address deficiencies along with the date the revised procedures were implemented. The fine of $112,500 to be paid to the AMEX (as part of a fine of $225,000 in total to be paid to the AMEX and the NASD) at their instruction was paid on July 9, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and a censure and fined $225,000 in total. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CMS040066 04/27/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: April 27, 2004. The NASD alleged that DBSI violated NASD Conduct Rules 2110, 3010, and 3360. DBSI's short interest reported to the NASD was inaccurate and short positions were incorrectly classified as type 1 or 2 accounts, rather than as type 5 accounts; failed to make corrections in a timely and effective manner such that short interest positions were reported to NASD prior to completion of procedures to review affiliate accounts and were reported to NASD inaccurate; incorrectly netted short positions against long positions and short interest reported to the NASD were inaccurate; and, its supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to applicable securities laws and regulations concerning short interest reporting. The current status is: closed on April 27, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure and fined $225,000 in total (to the NASD and the AMEX), that was paid on July 9, 2004. Closed on April 27, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent to a censure and fined $225,000 in total (to the NASD and the AMEX), that was paid on July 9, 2004. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CAF040037 05/18/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: May 18, 2004. The NASD alleged that DBSI violated NASD conduct rule 2110 in connection with the firm's allocation and sale of initial public offerings ("IPOS") from September 1999 through March 2000. The NASD found that DBSI received without inquiry $4.81 million in unusually high agency commissions on listed agency trades from 10 customers within one day of allocating IPO shares to such customers. The firm received commissions set by these customers of up to $1 per share to execute institutional sized agency trades in listed securities. By receiving these payments from certain customers without inquiry while providing the customers with IPO allocations the NASD found that, the firm failed to observe high standards of commercial honor and just and equitable principles of trade, in violation of NASD Conduct Rule 2110. DBSI neither admitted nor denied the NASD's findings. The current status is: closed on May 18, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure, a fine in the amount of $481,000, and disgorgement of $4,810,000, both of which were paid on May 20, 2004. Closed on May 18, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, a fine in the amount of $481,000, and disgorgement of $4,810,000. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CMS040065 04/27/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: April 27, 2004. In connection with MRD review #200022250, the NASD alleged that DBSI violated NASD conduct rules 2110, 3010, and 3360. DBSI submitted to the NASD its short interest position report which included a short interest position of 105,440,517 shares for 285 securities when the firm's actual short interest for the month was 53,867,000 shares in 306 securities; and, DBSI's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations concerning short interest reporting. The current status is: closed on April 27, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure and fine of $10,000 that was paid on May 17, 2004. Closed on April 27, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure and fine of $10,000 that was paid on May 17, 2004. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CMS040105 AWC 07/15/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: July 15, 2004. The NASD alleged violations of rules 2440, rule 2110, and IM-2440 in connection with DBSI's pricing of high yield and distressed corporate debt securities in 7 identified transactions. The NASD also alleged violations of rule 6420 for reporting inaccurate execution times for certain transactions in corporate debt securities, violations of rule 3110 and the recordkeeping provisions of the federal securities laws for failing to create and maintain required records associated with customer orders and trade executions for certain transactions in corporate debt securities, violations of NASD rule 1022 for registration failures, and violations of rule 3010 for supervisory failures associated with each of the alleged underlying violations. DBSI consented to make payments totaling $5 million, reflecting restitution payments to customers of $421,575 and the remainder as a fine paid to NASD (representing a $1,578,425 fine for the markup/markdown, registration and FIPS reporting violations, a fine of $1,500,000 for the supervision violations, and a fine of $1,500,000 for the books and records violations). DBSI made restitution payments to customers between July 12, 2004 and July 23, 2004 and made payment to the NASD on July 23, 2004. DBSI also consented to a censure and agreed to revise its written supervisory procedures to address the findings in the letter of acceptance, waiver and consent. The current status is closed on July 15, 2004. On July 12, 2004, DBSI submitted an AWC to the NASD, which was reviewed and accepted by the NASD on July 15, 2004. In the AWC, solely for the purpose of the proceeding any other action in which the NASD is a party and without admitting or denying the findings set forth in the AWC, DBSI consented to findings that DBSI violated certain NASD rules and the recordkeeping provisions of the federal securities laws as set forth above. In addition to the payment of the fine and restitution, DBSI agreed to a censure and to revise its written supervisory procedures. Closed on July 15, 2004. Without admitting or denying the findings DBSI consented to certain findings, agreed to censure, and to make payments totaling $5 million. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CMS040137 08/25/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: July 23, 2004. NASD alleged that DBSI violated NASD Marketplace Rule 4632 in connection with DBSI's failure to report required information for "At Risk" and "Riskless" principal transactions. The NASD also alleged violations by DBSI of SEC Rule 10B-10 for failure to provide written notification to customers that transactions were executed at an average price and incorrectly documenting the average price disclosure. The current status is closed on August 25, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver & consent ("AWC"), consenting to a censure and fine totaling $10,000, (comprised of a $5,000 fine for the trade reporting violations and a $5,000 fine for the SEC Rule 10B-10 violations), payable to the NASD. DBSI remitted said sum on September 23, 2004. Closed on August 25, 2004. Without admitting or denying the allegations, DBSI agreed to a letter of AWC consenting to a censure and fine totaling $10,000. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 2004-INV-12A 09/29/2004 Chicago Board of Trade The Registrant has not been the subject of this matter: Initiation date: August 23, 2004. The Chicago Board of Trade ("CBOT") alleged that Deutsche DBSI violated CBOT Regulation 9B.16, by virtue of Regulation 9B.07, in that cross trades executed by DBSI were not entered in accordance with prescribed time requirements and procedures. The CBOT also alleged DBSI violated Regulation 336.01, in that DBSI directly or indirectly guaranteed the execution of orders to purchase 10-year U.S. Treasury Note option contracts. The current status is closed on September 29, 2004. On that date, without admitting or denying the allegations set forth by CBOT in the settlement, DBSI consented to the alleged findings and fine in the total amount of $75,000. DBSI remitted said sum on October 26, 2004. Closed on September 29, 2004. Without admitting or denying the allegations set forth by CBOT in the settlement, DBSI consented to the alleged findings and fine in the amount of $75,000. DBSI remitted said sum on October 26, 2004. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: CLG050032 ("AWC") 03/22/2005 National Association of Securities Dealers, Inc. The Registrant has not been the subject of this matter: Initiation date: February 26, 2005. The National Association of Securities Dealers, Inc. ("NASD") alleged that DBSI violated NASD conduct rules 2110 and 2320, in that DBSI failed to use reasonable diligence to ascertain the best inter-dealer market and failed to buy or sell in such market so that the resultant price to its customer was as favorable as possible under prevailing market conditions. The current status is closed on 03/22/2005. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consisting of a censure and fine of $15,000, payable to the NASD, and restitution payments to customers in the amount of $323.87 plus any interest due. DBSI remitted the fine on April 11, 2005, the restitution payments will be paid. Closed on 03/22/2005. Without admitting or denying the allegations, DBSI agreed to an AWC consisting of a censure and fine of $15,000, and restitution payments to customers in the amount of $323.87. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: MRD20050002625-01 09/09/2005 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: July 22, 2004. Following examination MRD200447866 on 07/22/04 (subsequently designated as MRD20050002625-01), the National Association of Securities Dealers ("NASD") alleged that DBSI (or the "Firm") violated: (1) NASD Conduct Rule 3370 because it effected five short sales for the Firm's proprietary account and failed to make an affirmative determination that DBSI could borrow or deliver the securities by settlement date; (2) NASD Marketplace Rule 6130(D), because a third party acting on DBSI's behalf failed to report to the NASDAQ Market Center the correct symbol indicating whether, in 291 transactions, DBSI acted in a principal or agency capacity; and (3) SEC Rule 10B-10 because DBSI's failure to provide written notification to its customers on seven occasions that transactions were executed at average price, and failed to provide written notification to its customers on thirteen occasions the correct capacity in which it was acting. The current status is closed on 09/09/2005. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and a fine of $15,000 (comprised of a $5,000 fine for the affirmative determination of violations, $5,000 fine for the trade reporting violations, and a $5,000 fine for SEC Rule 10B-10 violations). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent and a fine of $15,000. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: HPD# 05-045 02/02/2006 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: March 4, 2005. The NYSE alleged, and DBSI, without admitting or denying guilt consented to findings that DBSI violated Exchange Rule 451 in that the firm, on numerous occasions, failed to transmit to its customers who were beneficial owners of stock, via its service provider, accurate information in connection with proxy solicitations; that the firm violated Securities and Exchange Commission Rule 240.17A-4, Exchange Rule 440, and Exchange Rule 452.20, in that the firm failed to retain all proxy solicitation records for period of not less than three years, the first two in an easily accessible location; that the firm engaged in conduct inconsistent with just and equitable principles of trade, in that the firm: (A) failed to implement adequate policies and procedures to adjust its record of stock ownership so that votes of its customers who were beneficial owners of stock were accurately tallied by the tabulator for proxy voting purposes; (B) on numerous occasions, voted more shares than it was entitled to vote in proxy matters; (C) failed to assure that its systems and procedures provided for the accurate submission of proxy data to proxy tabulators; that the firm violated Exchange Rule 401 by failing to adhere to the principles of good business practice in that the firm, on numerous occasions, failed to reconcile its record of stock ownership so that votes of beneficial owners were accurately tallied by the tabulator for proxy voting purposes; and that the firm violated Exchange Rule 342 in that the firm failed to (A) supervise proxy operations to prevent overvoting; provide for and implement written procedures for proxy operations and supervision of the proxy function; and (C) provide for and implement written procedures for supervision of its proxy service provider. The current status is closed on 02/02/2006. The Board imposed the penalty consented to by the parties, that of a censure and a $1 million dollar fine. Without admitting or denying the allegations, DBSI agreed to the censure and $1 million dollar fine. The entire $1 million fine was levied against DBSI. The fine was paid on March 10, 2006. Closed on 02/02/2006. Without admitting or denying the allegations, DBSI consented to the censure and a $1 million dollar fine. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant ISE Unknown 12/20/2005 International Securities Exchange, Inc. The Registrant has not been the subject of this matter: Initiation date: September 15, 2005. The International Securities Exchange, Inc. ("ISE") alleged that DBSI violated ISE Rules 713(B), 713(C), 713(E), 803(A), 804(D) and SEC 11AC1-1, when on a number of occasions in the period October 2003 through October 2004, DBSI failed to properly handle public customer orders that it held for manual handling, including failing to allocate public customer orders to the market participant representing the best quotation on the Exchange. The ISE further alleged that DBSI violated ISE Rules 803(A), 803(C)(2), and 804(A), when on a number of occasions in the period January 2004 through June 2004, DBSI failed to properly handle public customer orders that it held for manual handling, including failing to provide public customer orders with the best price as represented at another exchange. The current status is closed on 12/20/2005. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver, & consent to a censure and a fine of $75,000 (comprised of $50,000 for the trade reporting violations and $25,000 for the firm quote violations). The entire $75,000 fine was levied against DBSI. The fine was paid on February 14, 2006. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver, & consent to a censure and a fine of $75,000 (comprised of $50,000 for the trade reporting violations and $25,000 for the firm quote violations). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 20050004905 02/06/2006 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: January 3, 2006. National Association of Securities Dealers ("NASD") alleged that DBSI violated NASD Marketplace Rule 6620(A) and NASD Conduct Rules 2110 and 3010 when, on a number of occasions from September 1, 2004 through December 31, 2004, DBSI (I) failed to transmit through NASDAQ Market Center within 90 seconds after execution certain last sale reports of transactions in OTC equity securities; (II) failed to transmit through NASDAQ Market Center within 90 seconds after execution certain last sale reports of transactions in OTC equity securities and failed to designate through NASDAQ Market Center such last sales reports as late; (III) incorrectly designated as "SLD" certain last sales reports of transactions in OTC equity securities executed outside normal market hours; (IV) failed to enforce its written supervisory procedures for trade reporting. The current status is closed 02/06/2006. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent; to a censure and a fine of $15,000 (comprised of a $10,000 fine for trade reporting violations and a $5,000 fine for supervisory violations). DBSI consented to a censure and a fine totaling $15,000 (comprised of a $10,000 fine for trade reporting violations, and a $5,000 fine for supervision violations). The fine was paid on March 3, 2006. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver, and consent; to a censure, and a fine of $15,000. Deutsche Bank Securities Inc. (DBSI or the Firm), a Control Affiliate of the Registrant Docket/Case Number: 2005-60, 112, 59 03/08/2006 International Securities Exchange, Inc. The Registrant has not been the subject of this matter: Initiation date: January 10, 2006. The International Securities Exchange, Inc. ("ISE") alleged that DBSI violated ISE Rule 1901(C)(2) when: (1) on a number of instances between January 1, 2005 and June 30, 2005, when sending P/A orders that were larger than the Firm customer quote size, the Firm sent an initial P/A order that was not for the Firm customer quote size; and (2) in some instances when sending a P/A order that was larger than the Firm customer quote size, DBSI sent an additional P/A order when such order was not for at least the lesser of the size of the disseminated quotation, 100 contracts, or the entire remainder of the public customer order; and ISE further alleged that DBSI violated Rule 400 when: (1) on certain instances between January 2005 and March 2005, the Firm sent P/A orders through the linkage that did not reflect an unexecuted public customer order; and (2) in some instances, the Firm failed to pass the execution of the P/A orders to the public customer. The current status is closed on 03/08/2006. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and a fine of $15,000 (comprised of a $5,000 fine for violations in ISE No. 2005-60, $5,000 for the violation in ISE No. 2005-112, and $5,000 for the violations in ISE No. 2005-59). DBSI agreed to a censure and a fine totaling $15,000 (comprised of a $5,000 fine for violations in ISE No. 2005-60, $5,000 for the violation in ISE No. 2005-112, and $5,000 for the violations in ISE No. 2005-59). The fine was paid on March 14, 2006. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and fine. Deutsche Bank Securities Inc. (DBSI ), a Control Affiliate of the Registrant Docket/Case Number: 2006-INV-12E 07/20/2006 Chicago Board of Trade The Registrant has not been the subject of this matter: Initiation date: December 2, 2005. On July 20, 2006, the Chicago Board of Trade ("CBOT") Floor Governors Committee charged DBSI with having violated CBOT Regulation 9B.13 in that its employees engaged in pre-execution conversations and failed to enter cross trades in accordance with required time parameters and procedures. The CBOT simultaneously accepted DBSI's offer of settlement in which, without admitting or denying the allegations set forth in the complaint, DBSI agreed to pay a fine of $25,000. The current status is closed on 07/20/2006. The fine of $25,000 was paid on 8/7/06. Closed on 07/20/2006. Without admitting or denying the allegations set forth in the complaint, DBSI agreed to pay a fine of $25,000. The fine of $25,000 was paid on 8/7/06. DWS Scudder Distributors Inc. (SDI), a Control Affiliate of the Registrant Docket/Case Number: EAF0400170003 09/28/2006 National Association of Securities Dealers The Registrant has not been the subject of this matter: This matter is also related to a prior Registrant TA-1 filing , item 10(C)(2). on the form and identified as Title of Action 34-54529. The National Association of Securities Dealers ("NASD") alleged that SDI requested the direction of certain fund portfolio brokerage commissions to broker-dealers who also sold fund shares. The current status is closed on 09/28/2006. The matter was resolved by the NASD's acceptance of SDI's letter of Acceptance, Waiver and Consent. Closed on 09/28/2006. The matter was resolved by the NASD's acceptance of SDI's letter of Acceptance, Waiver and Consent. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Decision No. 06-217 02/07/2007 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: 8/18/2004. During the period of July 2002 through June 2004, DBSI failed to include required conflict disclosures on its published reports in violation of NYSE Rule 472 (K). DBSI also violated NYSE Rule 476(A)(6) by engaging in conduct inconsistent with just and equitable principles of trade by publishing research reports without required conflict of interest disclosures and violated NYSE Rule 342 in failing to establish and maintain appropriate procedures and systems and establish separate systems of follow-up and review to adequately supervise the inclusion of required conflict of interest disclosures on published research reports and in connection with research analysts' public appearances. On or about July 26, 2004, DBSI reported to the SEC, the NYSE and the NASD that it had experienced problems with its collections and processing of research report conflict disclosures. A subsequent meeting was held with the SEC on July 29, 2004. Thereafter, NYSE enforcement notified the firm of its investigation of the reported matters, which were combined with findings resulting from a sales practice examination conducted by the NYSE in April and May 2004. Pursuant to NYSE Rule 472 DBSI was required to implement systems to maintain and update conflict of interest disclosure information for inclusion in published research reports and in connection with firm research analysts' public appearances. The $950,000.00 fine was paid on February 7, 2007. The $950,000.00 fine was paid on February 7, 2007. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: Decision 06-157 12/21/2006 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: 12/18/2006. On December 21, 2006 the NYSE instituted and settled a disciplinary proceeding against Deutsche Bank Securities Inc. ("DBSI") in connection with DBSI's alleged violations of NYSE Rules 401 and 476(A)(6) for failure to adhere to principles of good business practice and engaging in conduct inconsistent with just and equitable principles of trade in connection with having violated Rule 22C-1, as adopted under section 22(C) of the investment company act of 1940. The NYSE alleged that DBSI violated the above cited Rules by the conduct of a DBSI former registered representative who entered late trades for at least one customer. More specifically, the NYSE alleged that the registered representative received and entered orders to purchase, redeem or exchange mutual fund shares after 4:00 P.M. Eastern time market close on certain occasions where customer orders received before 4:00 P.M. were blocked by fund companies as market timing trades. The customer orders entered into after 4:00 P.M. served as substitute orders for those that had been previously received and blocked before 4:00 P.M. The NYSE further alleged that DBSI violated NYSE Rule 342 by failing to reasonably supervise the registered representative and failing to establish and maintain appropriate procedures for supervision and control effective to detect and prevent the registered representative's deceptive customer trading of mutual funds. DBSI, without admitting or denying the allegations or findings, consented to censure and total payment of $442,954. In view of the above findings the NYSE imposed the penalty consented to by DBSI of a censure and a total payment in the amount of $442,954. Payment of the $442,954 by DBSI pursuant to an order issued in a related SEC proceeding against DBSI shall be deemed payment in satisfaction of the NYSE stipulation and consent. DBSI, without admitting or denying the allegations or findings, consented to censure and total payment of $442,954. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE NO. 06-17 01/05/2007 New York Stock Exchange ARCA The Registrant has not been the subject of this matter. Initiation date: 12/07/2006. Without admitting or denying the allegations, DBSI settled a disciplinary action by NYSE ARCA alleging that between April 4, 2005 and June 16, 2005, DBSI failed to aggregate odd lot orders into round lots as required by NYSE ARCA Equities Rules 7.38(C) and 6.2(B), failed to exercise sufficient due diligence to learn essential facts relating to such orders as required by NYSE ARCA Equities Rule 9.2(A), failed to diligently supervise a customer account in connection with such orders as required by NYSE ARCA Equities Rule 9.2(B), and failed to supervise its business operations and associated persons in connection with such orders and account as required by NYSE ARCA Equities Rule 6.18(A). DBSI was censured and fined $200,000. NYSE ARCA informed DBSI of the December 7, 2006 final decision in this matter on December 12, 2006. DBSI consented to a decision and order of offer of settlement, a censure and a fine of $200,000.00 (The fine was paid on 1/5/07). Without admitting or denying the allegations, DBSI settled a disciplinary action by NYSE ARCA. DBSI was censured and fined $200,000. (The fine was paid on 1/5/07.) Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 06-RFT-024 01/08/2007 Chicago Board of Trade The Registrant has not been the subject of this matter. Initiation date: 12/14/2006. DBSI paid a $2,000 fine to resolve the Chicago Board of Trade's preliminary conclusion that DBSI had violated Regulation 465.01 by failing to enter order entry time stamps on 21 customer orders during the period from June 1, 2006 and June 8, 2006. CBOT attempted to inform DBSI of this preliminary conclusion by an incorrectly addressed letter dated November 2, 2006. DBSI did not receive CBOT's November 2, 2006 letter until December 14, 2006. DBSI paid the $2,000 fine on January 8, 2007. Without admitting or denying, DBSI paid a $2,000 fine to resolve the Chicago Board of Trade's preliminary conclusion that DBSI had violated Regulation 465.01 by failing to enter order entry time stamps on 21 customer orders during the period from June 1, 2006 and June 8, 2006. CBOT attempted to inform DBSI of this preliminary conclusion by an incorrectly addressed letter dated November 2, 2006. DBSI did not receive CBOT's November 2, 2006 letter until December 14, 2006. DBSI consented to a fine of $2,000 (The fine was paid on January 8, 2007). Without admitting or denying, DBSI paid a $2,000 fine on January 8, 2007 to resolve the Chicago Board of Trade's preliminary conclusion that DBSI had violated Regulation 465.01 by failing to enter order entry time stamps on 21 customer orders. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 2005001465501 01/05/2007 National Association of Securities Dealers The Registrant has not been the subject of this matter. Initiation date: 12/15/2006. NASD alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Marketplace Rule 6955(A) in that DBSI submitted to OATS incorrect "order sent" timestamps for orders routed to its affiliates, DBPR and DBPT. As a result of the inaccurate timestamps, the route reports failed to match DBPR's or DBPT's new order reports. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $25,000.00. DBSI consented to a censure and a fine of $25,000.00 (The fine was paid on 1/5/2007). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $25,000.00. (The fine was paid on 1/5/2007). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: MRD # 20050004547-01 09/09/2005 National Association of Securities Dealers The Registrant has not been the subject of this matter. Initiation date: February 28, 2005. National Association of Securities Dealers ("NASD") alleges that DBSI failed to report 4,749 trace transactions within thirty minutes as required by NASD Rule 6230(A). The NASD also alleges pursuant to NASD Rule 2110 & 3010, that written supervisory procedures regarding trace reporting in place at DBSI, were not adequately enforced. The current status is closed on 09/09/2005. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and a fine of $15,000 (comprised of a $10,000 fine for the trace late reporting violations and a $5,000 fine for the supervision violations). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, and a fine of $15,000 (comprised of a $10,000 fine for the trace late reporting violations and a $5,000 fine for the supervision violations). Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: CMS040117 08/19/2004 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: 06/22/2004. NASD alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Marketplace Rule 6955(A) and NASD Conduct Rule 2110 in connection with DBSI's failure to comply with the reporting rules applicable to the order audit trail system ("OATS"). The NASD also alleged violations by DBSI of NASD Conduct Rules 2110 and 3010 for failure to designate an appropriate registered principal(s) with authority to carry out the supervisory responsibilities in relation to OATS reporting. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver & consent ("AWC"), consenting to a censure and fine of $15,000. DBSI consented to a censure and fine totaling $15,000, (comprised of a $10,000 fine for the OATS violations and $5,000 fine for the supervisory procedures violations), payable to the NASD. DBSI remitted said sum on September 7, 2004. (Occurrence 1217556) Without admitting or denying the allegations, DBSI consented to a censure and fine totaling $15,000, (comprised of $10,000 for the OATS violations and $5,000 for the supervisory procedures violations). DBSI remitted said sum on September 7, 2004. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 06-218 01/15/2007 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: 03/03/2004. The New York Stock Exchange ("NYSE") alleged that DBSI violated NYSE Rule 342 by failing to supervise an employee who used and distributed confidential and proprietary information of a former employee; that DBSI violated NYSE Rule 123C by failing to reasonably supervise MOC/LOC and audit trail activities, NYSE Rule 401 regarding the requirements for maintaining prime brokerage accounts and failing to timely notify NYSE of termination of floor employees and timely return floor badges of terminated floor employees. Wei Wu was employed by DBSI in its Index Department Group from on or about August 20, 2001 through on or about April 11, 2003. It is alleged that DBSI failed to reasonably supervise Wu's accessing and using his former member firm employer's password protected information. Wu utilized his former employer's research reports and bond indices data on more than 200 occasions. Wu was supervised by an individual working out of London employed by a non-member firm, Deutsche Bank AG. DBSI failed The matter was resolved on 01/15/2007. A monetary fine of $325,000 and censure were ordered. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: 20041000088-01 03/12/2007 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: 03/12/2007. NASD alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Conduct Rules 2110, 3010, and 3370, in that DBSI accepted 523 customer short sale orders from multiple accounts and, for each order, failed to make/annotate an affirmative determination that the firm would receive delivery of the security on behalf of the customer or that the firm could borrow the security on behalf of the customer for delivery by settlement date. DBSI failed to enforce its written supervisory procedures which specified that the designated supervisor was responsible for the daily review of all exceptions generated for instances in which the securities lending department did not have a corresponding locate or the number of shares exceeded the locate. NASD also alleged that DBSI failed to report, pursuant to MSRB Rule G-14, 102 customer transactions in municipal securities within 15 minutes of the time of execution. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $45,000.00. (Occurrence 1344123). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $45,000.00. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant 06-RFT-055 05/22/2007 Chicago Board of Trade The Registrant has not been the subject of this matter: Initiation date: May 22, 2007. The Chicago Board of Trade ("CBOT") during a routine Computerized Trading Reconstruction system ("CTR") examination alleged that Deutsche Bank Securities Inc. ("DBSI") violated regulations 332.08 and 465.01 in that trade data for certain trade dates reflected a CTR error rate higher than the CBOT's acceptable threshold. Without admitting or denying the allegations, DBSI agreed to pay a fine of $2,100.00. The fine was paid on June 13, 2007. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 20060054835-01 06/12/2007 National Association of Securities Dealers, Inc The Registrant has not been the subject of this matter: Initiation date: June 12, 2007. The NASD alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Market Place Rules 4632, 6130(D) and 6955(A), in that DBSI failed to submit to the trade reporting facility for the offsetting "Riskless" portion of 476 "Riskless" principal transactions in designated securities, either a clearing-only report with the capacity indicator or a non-tape, non-clearing report with a capacity indicator of "Riskless Principal." DBSI is also alleged to have failed to report to the trade reporting facility, two last sale reports of transactions in designated securities. NASD alleged that DBSI failed to report to the trade reporting facility, the correct symbol indicating whether a transaction was a buy, sell short, sell short exempt or cross for 55 transactions in reportable securities in violation of NASD Marketplace Rule 6130(D). NASD alleged that DBSI failed to submit required information to OATS in connection with nine orders representing approximately 12 percent of the sample of reports reviewed in TMMS examination in violation of NASD marketplace Rule 6955(A). NASD alleged that DBSI failed to mark the firm's ledger as short or short exempt in the execution of 64 long sale transactions in violation of SEC Rule 200(G) of Regulation SHO and failed, on 16 occasions, to provide written notification disclosing to its customer its correct capacity in the transaction and on one occasion, failed to provide to its customer the correct average price in violation of SEC Rule 10B-10. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $30,000.00 (comprised of a $5,000.00 for trade violations, a $5,000.00 for SEC Rule 200(G) violations, a $10,000.00 fine for OATS violations, and a $10,000.00 for SEC Rule 10B-10 violations). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a censure and fine of $30,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 20060047177-01 09/27/2007 National Association of Securities Dealers The Registrant has not been the subject of this matter: Initiation date: 09/27/2007. In connection with review 20060047177, the NASD conducted a review of Deutsche Bank Securities Inc.'s ("DBSI's") compliance with rules applicable to the order audit trail system ("OATS") during the period of October 1, 2005 through December 31, 2005. The NASD alleged during the review period, DBSI submitted to OATS 2,144 reportable order events ("ROES") that were rejected by OATS for context syntax errors. DBSI did not repair 1,412 of the rejected ROE's, representing approximately 66 percent of all rejected ROES. This conduct constitutes separate and distinct violations of NASD Marketplace Rule 6955 (A). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $10,000.00. The fine was paid on 10/19/2007. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $10,000.00. The fine was paid on 10/19/2007. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 2006006015001 09/27/2007 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Initiation date: 09/27/2007. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") failed to report to TRACE, 2,429 transactions in TRACE eligible securities executed on a business day during TRACE system hours within the required 15 minutes of the time of execution in violation of NASD Marketplace Rule 6230(A). The late transactions constituted approximately 8% of all transactions in TRACE eligible securities that the firm was required to report to TRACE during the period April 1, 2006 through June 20, 2006. The conduct constituted separate and distinct violation of 6230(A) and a pattern of late reporting without exceptional circumstances in violation of NASD conduct Rule 2110. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a $20,000 fine and censure. The fine was paid on 10/19/2007. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a $20,000 fine and censure. The fine was paid on 10/19/2007. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: NYSE Hearing Decision 07-120 10/02/2007 New York Stock Exchange The Registrant has not been the subject of this matter: Initiation date: 10/18/2004. NYSE alleged that during the period July 1, 2003 through October 31, 2004, Deutsche Bank Securities Inc. ("DBSI") failed to have appropriate policies and procedures relating to the delivery of prospectuses and offering documents to customers who purchased certain registered securities and exchange traded funds. It was also alleged that failure to do so further caused DBSI to experience certain systemic deficiencies relating to the delivery of offering documents to certain customers who purchased securities and that DBSI failed to provide for adequate supervisory controls and review procedures. DBSI, without admitting or denying guilt, consented to a finding by an NYSE hearing officer that it violated NYSE Rule 401(A) by failing to adhere to the principles of good business practice by failing to ensure the delivery of prospectuses in connection with certain sales of registered securities in violation of Section 5(B)(2) of the Securities Act of 1933. In addition, DBSI consented to a finding that it had violated NYSE Rule 1100(B) by failing to deliver product descriptions to certain customers who purchased certain exchange traded funds and consented to a finding that DBSI had violated NYSE Rule 342 by failing to provide for, establish and maintain appropriate procedures of supervision and control, including a system of follow up and review, with respect to its operational and technological activities relating to the delivery of product descriptions and prospectuses. The hearing officer noted that DBSI cooperated fully in responding to enforcement's investigation and had already developed and implemented new written supervisory and operational policies and procedures relating to the delivery of prospectuses and product descriptions. DBSI, without admitting or denying guilt, consented to a finding by an NYSE hearing officer that it violated NYSE Rule 401(A) by failing to adhere to the principles of good business practice; accepted a fine of $1,250,000.00 and censure. DBSI agreed to an undertaking to provide NYSE Enforcement, within 90 days of the date the decision becomes final, with a written certification that DBSI's current policies and procedures, including written supervisory and operational policies and procedures, regarding the delivery of prospectuses and new product descriptions are reasonably designed to ensure compliance with federal securities laws and NYSE rules applicable to the delivery of prospectuses and product descriptions. DBSI, without admitting or denying guilt, consented to a finding by an NYSE hearing officer; accepted a fine of $1,250,000.00 and accepted censure. See "Description of Action" above. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 20060067543-01 12/18/2007 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Initiation date: 12/18/2007. Financial Industry Regulatory Authority ("FINRA") alleged that nineteen firms including Deutsche Bank Securities Inc. ("DBSI") violated NASD Conduct Rules 2110, 3010, 3310 in that the firms did not determine whether the aggregate trade volumes in certain securities that they advertised in Autex, Bloomberg and / or Reuters in August 2006 accurately reflected their executed trade volumes. In DBSI's case, FINRA alleged that the advertised aggregate trade volume for two equity securities exceeded the firm's executed trade volume for those securities. FINRA further alleged that the firm's supervisory system was not reasonably designed to achieve compliance with respect to the advertising rules. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a $150,000.00 fine and censure. DBSI consented to a censure and a fine of $150,000.00. The fine was paid on January 9, 2008. DBSI was also required to revise its written supervisory procedures with respect to compliance with NASD Rule 3310 within 30 days of acceptance of the AWC. DBSI has completed the required revisions. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent, consenting to a $150,000.00 fine and censure. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: AMEX CASE NO. 06-338 03/19/2008 American Stock Exchange ("AMEX") The Registrant has not been the subject of this matter: Initiation date 01/14/ 2008. AMEX alleged that Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 208 on April 19, 2005, by accepting from a customer multiple odd-lot orders, rather than round lot orders and placing such multiple orders into the firm's electronic order entry system, thereby violating Exchange Rules 320(B) and (C) it was further alleged that during the relevant period, DBSI failed to establish and maintain adequate policies, systems and procedures of supervision and control, including written supervisory procedures, and failed to establish a separate system to follow up and review, to ensure compliance with Exchange Rule 208, in particular, odd-lot trading practices. Without admitting or denying the allegations, DBSI entered into a stipulation and consent to penalty, consenting to a $10,000.00 fine and censure. Without admitting or denying the allegations, DBSI consented to a censure and a fine of $10,000.00. The fine was paid on April 9, 2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: NYSE HBD# 08-27 06/09/2008 New York Stock Exchange Division Of Enforcement The Registrant has not been the subject of this matter: Initiation date 5/15/2008. The New York Stock Exchange ("NYSE") alleged that Deutsche Bank Securities Inc. ("DBSI") violated Rules 80A and 476(A) (10). Without admitting or denying any allegations or findings, and for the sole purpose of settling this proceeding, DBSI and the NYSE entered a stipulation of facts and consent to penalty that during the period of June and July 2006, 1) DBSI violated NYSE Rule 80A by introducing for execution on the NYSE ninety-three baskets of index arbitrage orders without the appropriate tick restrictions when an NYSE Rule 80A collar was in place and; 2) violated NYSE Rule 476(A)(10), on six trade dates, by failing to submit to the NYSE accurate daily program trade reports relating to aforementioned index arbitrage orders. On May 15, 2008, the NYSE hearing officer accepted the stipulation. Without admitting or denying the allegations, DBSI agreed to a stipulation and censure consenting to a fine of $35,000.00. Without admitting or denying the allegations, DBSI agreed to a stipulation and censure, consenting to a fine of $35,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: FINRA 20050018280-01 06/26/2008 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Initiation date 6/26/2008. It was alleged that: DBSI, in May 2006, had a fail to deliver position in a threshold security for thirteen consecutive settlement days and failed to immediately thereafter close it out, thereby allegedly violating Rule 203(B)(3). During the periods July 1, 2005 through December 31, 2005, DBSI reported to OATS route or combined order/route reports that the OATS system was unable to link to the related orders routed to OATS allegedly due to inaccurate, incomplete or improperly formatted data. The conduct allegedly violated NASD Marketplace Rule 6955(A). DBSI failed, within 90 seconds after execution, to transmit to the Trade Reporting Facility ("TRF"), formerly the NASDAQ Market Center ("NMC"), last sale reports of transactions during the period December 1, 2005 through April 30, 2006. The conduct allegedly violated NASD Marketplace 4632(A). DBSI transmitted to the TRF ten last sale reports of transactions and failed to append as required the ".W" modifier. The conduct allegedly violated NASD Marketplace Rule 4632(A)(6). DBSI, during the period May 1, 2006 through August 31, 2006, failed to accept or decline as required in the TRF transactions within twenty minutes after execution. The conduct allegedly violated NASD Marketplace Rule 6130(B) and NASD Conduct Rule 2110. DBSI failed, within 90 seconds after execution, to transmit to the TRF last sale reports of transactions and failed to designate to the TRF certain of those reports as late. The conduct allegedly violated of NASD Conduct Rule 2110 and NASD Marketplace Rule 6420(A). DBSI, without admitting or denying the allegations consented to the imposition of a censure and a fine of $37,500 (comprised of a $7,500 fine for the Reg. SHO violations; a $15,000 fine for the OATS violations; and a $15,000 fine for the trade reporting violations). DBSI consented to a censure and a fine of $37,500.00. The fine was paid on July 22, 2008. DBSI consented to a censure and a fine of $37,500.00. The fine was paid on July 22, 2008. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Enforcement Decision No. 08-AE-02 08/28/2008 NYSE Arca Equities, Inc. The Registrant has not been the subject of this matter: Initiation date 8/28/2008. NYSE Arca Equities, Inc. alleged that between January 2005 through approximately October 2006 (the "relevant period"), Deutsche Bank Securities Inc. ("DBSI"), with respect to at least five of its 19 proprietary trading desks (the "five desks"), failed to comply with certain NYSE Arca Equities rules and regulation SHO ("Reg SHO") requirements with respect to its execution and supervision of the short sale orders described below. Specifically, NYSE Arca Equities, Inc. alleged the firm effected an unquantified but significant number of short sales on at least the five desks in securities that were not on the firm easy-to-borrow list without having borrowed the securities or entered into bona-fide arrangements to borrow the securities, or having reasonable grounds to believe that the securities could be borrowed for delivery when due, and without the proper documentation of such. Further, NYSE Arca Equities, Inc. alleged at least two of such desks did not properly adhere to the independent trading unit aggregation requirements and one trader on each of the two desks did not correctly mark an unquantified but significant number of proprietary sell orders. As a result, certain short sales allegedly were incorrectly marked long, and some of those orders allegedly were improperly executed. NYSE Arca Equities, Inc. also alleged the firm failed to adequately supervise certain traders on at least the five desks and failed to maintain and enforce written supervisory procedures concerning proprietary short sales in a manner reasonably designed to achieve compliance with the relevant provisions of Reg SHO and NYSE Arca Equities rules. Without admitting or denying the allegations, DBSI consented to a decision and order of offer of settlement, a censure and a fine of $575,000.00. (The fine was paid on 9/12/08). Without admitting or denying the allegations, DBSI consented to a decision and order of offer of settlement, a censure and a fine of $575,000.00. (The fine was paid on 9/12/08). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FINRA 2006005064401 02/05/2009 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Initiation date 2/5/2009. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI"): (1) submitted certain inaccurate OATS reports in December 2005 in violation of NASD Rule 6995(A); (2) failed to timely report certain transactions to TRACE during the period from January 1, 2007 through March 31, 2007 in violation of NASD Rules 6230(A) and 2110; (3) failed to timely report certain information concerning certain municipal securities transactions to RTRS during the period from July 1, 2007 through September 30, 2007 in violation of MSRB Rule G-14; (4) failed to timely report certain transactions to the NNTRF during the period from January 1, 2007 through April 30, 2007 in violation of NASD Rule 6130 (G); (5) failed to provide written notification to certain customers of information relating to certain transactions during the period from January 4-7, 2008 in violation of SEC Rule 10B-10; and (6) failed to timely report certain transactions to the NNTRF during the period from January 1, 2008 through April 30, 2008 in violation of NASD Rule 6130(G). Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $43,000.00. The fine was (comprised of a $10,000 fine for OATS violations, a $10,000 fine for TRACE violations, a $10,000 fine for MSRB violations, a $10,000 fine for violations of NASD Rule 6130, and $3,000 fine for SEC Rule 10-B10 violations). DBSI consented to a censure and a fine of $43,000.00. The fine was paid on 2/19/2009. Without admitting or denying the allegations, DBSI consented to a censure and a fine of $43,000.00. The fine was paid on 2/19/2009. Deutsche Bank AG (DBAG) Occurrence 1457357 04/20/2009 New York Mercantile Exchange ("NYMEX") The Registrant has not been the subject of this matter: Initiation date 4/20/2009. NYMEX alleged that DBAG violated Rule 9a.36, in that DBAG had a second position limit violation within a 12 month period. DBAG was summarily fined in the amount of $5,000.00, and informed that any further violation in accordance with this Rule will automatically result in a hearing before the Probable Cause Committee ("PCC"). Without admitting or denying the allegations DBAG paid the fine of $5,000.00. DBAG consented to a fine of $5,000.00. The fine was paid on May 8, 2009. Without admitting or denying the allegations DBAG paid the fine of $5,000.00. DBAG consented to a fine of $5,000.00. The fine was paid on May 8, 2009. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 09-05550-CTRA 05/29/2009 Chicago Board Of Trade ("CBOT") The Registrant has not been the subject of this matter: Initiation date 5/29/2009. The Chicago Board Of Trade ("CBOT") during a routine Computerized Trading Reconstruction system ("CTR") examination alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 536.F in that trade data for certain trade dates reflected a CTR error rate higher than the CBOT's acceptable threshold. Without admitting or denying the allegations, DBSI agreed to pay the fine of $2,500.00. The fine will be debited from DBSI's CBOT account. Without admitting or denying the allegations, DBSI agreed to pay the fine of $2,500.00. The fine will be debited from DBSI's CBOT account. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 09-ARCA-8 09/04/2009 NYSE ARCA, Inc. The Registrant has not been the subject of this matter: Initiation date 9/4/2009. Without admitting or denying the allegations, Deutsche Bank Securities Inc. ("DBSI") settled the alleged violations of NYSE ARCA Equities Rules 6.18(B) and (C), which were the result of a programming glitch in DBSI's NTRADE algorithmic order routing and trading platform and an inadvertent filtering mistake (a programming mistake) in connection with an exception report relating to its Arina trading platform. DBSI promptly corrected these issues when it became aware of them. Censure and fine of $50,000 against DBSI was paid on September 29, 2009. Without admitting or denying the allegations, DBSI settled the alleged violations and paid a fine of $50,000 on September 29, 2009. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 20060054508-01 09/22/2009 FINRA The Registrant has not been the subject of this matter: Initiation date 9/22/2009. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") failed to establish adequate supervisory procedures and systems for the outsourcing of communications with its customers about the sale of Vonage LLC securities in connection with Vonage's Directed Share Program, which was part of Vonage's initial public offering in May 2006. DBSI executed an AWC without admitting or denying FINRA's findings. FINRA found that DBSI, one of three lead underwriters for the May 24, 2006 initial public offering of the common stock of Vonage LLC, failed to establish supervisory procedures and systems reasonably designed to supervise the activities of a third party company to whom DBSI outsourced communications with DBSI's customers through a website developed by the third party company to administer Vonage's Directed Share Program. DBSI paid a $100,000 fine on October 6, 2009 as required. The AWC sets forth a timetable pursuant to which (1) FINRA will identify customers eligible for restitution, (2) DBSI will prepare notifications and certifications, and once approved by FINRA, will send such materials to eligible customers, (3) eligible customers may return executed certifications, and (4) DBSI will provide restitution to customers who timely return executed certifications. Further, DBSI is in the process of reviewing certain aspects of its supervisory policies and procedures, in accordance with the terms of the AWC. Within 150 days of issuance of the AWC, DBSI must certify that it has policies and procedures in place relating to outsourcing in connection with public offerings of common stock that are reasonably designed to achieve compliance with FINRA rules, and provide a written description of such policies and procedures. Fine of $100,000 paid on October 6, 2009; restitution of no more than approximately $52,000 to no more than approximately 59 customers to be paid in accordance with procedures set forth in the AWC. Without admitting or denying FINRA's findings within 150 days DBSI must certify that it has certain policies and procedures in place. Fine of $100,000 paid on October 6, 2009; restitution of no more than $52,000 to no more than 59 customers to be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 2008014450501 02/16/2010 FINRA The Registrant has not been the subject of this matter. Initiation date 2/16/2010. FINRA alleged that DBSI violated rules 200(G), 203(A)(1), 203(B)(1), and 203(B)(3) of Regulation SHO, Rules 15C-3(M), 15C3-(N) and 17A-3 of the Securities Act of 1934, FINRA Rule 2010, and NASD Rules 2110, 3010, 3110(A) and 8211 in that the firm allegedly: accepted short sale orders from its clients and subsequently released them for execution through its direct market access platform without having borrowed the securities or entered into bona-fide arrangements to borrow the securities, or having reasonable grounds to believe that the securities could be borrowed for delivery when due, and without the proper documented compliance of such; failed to have reasonable grounds to mark client sell orders as long and utilized borrowed shares for delivery and/or failed to deliver securities related to such client long sales; failed to monitor its fails in threshold securities listed on the Archipelago Exchange, and consequently did not close out such fails as required and/or executed short sales in these securities while an aged fail was pending without first having borrowed or arranged to borrow the security as required; provided inaccurate information on the firm's blue sheet reports by erroneously reflecting position movements between related client accounts as buy and sell transactions and, in certain instances erroneously reported short sales as long sales; did not monitor, effect buy-ins or file extensions for client long sale orders where the firm had not obtained possession of the securities from the customer within 10 days after settlement date; the firm incorrectly booked customer long sale orders to short accounts when customers did not maintain a long position at the firm and failed to maintain trade data relating to a customer that submitted trades through its direct market access platform; in connection with the points above, failing to implement procedures and systems reasonably designed to ensure compliance with the relevant sections of Reg. SHO, the rules of the NASD and FINRA, and other securities laws and regulations. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC"), consenting to a censure and fine of $575,000.00. DBSI consented to a censure and fine of $575,000. The fine was paid on March 2, 2010. Without admitting or denying the allegations, DBSI consented to a censure and fine of $575,000. The fine was paid on March 2, 2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2010-015 04/15/2010 ICE Futures U.S., Inc. The Registrant has not been the subject of this matter: Initiation date 4/15/2010. Deutsche Bank Securities Inc. ("DBSI") violated Exchange Floor Trading Rule 4.31 (C) by failing to report (4) block trades within the five (5) minutes required time period. DBSI was issued a summary fine of $500.00. It was paid on May 5, 2010. DBSI was issued a summary fine of $500.00. It was paid on May 5, 2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case Number: 2008012808701 07/20/2010 The Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Initiation date 7/20/2010. FINRA alleged violations by DBSI of NASD Rule 2110 relating to (1) negligent errors in describing, in the prospectus supplements for 6 RMBS offerings, the methodology by which mortgage delinquency rates were calculated and (2) negligent errors in reporting historical mortgage delinquency rates in static pool information posted on DBSI's REG AB website in connection with 16 RMBS offerings. In addition, FINRA alleged that DBSI failed to have a sufficient system in place to identify and correct inaccuracies in static pool information posted on DBSI's REG AB website, in violation of NASD Rules 3010 and 2110. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $7,500,000.00. DBSI consented to a censure and fine of $7,500,000.00. The fine was paid on 8/2/2010. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent consenting to a censure and fine of $7,500,000.00. The fine was paid on 8/2/2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2010-055 10/04/2010 Ice Futures U.S., Inc. The Registrant has not been the subject of this matter: Initiation date 10/4/2010. Deutsche Bank Securities Inc. ("DBSI") violated Exchange Floor Trading Rule 4.31(C) by failing to report (1) block trade within the five (5) minutes required time period. DBSI was issued a summary fine of $1,000.00. It was paid on October 12, 2010. DBSI was issued a summary fine of $1,000.00. It was paid on October 12, 2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 03-CH-0310 09/29/2010 Chicago Board of Trade (CME Group) The Registrant has not been the subject of this matter: Initiation date 9/29/2010. Chicago Board of Trade (CME Group) alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 980.A in that it failed to timely provide the necessary documents to the Chicago Board of Trade to complete its audit. DBSI was fined $25,000.00. Without admitting or denying the allegations DBSI agreed to pay the fine of $25,000.00. The fine was paid on October 12, 2010. DBSI was fined $25,000.00. Without admitting or denying the allegations DBSI agreed to pay the fine of $25,000.00. The fine was paid on October 12, 2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE # 10-05138 11/11/2010 Chicago Board Of Trade ("CBOT") The Registrant has not been the subject of this matter: Initiation date 11/11/2010. The Chicago Board Of Trade ("CBOT") during a routine computerized trading reconstruction system ("CTR") examination (for the period of 7/12/10 through 7/20/10) alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 536.F in that trade data for certain trade dates reflected a CTR error rate higher than CBOT's acceptable threshold. DBSI consented to a fine of $5,000.00 in accordance with the automatic fine schedule. The fine was paid on 11/5/2010. DBSI consented to a fine of $5,000.00 in accordance with the automatic fine schedule. The fine was paid on 11/5/2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE # 10-07425 11/11/2010 Chicago Mercantile Exchange Inc. ("CME") The Registrant has not been the subject of this matter: Initiation date 11/11/2010. The Chicago Mercantile Exchange Inc. ("CME") during a routine computerized trading reconstruction system ("CTR") examination (for the period 7/6/10 through 7/22/10) alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 536.F in that trade data for certain trade dates reflected a CTR error rate higher than CBOT's acceptable threshold. DBSI consented to a fine of $2,500.00 in accordance with the automatic fine schedule. The fine was paid on 11/5/2010. DBSI consented to a fine of $2,500.00 in accordance with the automatic fine schedule. The fine was paid on 11/5/2010. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20060065005-01 01/25/2011 FINRA The Registrant has not been the subject of this matter: Initiation date: 1/25/2011. FINRA alleged that DBSI violated: (1) NASD Rule 3360 with respect to certain short interest reports between February 15, 2006 and February 15, 2007 and NASD Rule 2110 and NYSE Rule 421.10 regarding a short interest position report for September 15, 2006; (2) NASD Rule 6955(A) with respect to certain OATS reports from July 1, 2006 through September 30, 2006; (3) NASD Rule 2860(B)(5) with respect to certain LOPRS from June 11, 2007 through June 15, 2007; (4) NASD Rule 6130(B) by failing to accept or decline certain transactions in reportable securities within 20 minutes from May 1, 2007 through August 31, 2007; and (5) NASD Rule 6130(B) by failing to accept or decline certain transactions in reportable securities within 20 minutes from May 1, 2008 through August 31, 2008. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $65,000.00. The fine was paid on 2/11/11. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $65,000.00. The fine was paid on 2/11/11. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant HBD# 11-AMEX-1 04/01/2011 American Stock Exchange The Registrant has not been the subject of this matter: Initiation date: 2/17/2011. NYSE AMEX alleged that during the period of November 2003 through March 2008 DBSI: 1. violated American Stock Exchange Rule 906(A) by reporting the options positions of approximately 340 prime brokerage clients to the Large Options Position Report in the aggregate via an omnibus account rather than at the client account level, 2. violated American Stock Exchange Rule 320 by failing to reasonably supervise and implement adequate controls, including a separate system of follow-up and review, reasonably designed to achieve compliance with American Stock Exchange Rule 906(A). Without admitting or denying the allegations, DBSI consented to the imposition of a censure and a fine of $150,000.00. Without admitting or denying the allegations, DBSI consented to the imposition of a censure and a fine of $150,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case No. 2008013864402 06/28/2011 Financial Industry Regulatory Authority The Registrant has not been the subject of this matter: Initiation date: 6/28/2011. On May 17, 2011 Deutsche Bank Securities Inc. (DBSI) submitted an offer of acceptance, waiver & consent (AWC) to findings by FINRA that DBSI did not adequately supervise the trading activity of certain former DBSI registered representatives who, between January 2005 and May 2008, "shadowed" the confidential trading strategies of third-party investment advisers. The AWC found that DBSI failed to implement appropriate procedures to detect and prevent the shadowing activity, which violated DBSI policy and agreements between DBSI and the investment advisers. As a result, the AWC found that DBSI violated NASD Rules 2110 and 3010. On May 17, 2011, DBSI submitted an AWC to FINRA, and was notified of its acceptance by FINRA on June 28, 2011. In the AWC, solely for the purpose of the proceeding any other action in which FINRA is a party and without admitting or denying the findings set forth in the AWC, DBSI consented to findings that DBSI violated certain NASD Rules as set forth in 7, above. In addition to the payment of the fine, DBSI agreed to a censure. DBSI consented to make payment of a $350,000 fine, which it paid on June 28, 2011. DBSI also consented to a censure. Without admitting or denying the findings set forth in the AWC, DBSI consented to findings that DBSI violated certain NASD Rules. DBSI consented to make payment of a $350,000 fine, which it paid on June 28, 2011. DBSI also consented to a censure. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Matter No. 11-00116 10/12/2011 ICE U.S. OTC Commodity Markets, LLC The Registrant has not been the subject of this matter: Initiation date: 10/12/2011. ICE U.S. OTC Commodity Markets, LLC alleged DBAG violated Ice OTC Rule 1.13 (Enforcement of Position Limits and Position Accountability Levels) by holding both intra-day and inter-day positions in excess of the Firm's exempted position limit for July 2011 ICE Henry Hub LD1 contract between June 23, 2011 and June 24, 2011. Without admitting or denying the allegations, DBAG agreed to the settlement and fine of $20,000. The fine of $20,000 was paid on October 18, 2011. Without admitting or denying the allegations, DBAG agreed to the settlement and paid a fine of $20,000 on October 18, 2011. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant NYMEX Case 11-08386-BC 05/22/2012 New York Mercantile Exchange ("NYMEX") The Registrant has not been the subject of this matter: Initiation date: 6/23/2011. NYMEX alleged that DBAG violated NYMEX rule 562 (position limit violations). In that on June 23, 2011, Deutsche Bank held a position of 5,761.25 short July 2011 Henry Hub natural gas lookalike last day financial futures ("JUL11 NATGAS") contracts, which was 1,261.25 contracts or 28.0% over its exchange approved expiration month hedge exemption level of 4,500 contracts in JUL11 NATGAS. Furthermore, on June 24, 2011, Deutsche Bank increased its JUL11 NATGAS position to 6,011.25 short JUL11 NATGAS contracts or 33.6% over its exchange approved expiration month hedge exemption level. Without admitting or denying the allegations, DBAG agreed to the settlement and fine of $40,000.00. The fine of $40,000.00 was paid on June 1, 2012. Without admitting or denying the allegations, DBAG agreed to the settlement and fine of $40,000.00. The fine of $40,000.00 was paid on June 1, 2012. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant CBOT 11-8175-BC 08/07/2012 Chicago Board of Trade (CME Group) The Registrant has not been the subject of this matter: Date Initiated: 08/07/2012. Chicago Board of Trade (CME Group) alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 17107.B. in that during the March 2011 delivery cycle, based upon intents and invoices the firm submitted to the exchange, DBSI was short-position holder scheduled to deliver rough rice receipts to multiple long-position holders stopped for delivery. However, DBSI failed to completely deliver all receipts over the Electronic Warehouse Receipt System prior to the 1:00 PM dead line on March 2, 2011. Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00. The fine was paid on 8/10/2012. Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00. The fine was paid on 8/10/2012. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant Docket/Case Number: No. 2010023096302 08/10/2012 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 8/10/2012. This matter stems from the personal financial difficulties of a former DBSI client advisor in the firm's Boston branch. Between approximately January 2009 and April 2010, the client advisor misused a corporate credit card for personal charges, bounced checks, and borrowed money from one of his customers. DBSI terminated his employment in April 2010. In the AWC settling this matter, DBSI accepted and consented, without admitting or denying, that the firm's lexicon-based search system for the review of electronic correspondence in the PCS division was inadequate to search for terms indicating that a client advisor might be experiencing personal financial difficulties and/or violating certain applicable laws, rules or regulations in connection with those difficulties, and that the firm's supervisory system and written supervisory procedures were inadequate to effectively respond to such "red flags." Accordingly, as set forth more fully in the AWC, the firm has undertaken to add terms to its email review lexicon for client advisors, to review electronic communications of client advisors from January 1, 2012 to date using those additional terms, and to review its supervisory procedures for responding to "red flags" of potential misconduct by a client advisor relating to such personal financial difficulties. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $100,000.00. The fine was paid on 8/22/12. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $100,000.00. The fine was paid on 8/22/12. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant 12-CH-1204 08/29/2012 Chicago Mercantile Exchange ("CME") The Registrant has not been the subject of this matter: Date Initiated: 7/18/2012. CME alleged that Deutsche Bank Securities Inc ("DBSI") violated Chicago Board of Trade ("CBOT") Rule 970.A.4 relating to computing and recording balances in the net capital computation, CBOT Rule 971.A.2 relating to recording and reporting balances in segregation secured sequestered accounts, and CBOT Rule 971.A.3 relating to identifying segregated, secured and sequestered accounts. On August 6, 2012, DBSI submitted an offer of settlement for $50,000.00 without admitting or denying the charges. CME accepted DBSI'S offer of settlement effective August 29, 2012. The firm paid the $50,000.00. DBSI submitted an offer of settlement for $50,000.00 without admitting or denying the charges. CME accepted DBSI'S offer of settlement effective August 29, 2012. DBSI was ordered to pay a fine of $50,000.00. The firm paid the $50,000.00. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant CME 11-08055-BC 11/27/2012 Chicago Mercantile Exchange ("CME") The Registrant has not been the subject of this matter: Date Initiated: 11/27/2012. CME alleged that Deutsche Bank Securities Inc. ("DBSI") between July 2010 and March 2012, executed multiple block trades for customers in various CME contracts that were not reported to the exchange within the applicable time limit following execution in violation of CME Rule 526.F. During the same time frame, DBSI misreported to the exchange the accurate time of execution of multiple block trades in violation of CME Rule 432.I. In addition, DBSI failed to maintain accurate records of the block trade transactions. CME also found that the firm violated CME Rule 432.W by failing to diligently supervise its employees or agents in the conduct of their business relating to the exchange. Without admitting or denying the allegations, DBSI accepted the decision & offer of settlement consenting to a fine of $250,000.00. DBSI consented to the decision & order of settlement and fined $250,000.00. The fine was paid on December 7, 2012. DBSI consented to the decision & order of settlement and fined $250,000.00. The fine was paid on December 7, 2012. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant CBOT 09-04307-BC 11/27/2012 Chicago Board of Trade ("CBOT") The Registrant has not been the subject of this matter: Date Initiated: 11/27/2012. CBOT alleged that Deutsche Bank Securities Inc. ("DBSI") between October 1, 2009 and March 16, 2012, executed multiple block trades for customers in various CBOT contracts that were not reported to the exchange within the applicable time limit following execution. DBSI employees also reported several inter-commodity spread trades to the exchange as block trades when these transactions did not meet the minimum quantity threshold for inter-commodity spread block trades, these actions violated CBOT Rules 526.A and F. During the same time frame, DBSI, misreported to the exchange the true and accurate time of execution of multiple block trades, on two occasions, DBSI employees appeared to intentionally misreport block trades' execution times in order to give the appearance that the transactions were reported to the exchange within the applicable time limit following execution, these actions violated CBOT rule 432.I. In addition, DBSI failed to maintain accurate written or electronic records of the block trade transactions, these actions violated CBOT Rule 536. CME also found that the firm violated CME Rule 432.W by failing to diligently supervise its employees or agents in the conduct of their business relating to the exchange. Without admitting or denying the allegations, DBSI accepted the decision & order of settlement consenting to a fine of $550,000.00. DBSI consented to the decision & order of offer settlement and fined $550,000.00. The fine was paid on December 6, 2012. DBSI consented to the decision & order of offer settlement and fined $550,000.00. The fine was paid on December 6, 2012. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant 20090174106-01 11/26/2012 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 11/26/2012. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI"), (a) in seven transaction pairs between October 1, 2008 and December 31, 2008, the Firm sold corporate bonds to customers and failed to sell such bonds at a price that was fair, taking into consideration all relevant circumstances, in violation of NASD Rules 2110, 2440 and IM-2440; (b) from March 14, 2008 to April 15, 2010, on 29 settlement dates, the Firm submitted to FINRA inaccurate short interest position reports in violation of NASD Rule 3360, NYSE Rule 421, and FINRA Rule 4560 (for settlement dates on or after December 15, 2008); (c) during the periods January 14, 2008 through March 31, 2008 and July 8, 2008 through September 30, 2008, the Firm transmitted to the FNTRF 70 last sale reports of transactions in designated securities and failed to designate such reports as reflecting a price different from the current market when the execution was based on a prior reference point in time in violation of NASD Rule 4632(A)(5)(G). The Firm also failed to designate as "W" to the FNTRF 13 last sales reports of transactions in NMS securities that occurred at prices based on an average weighting or another special pricing formula in violation of NASD Rule 4632(A)(5)(E) and failed to report the correct time of execution to the FNTRF in 78 last sale reports of transactions in designated securities in violation of NASD Rule 4632(C)(5); (d) during the period May 1, 2010 through May 31, 2010, the Firm failed to show the correct terms and conditions on the memorandum of 41 brokerage orders in violation of SEC Rule 17A-3 and NASD Rule 3110; (e) during the period July 1, 2010 through September 30, 2010, the Firm failed to report the correct time of trade to the RTRS in 24 reports of transactions in municipal securities in violation of MSRB Rule G-14(B)(II). The Firm also failed to report information regarding 24 purchase and sale transactions effected in municipal securities to the RTRS in the manner prescribed by Rule G-14 RTRS procedures and the RTRS Users Manual in violation of MSRB Rule G-14, and in 23 instances, the Firm improperly reported information to the RTRS that it was not required to report in violation of MSRB Rule G-14. The firm also failed to show the correct time of execution on the memorandum of 24 brokerage orders in municipal securities in violation of MSRB Rule G-8. (f) During the period April 1, 2010 through June 30, 2010, the Firm failed to repair 3,041 rejected ROES transmitted to OATS in violation of FINRA Rule 7450. (g) During the period May 1, 2010 through August 31, 2010, the Firm failed to accept or decline in the FNTRF 126 transactions in reportable securities within 20 minutes after execution in violation of FINRA Rule 7230a; (h) during the period July 1, 2010 through September 30, 2010, in 49 instances the Firm improperly reported information to the RTRS that it should not have in violation of MSRB Rule G-14; and (i) during the period July 1, 2011 through September 30, 2011 the Firm failed to report to TRACE 629 S1 transactions within 15 minutes of the time of execution in violation of FINRA Rule 6730( A) and FINRA Rule 2010. Without admitting or denying the allegations DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine. The fine of $175,000 was comprised of $20,000 for the fair pricing violations; $50,000 for the short interest reporting violations; $22,500 for the trade reporting violations; $5,000 for the books and records violations; $12,500 for the violations of MSRB Rule G-14 and $2,500 for the violations of MSRB Rule G-8; 12,500 for the OATS violations; $22,500 for the trade reporting violations; $22,500 for the violations of MSRB Rule G-14; and $5,000 for the TRACE reporting violations. Restitution in a total amount of $10,314.44 plus statutory interest to customers in connection with the fair pricing violations. DBSI consented to a censure and fine of $175,000.00 plus interest restitution of $10,314.44. The fine was paid on December 13, 2012. Deutsche Bank Securities Inc., a Control Affiliate of the Registrant 2,008,016,167,401 11/21/2012 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 11/21/2012. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") from July 2006 through December 15, 2008, failed to report approximately 8,760 options positions in conventional options to the LOPR in violation of NASD Rule 2860(B)(5). Also between March 23, 2011 and March 30, 2011, one of the Firm's customers exceeded the position limit in HK939 in violation of FINRA Rule 2360(b)(3) and the Firm failed to submit to the OCC its OCEND for approximately two months from March 23, 2011 through May 31, 2011 in violation of FINRA Rule 2360(B)(3)(A)(VII)(B)(4)(B). In addition, from December 1, 2010 through October 6, 2011 the Firm failed to accurately report approximately 20,542 options positions in conventional options to the LOPR in violation of FINRA Rule 2360(B)(5), and from July 2006 to December 2011, the Firm failed to implement and maintain an adequate system of follow-up and review designed to reasonable ensure the submission of complete and accurate LOPR in violation of NASD Rule 3010, NASD 2110 and FINRA Rule 2010. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $35,000.00. DBSI consented to a censure and a fine of $35,000. The fine was paid on December 12, 2012. Without admitting or denying the allegations, DBSI consented to a censure and a fine of $35,000. The fine was paid on December 12, 2012. Deutsche Bank Securities, Inc.'s (DBSI or Firm) , a Control Affiliate of the Registrant 20080136798-01 12/14/2012 Financial Industry Regulatory Authority ("FINRA") In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(vi). Deutsche Bank Securities, Inc.'s (DBSI) , a Control Affiliate of the Registrant 2,011,029,270,401 12/31/2012 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/31/2012. FINRA alleged that during the period January 1, 2009 through June, 30, 2011, Deutsche Bank Securities Inc. ("DBSI") failed to deliver certain mutual fund prospectuses to DBSI customers within three business days of their purchases, and DBSI failed to establish and maintain adequate supervisory systems and written supervisory procedures reasonably designed to monitor and ensure the timely delivery of mutual fund prospectuses. It was also alleged that during the period January 1, 2011 through May 31, 2011, DBSI failed to deliver certain preliminary IPO prospectuses to DBSI customers, and DBSI failed to establish and maintain adequate supervisory systems and written supervisory procedures reasonably designed to monitor and ensure the timely delivery of preliminary IPO prospectuses. Accordingly, FINRA found that DBSI violated NASD Conduct Rules 3010(A)(1) and (B)(1) and FINRA Rule 2010. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $125,000.00. DBSI consented to a censure and fine of $125,000.00. The fine was paid on 1/9/2013. DBSI consented to a censure and fine of $125,000.00. The fine was paid on 1/9/2013. Deutsche Bank Securities, Inc.'s (DBSI) , a Control Affiliate of the Registrant 20080163813-01 02/05/2013 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 02/05/2013. FINRA alleged that: (1) during the periods July 1, 2007 through September 30, 2007, July 1, 2008 through September 30, 2008, and April 1, 2009 through June 30, 2009, the Firm failed to report to TRACE the correct contra-party identifier for certain transactions in TRACE Eligible Securities and failed to report to TRACE certain transactions in TRACE-Eligible Securities that it was required to report. These alleged failures violated NASD Rules 6230(C)(6) and 6230(B) or FINRA Rules 6730(C)(6) and 6730(B)(1); (2) during the period from April 1, 2009 through June 30, 2009, the Firm failed to report to TRACE certain transactions in TRACE-Eligible Securities within 15 minutes of the time of execution and failed to report to TRACE the correct time of trade execution for certain transactions in TRACE-Eligible Securities in violation of FINRA Rules 6730(C)(8), 6730(A), and 2010. It also failed to show the correct time of execution on the memorandum of certain brokerage orders in violation of SEC Rule 17A-3 and NASD Rule 3110; (3) for trade dates April 15 and 16, 2009 and July 28 and 29, 2010, certain of the FIRM'S trade confirmations with institutional customers omitted certain information or contained incorrect information in violation of SEC Rule 10B-10; (4) during the periods January 1, 2009 through March 31, 2009 and July 1, 2009 through September 30, 2009, respectively, the Firm failed to report the correct time of trade to the RTRS in certain reports of transactions in municipal securities and failed to timely report information regarding certain purchase and sale transactions effected in municipal securities to the RTRS in violation of MSRB Rule G-14. The Firm also failed to show the correct time of trade on the memorandum of certain municipal securities orders in violation of MSRB Rule G-8. (4) during the period May 1, 2009 through August 31, 2009, the Firm failed to accept or decline in the FINRA/NASDAQ TRF or the OTC trade reporting facility certain transactions in reportable securities within 20 minutes after execution in violation of FINRA Rules 7230A(B) OR 7330(B); (5) during the period from January 1, 2010 through April 30, 2010, the Firm failed, within 90 seconds after execution, to transmit to the OTC TRF certain last sale reports of transactions in OTC equity securities in violation of FINRA Rules 6622(A) and 2010. It also failed, within 90 seconds after execution, to transmit to the OTC TRF certain last sale reports of transactions in OTC equity securities, failed to report the correct time of execution for such transactions, and failed to designate to the OTC TRF such last sale reports as late, in violation of FINRA Rule 6622(A); (6) during the period from January 1, 2010 through April 30, 2010, the Firm failed, within 90 seconds after execution, to transmit to the FINRA/NASDAQ TRF certain last sale reports of transactions in designated securities in violation of FINRA Rule 6380A and failed to report to the FINRA/NASDAQ TRF the correct time of execution for certain transactions in reportable securities in violation of FINRA Rule 7230A(D)(4); and (7) during the period July 1, 2008 through December 31, 2008, the Firm effected 11 transactions in seven securities while a trading halt was in effect with respect to each of the securities in violation of NASD Rules 3340 and 2110 or FINRA Rule 2010. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $215,000.00. DBSI consented to a censure and fine of $215,000.00. The fine was paid on 2/14/2013. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $215,000.00. The fine was paid on 2/14/2013. Deutsche Bank Securities, Inc.'s (DBSI or Firm) , a Control Affiliate of the Registrant 2,008,015,717,201 04/08/2013 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 4/8/2013. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Rules 2010, 2110 and 3010 during the period of 2006-2011 by failing to establish and enforce adequate written supervisory procedures regarding dividend-related yield enhancement on total return swap transactions that involved U.S. equities. Specifically, FINRA alleged that the Firm failed to establish adequate written procedures for the transactions themselves, the review of the transactions, or for documenting supervision that occurred. Although the Firm conducted reviews, FINRA alleged that it relied on incomplete data that did not provide enough information to ensure a comprehensive review and that it failed to document such reviews. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $275,000.00. The fine was paid on 4/15/2013. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $275,000.00. The fine was paid on 4/15/2013. Deutsche Bank Securities, Inc.'s (DBSI or Firm) , a Control Affiliate of the Registrant CBOT 12-08830-BC 06/05/2013 CME Group The Registrant has not been the subject of this matter: Date Initiated: 6/5/2013. CME alleged that Deutsche Bank Securities Inc. ("DBSI") violated CBOT Rule 854 between March 1, 2012 and March 5, 2012, by overstating open interest on certain futures contracts because it impermissibly netted certain contracts as a result of not receiving timely close-out instructions from its customer. Without admitting or denying the allegations, DBSI consented to the Decision & Offer of Settlement and was fined of $65,000.00. Without admitting or denying the allegations, DBSI consented to the Decision & Order of Settlement and was fined $65,000.00. The fine was paid on June 11, 2013. Without admitting or denying the allegations, DBSI consented to the Decision & Order of Settlement and was fined $65,000.00. The fine was paid on June 11, 2013. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant NYMEX-RSRH-13-1264/COMEX-RSRH-13-1265 08/07/2013 Chicago Mercantile Exchange (CME Group) The Registrant has not been the subject of this matter: Date Initiated: 8/7/2013. On July 23, 2013, the CME imposed a summary fine in the amount of $3,500.00 on DBAG, the Registrant's ultimate parent, in connection with its allegation that DBAG did not timely report seven Block Trades. Without admitting or denying the allegations, DBAG accepted the decision & offer of settlement consenting to a fine of $3,500.00. DBAG consented to the decision & order of settlement and fined $3,500.00. The fine was paid on August 7, 2013. Without admitting or denying the allegations, DBAG accepted the decision & offer of settlement consenting to a fine of $3,500.00.The fine was paid on August 7, 2013. Deutsche Bank Securities, Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 2012-056 09/10/2013 ICE Futures U.S., Inc. The Registrant has not been the subject of this matter: Date Initiated: 9/3/2013. ICE Futures U.S., Inc. alleged Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 27.12a in that it did not provide complete electronic data for 11 orders entered onto the ETS in July 2012. Without admitting or denying the allegations, DBSI agreed to the summary fine of $5,000.00. The fine was paid on September 9, 2013. DBSI was issued a summary fine of $5,000.00. It was paid on September 9, 2013. Without admitting or denying the allegations, DBSI agreed to the summary fine of $5,000.00. The fine was paid on September 9, 2013. DBSI was issued a summary fine of $5,000.00. It was paid on September 9, 2013. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 20110288146-01 12/12/2013 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/12/2013. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") violated FINRA Rules 2010, 6730(a), NASD Rule 3010, MSRB Rules G-8, G-14, G-14(b)(11) by: failing to report correct trade time to the real-time transaction reporting system (RTRS) in Municipal Securities Transactions; by failing to report information regarding purchase and sale transactions effected in municipal securities to the RTRS in the manner prescribed by Rule G-14; by failing to report information about such transactions within 15 minutes of trade time to an RTRS Portal; by failing to document the correct execution time on trade memorandum for transactions in municipal securities; and by failing to report new issue offerings in Trade Reporting and Compliance Engine TRACE-eligible corporate securities in accordance with the time frame of FINRA Rule 6760(c). The Firm's supervisory system did not include Written Supervisory Procedures (WSPS) reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules concerning the reporting of new issues to trace and the firm failed to report to TRACE P1 Transactions in TRACE-eligible corporate securities within T+1. This conduct constitutes separate and distinct violations of FINRA Rule 6730(a) and a pattern or practice of late reporting without exceptional circumstances in violation of FINRA Rule 2010. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $30,000.00. DBSI consented to a censure, a fine of $30,000.00, and an undertaking within 30 days of acceptance of the AWC to revise its WSP's concerning the reporting of new issues to TRACE. The fine was paid on 12/19/13 and the WSP's were revised and implemented on December 2, 2013. Without admitting or denying the allegations, DBSI agreed to a AWC consenting to a censure, a fine of $30,000.00 and to an undertaking within 30 days of acceptance of the AWC to revise its WSP's concerning the reporting of new issues to TRACE. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 2011030737001 12/19/2003 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/19/2013. FINRA alleged violations of Securities Exchange Act Rule 17f-2, Article III Section 3(b) of FINRA's By-Laws, FINRA Rule 2010, and NASD Rules 2110 and 3010(b). Specifically, FINRA alleged that Deutsche Bank Securities Inc. ("DBSI" or the "Firm") permitted two statutorily disqualified ("SDED") persons to associate with the firm and DBSI failed to enforce its written policies and procedures requiring background checks and fingerprinting of all new hires with respect to non-registered employees transferring from another Deutsche Bank entity. Although employees were fingerprinted and had background checks run on them when they first entered a Deutsche Bank entity, DBSI did not re-fingerprint and rerun background checks on individuals who transferred from another Deutsche Bank entity into DBSI. Once discovered, DBSI immediately self-reported the facts surrounding the employment of the SDED individuals. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $40,000.00. DBSI consented to a censure, a fine of $40,000.00. The fine was paid on 12/23/13. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $40,000.00. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 2010023559301 12/19/2013 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/19/2013. FINRA alleged violations of Section 17(a) of the Securities Exchange Act of 1934 and Rules 15c3-1, 15c3-3, 17a-3, 17a-4 and 17a-5 thereunder, FINRA Rule 2010, and NASD Rule 3010 and 3110, relating, primarily, to DBSI's enhanced lending program for: failure to maintain accurate books and records; failure to maintain books and records sufficiently transparent to ensure the accuracy of the data on DBSI's focus report; filing an inaccurate focus report; inaccurately over-reporting the amount of a margin call resulting from its reclassification of intercompany receivables as stock loans; inaccurately computing its customer reserve formula which, when self-identified and corrected, resulted in hindsight deficiencies ranging from $700 million to $1.6 billion during the period between March 5, 2010 and March 26, 2010; and, failing to establish and maintain adequate Written Supervisory Policies and Procedures for its independent price verification process to sufficiently document management reporting for certain of its residential mortgage backed securities and commercial mortgage backed security inventory positions. DBSI neither admitted nor denied any of the foregoing. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $6,500,000.00. DBSI consented to a censure, a fine of $6,500,000.00. The fine was paid on 12/30/13. Without admitting or denying the allegations, DBSI agreed to a letter of acceptance, waiver and consent ("AWC") consenting to a censure and fine of $6,500,000.00. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 20100237658-01 01/13/2014 Financial Industry Regulatory Authority ("FINRA") FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") 1) effected transactions in securities while a trading halt was in effect with respect to each of the securities; 2) failed to establish, maintain, and enforce written policies and procedures reasonably designed to prevent trade-throughs of protected quotations in National Market System ("NMS") stocks; 3) failed to take reasonable steps to establish that Intermarket Sweep Orders it routed complied with Exchange Act Rule 600(b)(30); 4) failed to report to TRACE the correct contra-party's identifier for certain transactions; 5) failed to report to TRACE certain transactions that it was required to report and reported to TRACE certain transactions that it was not required to report; 6) failed to report to TRACE S1 certain transactions in Corporate Debt Securities; 7) failed to report to TRACE the correct contra-party's identifier for S1 transactions in certain Corporate Debt Securities and failed to accurately report to TRACE the market identifier for an S1 transaction; 8) the firm failed to submit a report to TRACE identifying the correct volume, price, execution date, or execution time for certain S1 transactions in Corporate Debt Securities; 9) failed, within 30 seconds after execution, to transmit to the Over-The-Counter ("OTC") Trade Reporting Facility ("OTCTRF") reports of transactions in OTC securities in violation of FINRA Rules 6622(a) and 2010; 10) transmitted certain reportable order events to OATS that were rejected by OATS and failed to repair many of these rejected ROES. FINRA alleged that as a result of such conduct, DBSI violated SEC Rules 611(a), 611(c) of Regulation NMS, FINRA Rules 2010, 5260, 6622(a), 6730(b), 6730(b)(1), 6730(c)(2), 6730(c)(3), 6730(c)(5), 6730(c)(6), 6730(c)(8), 6730(d)(4)(d), 6730(e), 7450, NASD Rules 3010, 3340. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure and fine of $110,000.00. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant CASE NO. 2013-002A 02/04/2014 ICE Futures U.S. The Registrant has not been the subject of this matter: Date Initiated: 2/4/2014. ICE Futures U.S. alleged Deutsche Bank Securities Inc. ("DBSI") RULE 4.07(C) IN THAT IT FAILED TO REPORT A BLOCK TRADE IN A TIMELY MANNER AND CONVEYED AN INACCURATE EXECUTION TIME OF THAT TRADE TO THE EXCHANGE. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI AGREED TO THE SETTLEMENT AND THE FINE OF $5,000.00. THE FINE OF $5,000.00 WAS PAID ON 2/7/2014. Without admitting or denying the allegations, DBSI agreed to the settlement and the fine of $5,000.00. The fine was paid on 2/7/2014. Deutsche Bank Securities Inc.'s (DBSI) , a Control Affiliate of the Registrant 13-CH-1302 02/18/2014 CHICAGO MERCANTILE EXCHANGE ("CME") The Registrant has not been the subject of this matter: Date Initiated: 8/29/2013. On August 29, 2013, the Chicago Mercantile Exchange ("CME") alleged that Deutsche Bank Securities Inc. ("DBSI") violated Chicago Board of Trade ("CBOT") Rule 970.A relating to computing the risk-based capital requirement, CBOT Rule 971.A.2 relating to computing certain receivables, CBOT Rule 971.A.3 relating to account titling, CBOT RULE 980.A relating to prompt examination of records, and CBOT Rule 980.B relating to certain financial statement and internal accounting controls matters. On December 12, 2013, DBSI submitted an offer of settlement for $900,000.00 without admitting or denying the charges. CME accepted DBSI's offer of settlement effective February 18, 2014. The firm paid the $900,000.00 on March 3, 2014. DBSI was ordered to pay a fine of $900,000.00. Without admitting or denying the allegations, on December 12, 2013, DBSI submitted an offer of settlement for $900,000.00. CME accepted DBSI's offer of settlement effective February 18, 2014. The firm paid the $900,000.00 on March 3, 2014. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant NYMEX12-09149-BC 02/20/2014 CME Group The Registrant has not been the subject of this matter: Date Initiated: 2/20/2014. On February 20, 2014 a Business Conduct Committee of the CME Group accepted a fine from Deutsche Bank AG (DBAG) for $25,000 in connection with allegations that DBAG failed to maintain adequate documentation in connection with EFRP transactions on three trades between August 2012 and June 2013. The Bank neither admitted nor denied the Rule violations upon which the fine was based. Without admitting or denying the allegations DBAG agreed to pay the fine of $25,000.00 which was paid on March 4, 2014. DBAG was ordered to pay a fine of $25,000.00. The fine was paid on March 4, 2014. Without admitting or denying the allegations, DBAG agreed to pay the fine of $25,000.00 which was paid on March 4, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20110301435-01 05/21/2014 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 05/21/2014. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") failed to accept or decline in the FINRA/NASDAQ Trade Reporting Facility ("FNTRF") transactions in reportable securities within 20 minutes after execution. In addition, findings that the firm lacked sufficient written supervisory procedures to ensure the accuracy and timeliness of its equity trade reporting compliance. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $27,500.00. In addition to the firm undertaking to revise the WSP's, the fine of $27,500.00 was paid on June 13, 2014. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $27,500.00. Fine of $27,500.00 was paid on June 13, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant COMEX 12-9190-BC 05/28/2014 Commodity Exchange, Inc. ("COMEX") The Registrant has not been the subject of this matter: Date Initiated: 5/28/2014. COMEX alleged that Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 536.D ("Recordkeeping requirements for PIT, GLOBEX and negotiated trades - Customer Type Indicator (CTI) codes"), finding that during the time periods of July 25, 2012 through August 8, 2012, September 24, 2012 through October 7, 2012, April 1, 2013 through April 30, 2013 and November 1, 2013 through November 30, 2013, DBSI submitted numerous instances of incorrect CTI codes. DBSI neither admitted nor denied the rule violations upon which the penalty is based. On May 28, 2014, an offer of settlement was accepted by a Commodity Exchange Business Conduct Committee under which Deutsche Bank Securities Inc. (DBSI) was ordered to pay a fine of $2,500.00. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $2,500.00. The fine was paid on June 5, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $2,500.00. The fine was paid on June 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NYMEX 12-9189-BC 05/28/2014 New York Mercantile Exchange ("NYMEX") The Registrant has not been the subject of this matter: Date Initiated: 5/28/2014. NYMEX alleged that Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 536.D ("Recordkeeping requirements for PIT, GLOBEX and negotiated trades - Customer Type Indicator (CTI) codes"), finding that during the time periods of July 25, 2012 through August 8, 2012, September 24, 2012 through October 7, 2012, April 1, 2013 through April 30, 2013 and November 1, 2013 through November 30, 2013, DBSI submitted numerous instances of incorrect CTI codes. DBSI neither admitted nor denied the rule violations upon which the penalty is based. On May 28, 2014, an offer of settlement was accepted by a New York Mercantile Exchange Business Conduct Committee under which Deutsche Bank Securities Inc. (DBSI) was ordered to pay a fine of $3,500.00. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $3,500.00. The fine was paid on June 5, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $3,500.00. The fine was paid on June 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CBOT 12-9188-BC 05/28/2014 Chicago Board of Trade ("CBOT") The Registrant has not been the subject of this matter: Date Initiated: 5/28/2014. CBOT alleged that Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 536.D ("Recordkeeping requirements for PIT, GLOBEX and negotiated trades - Customer Type Indicator (CTI) codes"), finding that during the time periods of July 25, 2012 through August 8, 2012, September 24, 2012 through October 7, 2012, April 1, 2013 through April 30, 2013 and November 1, 2013 through November 30, 2013, DBSI submitted numerous instances of incorrect CTI codes. DBSI neither admitted nor denied the rule violations upon which the penalty is based. On May 28, 2014, an offer of settlement was accepted by a Chicago Board of Trade Business Conduct Committee under which Deutsche Bank Securities Inc. (DBSI) was ordered to pay a fine of $8,000.00. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $8,000.00. The fine was paid on June 5, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $8,000.00. The fine was paid on June 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CME 12-9187-BC 05/28/2014 Chicago Mercantile Exchange ("CME") The Registrant has not been the subject of this matter: Date Initiated: 5/28/2014. CME alleged that Deutsche Bank Securities Inc. ("DBSI") violated Exchange Rule 536.D ("Recordkeeping requirements for PIT, GLOBEX and negotiated trades - Customer Type Indicator (CTI) codes"), finding that during the time periods of July 25, 2012 through August 8, 2012, September 24, 2012 through October 7, 2012, April 1, 2013 through April 30, 2013 and November 1, 2013 through November 30, 2013, DBSI submitted numerous instances of incorrect CTI codes. DBSI neither admitted nor denied the rule violations upon which the penalty is based. On May 28, 2014, an offer of settlement was accepted by a Chicago Mercantile Business Conduct Committee under which Deutsche Bank Securities Inc. (DBSI) was ordered to pay a fine of $16,000.00. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $16,000.00. The fine was paid on June 5, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $16,000.00. The fine was paid on June 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20110260972-01 06/16/2014 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 6/16/2014. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") failed to append an average price disclosure to customer confirmations on nine occasions, as well as findings that the Firm's supervisory system did not include written supervisory procedures reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and FINRA rules, concerning the use of multiple market participant identifiers. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $15,000.00. In addition to the Firm undertaking to revise the Firm's WSP's, DBSI consented to a censure and fine of $15,000.00. Without admitting or denying the allegations, DBSI agreed to a letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $15,000.00. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant CBOT 13-9687 07/24/2014 Chicago Board of Trade (CME Group) The Registrant has not been the subject of this matter: Date Initiated: 07/24/2014. On July 24, 2014, a Chicago Board of Trade Business Conduct Committee accepted a $60,000.00 fine from Deutsche Bank AG (DBAG) in connection with allegations that DBAG violated CBOT Rule 562 (position limit violation). Specifically, it was alleged that on December 12, 2013, DBAG held intraday long position of 8,402 March 2014 soybean oil futures contracts, which exceeded the single month speculative position limit of 8,000 contracts by 42 contracts, or by .53%. Prior to the close on 12/12/13, DBAG sold 10 contracts to bring itself into compliance with the applicable limit. DBAG neither admitted nor denied the rule violations upon which the fine is based. Without admitting or denying the allegations, DBAG agreed to pay the fine of $60,000.00 which was paid on August 5, 2014. Without admitting or denying the allegations, DBAG agreed to pay the fine of $60,000.00 which was paid on August 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. 14-0035 08/08/2014 CHICAGO BOARD OPTIONS EXCHANGE, INC. ("CBOE") The Registrant has not been the subject of this matter: Date Initiated: 8/8/2014. CBOE alleged that DBSI failed to register two (2) Associated Persons as Proprietary Trader (PT) with the Exchange in Web CRD. Specifically, from on or about November 5, 2011 through on or about January 21, 2014, the Firm failed to register one Associated Person as a Proprietary Trader (PT) with the Exchange in Web CRD. In addition, from on or about May 21, 2012 through January 21, 2014, the Firm failed to properly register one Associated Person as a Proprietary Trader with the Exchange in Web CRD. In addition, from on or about August 1, 2012 through on or about January 21, 2014, DBSI failed to properly register one Associated Person as a Proprietary Trader Principal (TP) with the Exchange in Web CRD. (Exchange Rule 3.6a). DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $7,500.00. The fine was paid on August 20, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $7,500.00. The fine was paid on August 20, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CASE NO. 2014-051 08/07/2014 ICE FUTURES U.S., INC. ("IFUS") The Registrant has not been the subject of this matter: Date Initiated: 8/7/2014. IFUS alleged that DBSI may have violated Rule 4.07(C) by failing to report a block trade within the requisite time-frame (five minutes for a single-leg block trades; ten minutes for a multi-leg block trades). DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $5,000.00. The fine was paid on August 20, 2014. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI consented to the fine of $5,000.00. The fine was paid on August 20, 2014. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant SFC 509 EN 1291 05/22/2014 Securities and Futures Commission ("SFC") The Registrant has not been the subject of this matter: Date Initiated: 05/22/2014. The statement of disciplinary action follows an SFC investigation into the failure of DBAG to disclose to the Stock Exchange of Hong Kong ("SEHK") the changes to its percentage holdings in the issued share capital of Up Energy Development Group on occasions in 2011 (as required by Sections 310(1), 311, 313(1), 315, 324 and 325(1)(A) of the Securities and Futures Ordinance (CAP 571)). Three of these occasions involved trading activity by DBAG; the remainder involved increases to the listed company's total issued share capital. The SFC found that DBAG failed to implement adequate internal controls to ensure its positions in Hong Kong listed companies were properly monitored an disclosed to SEHK in compliance with the disclosure of interest requirements. Without admitting or denying the allegations, DBAG paid a fine of HK$1.6 million. The fine was paid on or about 22 May 2014. DBAG was ordered to pay a fine of HK$1.6 million. The fine was paid on or about 22 May 2014. Without admitting or denying the allegations, DBAG paid a fine of HK$1.6 million. The fine was paid on or about 22 May 2014. DBAG was ordered to pay a fine of HK$1.6 million. The fine was paid on or about 22 May 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20120339358-01 09/17/2014 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 09/17/2014. FINRA alleged that DBSI during the review period, from 2/2012 to 9/2013 failed to report to TRACE S1 transactions in trade reporting and compliance engine (TRACE) eligible corporate debt securities to TRACE that it was required to report, failed to report the correct contra-party's identifier for S1 transactions in TRACE eligible corporate debt securities to TRACE, reported S1 transactions in TRACE-eligible corporate debt securities to TRACE that it was not required to report, and failed to submit a report identifying the correct volume for one S1 transaction in a TRACE-eligible corporate debt security in TRACE. The findings stated that the Firm failed to report new issue offering in TRACE-eligible agency debt securities and TRACE-eligible corporate debt securities to FINRA in accordance with the time frame set forth in FINRA Rule 6760(C). The Firm failed to report transactions in TRACE-eligible securitized products to TRACE within the time required by FINRA Rule 6730. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $55,000.00. DBSI consented to a censure and fine of $55,000.00. The fine was paid on October 1, 2014. Without admitting or denying the allegations, DBSI agree to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure of $55,000.00. DBSI consented to a censure and fine of $55,000.00. The fine was paid on October 1, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant CME 12-8737-BC 09/23/2014 Chicago Mercantile Exchange Group ("CME Group") The Registrant has not been the subject of this matter: Date Initiated: 09/23/2014. On September 23, 2014, a Business Conduct Committee of the CME Group approved a settlement under which Deutsche Bank Securities Inc. ("DBSI") paid $7,500.00 to settle charges that on one or more occasions DBSI failed to properly register Tag50 user ids utilized by its employees and allowed its employees to enter orders on Globex using incorrect Tag50 user ids, and failed to provide an audit trail to the exchange for the preceding five years, thereby violating rules 536.B.2 and 576. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI was ordered to pay a fine of $7,500.00. The fine will be paid. DBSI neither admitted nor denied the rule violations upon which the penalty is based. DBSI was ordered to pay a fine of $7,500.00. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 14-CH-1411 10/24/2014 Chicago Mercantile Exchange Group ("CME Group") The Registrant has not been the subject of this matter: Date Initiated: 10/24/2014. On October 24, 2014, the Clearing House Risk Committee of the Chicago Mercantile Exchange Group approved DBSI's offer to pay $100,000.00 to settle charges that it had violated CBOT Rules 971.A.2 and 980.B. DBSI neither admitted nor denied that it had violated the rules upon which it was charged. DBSI was ordered to pay the fine of $100,000.00. The fine will be paid. DBSI neither admitted nor denied that it had violated the rules upon which it was charged. DBSI was ordered to pay the fine of $100,000.00. The fine will be paid. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Case #2014-017 11/25/2014 ICE Futures U.S., Inc ("ICE") The Registrant has not been the subject of this matter. Date initiated: 11/25/2014. ICE Futures U.S., Inc. alleged DBAG violated Exchange Rule 6.20(B) in one instance by exceeding the spot month speculative position limit established by the Exchange for the Henry Hub LD1 fixed price futures contract during the 2014 expiration. Without admitting or denying the allegations, DBAG agreed to the settlement and to pay the fine and disgorgement. The amount of $194,580.00 represents $20,000.00 (fine portion) and $174,580.00 represents disgorgement of profits, there was also an agreement to cease and desist from future violation of Exchange Rule 6.20(B). The fine and disgorgement was paid on December 11, 2014. Without admitting or denying the allegations, DBAG agreed to the settlement and to pay the fine and disgorgement. The fine and disgorgement was paid on December 11, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case #14-7974 11/18/2014 Chicago Mercantile Exchange Group ("CME Group") The Registrant has not been the subject of this matter. Date Initiated: 11/18/2014. CME Group market regulation completed its 2014 electronic recordkeeping exam of DBSI for trade dates February 21, 2014 through May 21, 2014. As a result of that exam, CME alleged that DBSI utilized Tag 50 Ids in a manner inconsistent with the requirements of Rule 576 ("Identification of GLOBEX terminal operators"). DBSI neither admitted nor denied the Rule violation upon which the penalty is based. The fine of $4,000 to CME Group was allocated by $2,000.00 going to the CME and $2,000.00 going to the CBT. DBSI was ordered to pay a fine of $4,000.00. The fine was paid on November 5, 2014. DBSI neither admitted nor denied the Rule violation upon which the penalty is based. DBSI was ordered to pay a fine of $4,000.00. The fine was paid on November 5, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20110306837-01 12/11/2014 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter. Date Initiated: 12/11/2014. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Rule 2711(C)(4), 2711(E) and FINRA Rule 2010 in that DBSI in an effort to win investment banking business from a company, the Firm's equity research analyst participated in the Firm's solicitation efforts and the Firm offered favorable research coverage to the company to induce the company to award the Firm its investment banking business. The findings stated that following the analyst's presentation, the company asked the Firm to complete a template showing an "equity commitment committee approved" valuation of the company, which would include the analyst's views on the company valuation. The company and its private equity owners (sponsors) asked the Firm to complete the template and provide a Firm wide valuation that the Firm, including its analyst, would be expected to support after the company awarded its Initial Public Offering (IPO) business, absent unexpected developments. Under the circumstances of the company's potential IPO, the Firm offered favorable research coverage to induce receipt of investment banking business by completing and submitting to the company, during the solicitation period, the valuation template requested by the company and the sponsors. The Firm complied with the company's request. By providing the company the unified valuation it sought, the Firm indicated to the company that post-IPO research coverage would be positive and aligned with investment banking. The company and the sponsors selected the Firm as an underwriter and co-bookrunner for the company's IPO. The company, however, eventually decided not to proceed with the offering. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure and a fine of $4,000.000.00. DBSI consented to a censure and a fine of $4,000,000.00. The fine was paid on December 18, 2014. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure and a fine of $4,000,000.00. The fine was paid on December 18, 2014. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20120316464-01 12/23/2014 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 12/23/2014. FINRA alleged Deutsche Bank Securities Inc. ("DBSI") transmitted reports to the Order Audit Trail System ("OATS") that contained inaccurate, incomplete, or improperly formatted data. FINRA also alleged that the Firm failed to provide written notifications disclosing to its customers its correct capacity in transactions, that the transaction was executed at an average price, and twice incorrectly disclosed that a "commission" was charged on a principal transaction. The Firm marked orders as short when it was long and marked orders as long when it was short. The Firm failed to report the correct related market center indicator for non-tape reports to the FINRA/NASDAQ Trade Reporting Facility (FNTRF) in transactions in designated securities and the Firm submitted an incorrect execution time for non-tape reports to the FNTRF. The Firm made available a report on the covered orders in national market system securities that it received for execution from any person which included inaccurate information as to whether orders were covered or not covered. The findings also stated that the Firm's Written Supervisory Procedures (WSPs) did not provide for supervision reasonably designed to achieve compliance with respect to certain applicable securities laws and regulations, and/or FINRA and SEC rules. The Firm's WSPs failed to provide for one or more of the four minimal requirements for adequate WSPs regarding best execution. trade reporting, and OATS reporting. Without admitting or denying the allegations, DBSI agreed to a Letter of acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking and a fine of $62,500.00. An undertaking to revise the Firm's WSPs. DBSI consented to a censure, fine and undertaking. The fine was paid on January 8, 2015. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking and a fine of $62,500.00. Deutsche Bank AG (London), a Control Affiliate of the Registrant RSRH-14-2575 02/12/2015 Chicago Mercantile Exchange Group ("CME Group") The Registrant has not been the subject of this matter: Date Initiated: 2/12/2015. CME Group alleged Deutsche Bank AG (London) violated CME Rule 526.F (Block Trades) during April 2014. Without admitting or denying the allegations. DBAG agreed to pay the fine of $4,000.00 which was paid on February 10, 2015. DBAG was ordered to pay a fine of $4,000.00. The fine was paid on February 10, 2015. Without admitting or denying the allegations, DBAG agreed to pay the fine of $4,000.00 which was paid on February 10, 2015. DBAG was ordered to pay a fine of $4,000.00. The fine was paid on February 10, 2015. Deutsche Bank AG (DBAG), a Contril Affiliate of the Registrant 2011-054 03/03/2015 Intercontinental Exchange Futures U.S. ("IFUS") The Registrant has not been the subject of this matter: Date Initiated: 3/3/2015. IFUS alleges that Deutsche Bank AG may have violated Exchange Rule 4.06(B) (V) by not maintaining the confirmation statements to substantiate the related physical trade in currency exchange for physical transactions in numerous instances between September 2011 and December 2013. Without admitting or denying the allegations, DBAG agreed to pay the fine of $650,000.00 which was paid on March 12, 2015. DBAG agreed to cease and desist from future violations of IFUS Rule 4.06(B) (V). DBAG was ordered to pay a fine of $650,000.00. The fine was paid on March 12, 2015. Without admitting or denying the allegations, DBAG agreed to pay the fine of $650,000.00 which was paid on March 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Case # 14-7974 03/12/2015 Chicago Mercantile Exchange Group ("CME Group") The Registrant has not been the subject of this matter: Date Initiated: 3/12/2015. CME Group cited DBSI for the use of the TAG 50 ID OGRAF which was being used across shifts and was therefore in violation of the requirements of Rule 576 and Market Regulations Advisory Notice RA0908-5. DBSI has taken all steps necessary to remediate the TAG50-ID OGRAF issues and communicated that fact to the CME. However, as has also been communicated to the CMI, there is one client which is still working to take steps to ensure the proper usage of the TAG50-ID OGRAF. The fine of $10,000.00 to the CME Group was allocated by $7,500.00 going to CME and $2,500.00 going to COMEX. DBSI was ordered to pay a fine of $10,000.00. The fine was paid on March 12, 2015. 10(e)(2)(vi). Disposition of action or claim: DBSI was ordered to pay a fine of $10,000.00. The fine was paid on March 12, 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant N/A 05/21/2015 CBOE Futures Exchange, LLC The Registrant has not been the subject of this matter: Date Initiated: 5/21/2015. CBOE Futures Exchange, LLC alleged that Deutsche Bank Securities Inc. ("DBSI") violated CFE Rule 415 (E)-Block Trading in the at the Firm failed to designated the trade as a "Block" on the account statement related to the Block transaction executed on July 1, 2013 and failed to maintain an order ticket in regards to the Block transaction executed on October 4, 2013. Without admitting or denying the allegations, DBSI agreed to pay the $2,500.00. The fine was paid. DBSI agreed to pay the $2,500.00 fine. The fine was paid. DBSI agreed to pay the $2,500.00 fine. The fine was paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant N/A 05/15/2015 CME Group The Registrant has not been the subject of this matter: Date Initiated: 5/15/2015. CME Group Market Regulation recently conducted a review of the manual order identifier ("TAG1028") for messaging submitted by Deutsche Bank Securities Inc. ("DBSI:) for trade dates December 1 through December 31, 2014. During the course of the review, it was discovered that DBSI had 5 TAG 50 ID's that submitted messages to Globex with the incorrect TAG 1028 and was therefore in violation of Rule 536.B.1 ("Globex Order Entry"). Without admitting or denying the allegations, DBSI agreed to pay the fine of $1,500.00 which was paid on May 15, 2015. DBSI agreed to pay the $1,500.00 fine. The fine was paid on May 15, 2015. DBSI agreed to pay the $1,500.00 fine. The fine was paid on May 15, 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant N/A 07/13/2015 CBOE Futures Exchange, LLC ("CFE") The Registrant has not been the subject of this matter: Date Initiated: 7/13/2015. CFE alleged Deutsche Bank Securities Inc. ("DBSI") had a late reporting of two block trades on March 17, 2015 which is a violation of CFE Rule 415(G). Without admitting or denying the allegations, DBSI agreed to pay the fine of $7,500.00. The fine was paid on 7/13/2015. DBSI agreed to pay the fine. The fine was paid on 7/13/2015. DBSI agreed to pay the fine. The fine was paid on 7/13/2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant N/A 07/29/2015 CME Group Inc. ("CME") The Registrant has not been the subject of this matter: Date Initiated: 7/29/2015. CME alleged DBSI had late reporting of four block trades on October 9, 2014, 2 on December 4, 2014 and I on February 25, 2015. Which is a violation of CME Rule 526.F. Without admitting or denying the allegations, DBSI agreed to pay the summary fine of $2,000.00. The fine was paid on July 24, 2015. DBSI agreed to pay the summary fine. The fine was paid on July 24, 2015. DBSI agreed to pay the summary fine. The fine was paid on July 24, 2015 Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130358240-01 09/11/2015 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 9/11/2015. FINRA alleged Deutsche Bank Services Inc. ("DBSI"): (1) Errors in customer confirmations, (2) Violations of equity trade reporting rules, namely incorrect reporting of buy/sell indicators, failure to submit a non-tape report identifying a party involved in a trade executed within its alternative trading system, submission of a non-media reported trade using an accurate next-day settlement modifier, inaccurate reporting of a principal trade with a riskless capacity, and submitting a media-reported transaction using an inaccurate outbound ISO modifier, (3) Violations of fixed income reporting rules, namely failures to report correct time of trade execution and failures to report within the time required, and (4) Ten transactions in securities while a trading halt was in effect with respect to each of the securities. Fine was comprised of $20,000 for customer confirmation violations, $35,000 for the equity trade reporting violations, $90,000 for the trace reporting violations, and $17,500 for the trading halt violations. The total fine is $162,500.00. Without admitting or denying the allegations, DBSI agreed to pay the fine of $162,500.00 fine. The fine was paid on October 2, 2015. The Firm was censured and fined $162,500.00. The fine was paid on October 2, 2015. The Firm was censured and fined $162,500.00. The fine was paid on October 2, 2015. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140424194-01 10/07/2015 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 10/7/2015. FINRA alleged Deutsche Bank Securities Inc. ("DBSI") during the review period failed to accept or decline in the FINRA/NASDAQ Trade Reporting Facility ("FNTRF") 126 transactions in reportable securities within 20 minutes after execution in violation of FINRA Rule 7230A(B). Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00 fine. The fine will be paid. The Firm was censured and fined $15,000.00. The fine will be paid. Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00 fine. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20110273488-01 11/19/2015 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 11/19/2015. FINRA's Department of Market Regulation (the "Staff") alleged, that between January 2005 and continuing through November, 2015, the Firm improperly included as part of its aggregation of net positions in certain securities numerous securities positions of a non-US broker-dealer affiliate. In addition, the Staff alleged that during the period of April 2004 through September 2012, the Firm improperly reported certain short interest positions on a net, instead of gross, basis. The Staff also alleged policy deficiencies related to both issues. The Staff alleged violations of Reg. SHO, NASD Rule 2110, 3010 and 3360 and FINRA Rules 2010, 3110 and 4560, applicable at different times during the period at issue. The staff conducted an investigation of the Firm's compliance with SEC and FINRA rules and regulations regarding certain short sale transactions. As a result, the Staff alleged that between January 2005 and continuing through November 2015, the Firm improperly included as part of its aggregation of net positions in certain securities numerous securities positions of a non-US broker-dealer affiliate. In addition, the Staff alleged that during the period of April 2004 through September 2012, the Firm improperly reported certain short interest positions on a net, instead of gross, basis. The Staff also alleged policy deficiencies related to both issues. Without admitting or denying the findings, the Firm accepted and consented to the entry of findings that the above violated Rule 200(F) of Reg. SHO, NASD Rule 2010, FINRA Rule 2010, and NASD Rule 3360, FINRA Rule 4560, NASD Rule 3010 and FINRA Rule 3110, as applicable during different periods at issue. The fine was paid on November 23, 2015. Undertaking: Revise the Firm's written supervisory procedures. Without admitting or denying the findings contained in the Acceptance Waiver of Consent ("AWC"), DB consented to the entry of the AWC. DB also agreed to (1) pay a monetary fine in the amount of $1,400,000, which was remitted in November, 2015 and (2) revise its written policies and procedures. DB consented to the entry of the AWC. DB also agreed to (1) pay a monetary fine in the amount of $1,400,000, which was remitted in November, 2015 and (2) revise its written policies and procedures. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130354658-01 12/29/2015 New York Stock Exchange LLC c/o Financial Industry Regulatory Authority The Registrant has not been the subject of this matter: Date Initiated: 12/29/2015. NYSE/FINRA alleged Deutsche Bank Securities Inc. ("DBSI") violated Section 11(A) of the Securities Exchange Act of 1934 in 168 instances in connection with syndicate offerings. NYSE/FINRA further alleges DBSI violated Rule 92 in various situations. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure and a fine of $150,000.00. The fine will be paid. The fine of $150,000.00 will be paid. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure and a fine of $150,000.00. The fine will be paid. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant Decision - CBOT 14-9808-BC 03/04/2016 CME Group The Registrant has not been the subject of this matter: Date Initiated: 3/4/2016. CME Group alleged Deutsche Bank AG ("DBAG") violated legacy CBOT Rules 534 (Wash Trades Prohibited), 538.A (Nature of an EFRP) and 538.B (Related Positions). These transactions occurred on June 4, 2013 and August 29, 2013. Without admitting or denying any rule violations, DBAG agreed to pay the fine of $60,000.00 which was paid on March 16, 2016. DBAG agreed to pay the $60,000.00 fine. It was paid on March 16, 2016. Without admitting or denying any rule violations, DBAG agreed to pay the fine of $60,000.00 which was paid on March 16, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140425698-01 03/11/2016 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 3/11/2016. FINRA alleged DBSI violated FINRA Rules 6730 and 6730(C). With respect to Rule 6730 FINRA stated DBSI failed to report to TRACE 58 large block S1 transactions within the time required by FINRA Rule 6730. Also, DBSI failed to report 92 new issue offerings in TRACE-eligible securitized products to FINRA in accordance with the time frame set forth in FINRA Rule 6760(C) and DBSI failed to report 196 new issue offerings in TRACE-eligible corporate debt securities to FINRA in accordance with the time frame set forth in FINRA Rule 6760(C). Without admitting or denying the allegations, DBSI agreed to pay the fine of $120,000.00. The fine will be paid. DBSI agreed to pay the fine of $120,000.00. The fine will be paid. Without admitting or denying the allegations, DBSI agree to pay the fine of $120,000.00 the fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2012-070 03/23/2016 International Securities Exchange, LLC The Registrant has not been the subject of this matter: Date Initiated: 3/23/2016. ISE alleged that Deutsche Bank Securities Inc. ("DBSI") during a sampled period between January 2010 and March 2015, failed to report options positions to the LOPR in as many as 943,545 instances and over-reported options positions to the LOPR in as many as 1,751,183 instances. In addition, the findings state that DBSI submitted inaccurate reports to the LOPR, in that the Firm entered incorrect data in the "effective date" field due to errors involving the Firm's third-party vendor's processing of certain trades. During the same sampled period, DBSI misreported options positions to the LOPR in tens of millions of instances as a result of errors in various required LOPR data fields (e.g., City, Quantity, and Tax Identification fields) when reporting those positions and its failure to report acting in concert identifiers in certain instances. This conduct violated ISE Rule 415(A). Also, DBSI failed to maintain adequate supervisory systems and controls, including adequate written supervisory procedures, reasonably designed to achieve the accurate reporting of reportable options positions to the LOPR. This constitutes a violation of ISE Rule 401. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking and a fine of $1,333,333.00. The fine was paid on 4/12/2016. Undertaking: 90 days after this AWC becomes final, and again 180 days after this AWC becomes final, DBSI shall make a written submission to FINRA regarding, its options positions reporting to LOPR. DBSI was fined $4,070,000 in total by FINRA, International Securities Exchange, and NASDAQ PHLX of which $1,333,333 was paid to ISE on 4/12/2016. Without admitting or denying the allegations, DBSI agreed to a Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking and a fine of $1,333,333.00. The fine was paid on 4/12/2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20110296003-01 03/28/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 3/28/2016. FINRA alleged DBSI exceeded the relevant position limit in three different securities for five different customers (exceeding the relevant position limit in a range of between 7.9 percent and 120 percent) for between one and seven consecutive days during October 2011, January 2014, November 2014, and January 2015 through February 2015. The findings stated that the Firm reported incorrect options contract equivalent of the Net Delta (OCENDS), excluded certain expiring options from its end-of-day OCEND calculations in one symbol, and failed to report its OCEND in one symbol. The findings also stated that the Firm failed to report or failed to accurately report, an unknown but significant number of conventional options positions to the Options Clearing Corporation (OCC) Large Options Positions Report (LOPR). In as many as approximately two million instances, the Firm had failed to report conventional options positions to the LOPR due to the Firm's failure to aggregate certain positions for acting in concert (AIC) purposes and the Firm's erroneous deletion of positions that fell below the 200-contract reporting threshold without first reporting the below-the-threshold amount to the OCC. In as many as 1.5 million instances, the Firm had over-reported conventional options to the LOPR due to the Firm's erroneous aggregation method and in tens of millions of instances, the Firm had failed to accurately report conventional options positions to the LOPR as a result of errors in various required LOPR data fields (e.g., Account Name, Tax Identification, and Account Address) and its failure to report AIC identifiers in certain instances. The findings also included that the Firm failed to maintain an adequate system of supervision, including systems of follow-up and review, which were reasonably designed to achieve compliance with the rules governing the reporting of positions to the LOPR system and compliance with position limits. The Firm also lacked sufficient written supervisory procedures requiring reviews to ensure compliance with position limits, to determine that LOPR submissions were accurate, to review rejects, to ensure that all reportable positions had actually been reported, and to identify and report options positions appropriately as AIC. This constitutes violations of FINRA Rule 2360(B)(3), NASD Rule 2360(B)(3) (A)(VII) (B)(2)(A) (for the period prior to February 17, 2009) and FINRA Rules 2360(B)(3) (A)(II) (B)(2)(A) (for the period after February 16, 2009), 2360(B)(3) (A)(II) (B)(4), Rule 2360(B)(5), NASD Rule 3010 (for the period prior to 12/1/2014), and FINRA Rules 2010 and 3110 (for the period after 11/30/2014). Without admitting or denying the allegations, DBSI agreed to A Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking, and a fine of $1,403,334.00. The fine was paid on 4/12/2016. Undertaking: 90 days after this AWC becomes, and again 180 days after this AWC becomes final, DBSI shall make a written submission to FINRA regarding, its options positions reporting to LOPR. DBSI was fined $4,070,000 in total by FINRA, International Securities Exchange, and NASDAQ PHLX of which $1,403,334 was paid to FINRA on 4/12/2016. Without admitting or denying the allegations, DBSI agreed to A Letter of Acceptance, Waiver and Consent ("AWC") consenting to a censure, undertaking, and a fine of $1,403,334.00. The fine was paid on 4/12/2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20120330918 03/23/2016 NASDAQ PHLX LLC The Registrant has not been the subject of this matter: Date Initiated: 3/23/2016. NASDAQ PHLX LLC alleged that Deutsche Bank Securities Inc. ("DBSI") during a sampled period between January 2010 and March 2015, failed to report options positions to the LOPR in as many as 943,545 instances and over-reported options positions to the LOPR in as many as 1,751,183 instances. In addition, the findings state that DBSI submitted inaccurate reports to the LOPR, in that the Firm entered incorrect data in the "Effective Date" field due to errors involving the Firm's third-party vendor's processing of certain trades. During the same sampled period, DBSI misreported options positions to the LOPR in tens of millions of instances as a result of errors in various required LOPR data fields (e.g., City, Quantity, and Tax Identification fields) when reporting those positions and its failure to report acting in concert identifiers in certain instances. Also, DBSI failed to maintain adequate supervisory systems and controls, including adequate written supervisory procedures, reasonably designed to achieve the accurate reporting of reportable options positions to the LOPR. This constitutes violations of Exchange Rules 748 and 1003. Without admitting or denying the allegations, DBSI agreed to the decision issued upon acceptance of offer of settlement consenting to a censure, undertaking, and a fine of $1,333,333.00. The fine was paid on 4/14/2016. Undertaking: 90 days after this AWC becomes final, and again 180 days after this AWC becomes final, DBSI shall make a written submission to FINRA regarding, its options positions reporting to LOPR. DBSI was fined $4,070,000 in total by FINRA, International Securities Exchange, and NASDAQ PHLX of which $1,333,333 was paid to NASDAQ PHLX LLC on 4/14/2016. Without admitting or denying the allegations, DBSI agreed to the decision issued upon acceptance of offer of settlement consenting to a censure, undertaking, and a fine of $1,333,333.00. The fine was paid on 4/14/2016. Deutsche Bank AG London Branch (DBAG), a Control Affiliate of the Registrant CME 15-0242-BC 06/03/2016 CME Group The Registrant has not been the subject of this matter: Date Initiated: 6/3/2016. CME Group alleged that DBAG London Branch executed an Exchange for Related Position ("EFRP") transaction on June 30, 2015 in which the related position transaction was established and offset without the incurrence of market risk. The transaction was transitory in nature and therefore non-bona fide. As a result, CME alleged that DBAG violated Exchange Rule 538.C. Without admitting or denying any rule violations, DBAG London Branch agreed to pay the fine of $15,000.00 which was paid on June 6, 2016. DBAG London Branch agreed to pay the $15,000.00. The fine was paid on June 6, 2016. Without admitting or denying any rule violations, DBAG London Branch agreed to pay the fine of $15,000.00 which was paid on June 6, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20150442966-01 06/28/2016 Financial Industry Regulatory Authority ("FINRA") The Registrant has not been the subject of this matter: Date Initiated: 6/28/2016. FINRA alleged that, from 2008 through at least 2015, Deutsche Bank Securities Inc. ("DBSI") experienced multiple problems with its Blue Sheet system that caused it to submit inaccurate and late Blue Sheets to the SEC and FINRA in violation of Section 17 (A) and Rules 17A-4(J), 17A-4(F) (3) (V), and 17A-25 of the Exchange Act and NASD Rules 8211, 8213, 3010(B), and 2110, later replaced by FINRA Rules 8211, 8213, 3110 (B), and 2010. Without admitting or denying the findings, and in order to fully resolve the matter, the Firm consented to the imposition of a censure, a fine of $600,000.00, and to retain an independent consultant to review the Firm's policies, systems, procedures, and training relating to Blue Sheets. The fine was paid on July 11, 2016. The Firm consented to a censure, fine of $600,000.00, and to retain an independent consultant to review the Firm's policies, systems, procedures, and training relating to Blue Sheets. The fine was paid on July 11, 2016. Without admitting or denying the findings, and in order to fully resolve the matter, the Firm consented to the imposition of a censure, a fine of $600,000.00, and to retain an independent consultant. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20120350032-01 08/08/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 8/8/2016. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") violated NASD Rules 3010 (for violations occurring before December 1, 2014) and 2010 (for violations occurring on or before December 14, 2008) and FINRA Rules 3110 (for violations occurring on or after December 1, 2014) and 2010 (for violations occurring on or after December 15, 2008) in connection with DBSI's alleged failure to establish, maintain, and enforce adequate supervisory systems, written policies, and procedures, including WSPS, reasonably designed to supervise certain registered representatives access to internal broadcast system speakers in transmissions known as Hoots or their communications with customers regarding Hoots. DBSI undertook to provide a written certification by a duly authorized senior officer that it has adopted and implemented supervisory systems and written procedures reasonably designed to achieve compliance with FINRA rules and federal securities laws with respect to Hoots. Without admitting or denying the findings, DBSI consented to a censure, fine in the amount of $12,500,000.00 and certain undertakings. The fine will be paid. Without admitting or denying the findings, DBSI consented to a censure, fine in the amount of $12,500,000.00 and certain undertakings. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140419100-01 08/22/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 8/22/2016. FINRA alleged that Deutsche Bank Securities Inc. ("DBSI") during the review period of March 15, 2012 and May 15, 2014 violated FINRA Rule 4560 in that DBSI failed to report short interest positions in dually-listed securities, because the Firm had been unaware that a U.S. ticker symbol had been assigned to such securities after the firm's initial short position had been established. In addition, DBSI's supervisory system and written supervisory procedures (WSPs) did not provide for supervision reasonably designed to achieve compliance with respect to the FINRA rules regarding short interest reporting, particularly with respect to dually-listed securities which constitutes violations of NASD Rule 3010 and FINRA Rule 2010. Without admitting or denying the allegations, DBSI consented to a censure, and a fine in the amount of $200,000.00 ($125,000 for short interest reporting violations and $75,000 for the supervisory violations). The fine was paid on September 19, 2016. The Firm consented to a censure and a fine in the amount of $200,000.00 ($125,000 for short interest reporting violations and $75,000 for the supervisory violations). The fine was paid on September 19, 2016. Without admitting or denying the allegations, DBSI consented to a censure, and a fine in the amount of $200,000.00 ($125,000 for short interest reporting violations and $75,000 for the supervisory violations). The fine was paid on September 19, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130375779--01 09/07/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 9/7/2016. FINRA alleged DBSI violated Rule 201(B) of Regulation SHO, NASD Rule 3010, and FINRA Rule 2010. With respect to Rule 201(B) of Regulation SHO, FINRA stated DBSI failed to establish, maintain, and enforce written policies and procedures reasonably designed to prevent the execution or display of non-exempt short sale in a security subject to a short sale circuit breaker at a price at or below the national best bid. FINRA states that DBSI's supervisory system did not provide for supervision reasonably designed to achieve compliance with Rule 201(B) of Regulation SHO. Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00. The fine will be paid. DBSI agreed to revise its controls and procedures, including WSPs within 30 business days of acceptance of the AWC. DBSI agreed to pay the fine of $15,000.00. The fine will be paid. DBSI agreed to revise its controls and procedures including WSPs within 30 business days of acceptance of the AWC. Without admitting or denying the allegations, DBSI agreed to pay the fine of $15,000.00. The fine will be paid. DBSI agreed to revise its controls and procedures, including WSPs within 30 business days of acceptance of the AWC. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20150464546-01 11/28/2016 FINRA The Registrant has not been the subject of this matter: Date Initiated: 11/28/2016. FINRA alleged that during a review period from April 1, 2015 through September 30, 2015, Deutsche Bank Securities Inc. ("DBSI"), in 204 instances improperly reported information to the Real-time Transaction Reporting System ("RTRS") that it was not required to report. The findings stated that specifically, DBSI over-reported 204 purchase and sale transactions effected in municipal securities to he RTRS when such transactions are non-reportable to the Municipal Securities Rulemaking Board ("MSRB"). This conduct was in violation of MSRB Rule G-14. Without admitting or denying the allegations, DBSI consented to a censure, fine in the amount of $17,500.00. The fine was paid on December 2, 2016. DBSI was censured and fined $17,500.00. The fine was paid on December 2, 2016. Without admitting or denying the allegations, DBSI consented to a censure, fine in the amount of $17,500.00. The fine was paid on December 2, 2016. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140429134-01 12/15/2016 FINRA In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(v). In reference to the "Title of Action" noted above, please see response to question 10(e)(1)(vi). Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2013039313502 (Incl 20140435497) 05/15/2017 NYSE MKT LLC The Registrant has not been the subject of this matter: Date Initiated: 5/15/2017. A. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, a certain post-trade market abuse surveillance was not run on the Firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the Firm failed to feed its DMA order data into the surveillance models with only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013 through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,667.00. The fine will be paid. Monetary fine of $191,667.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,667.00. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2013039313503 (Incl 20140417491 and 20140435497) 05/15/2017 New York Stock Exchange LLC The Registrant has not been the subject of this matter: Date Initiated: 5/15/2017. A. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, a certain post-trade market abuse surveillance was not run on the Firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013 through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,666.00. The fine will be paid. Monetary fine of $191,666.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,666.00. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135 (Incl 20140417491 and 20140435497) 05/15/2017 NYSE ARCA The Registrant has not been the subject of this matter: Date Initiated: 5/15/2017. A. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, a certain post-trade market abuse surveillance was not run on the Firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013 through December 31, 2014 on another. B. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,666.00. The fine will be paid. Monetary fine of $191,666.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $191,666.00. The fine will be paid. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-08 (Incl. 20140435497) 05/19/2017 BATS BZX Exchange, Inc. The Registrant has not been the subject of this matter: Date Initiated: 5/19/2017. A.20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the Firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with Smart Order Routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. The Firm was censured and fined $168,750.00. The fine was paid on August 7, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-10 (Incl. 20140417491 and 20140435497) 05/19/2017 BATS EDGA Exchange, Inc. The Registrant has not been the subject of this matter: Date Initiated: 5/19/2017. A. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. The Firm was censured and fined $168,750.00. The fine was paid on August 7, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-11 (Incl. 20140417491 and 20140435497) 05/19/2017 BATS EDGX Exchange, Inc. The Registrant has not been the subject of this matter: Date Initiated: 5/19/2017. A. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. The Firm was censured and fined $168,750.00. The fine was paid on August 7, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-06 (Incl. 20140417491 and 20140435497) 07/27/2017 NASDAQ BX, Inc. The Registrant has not been the subject of this matter: Date Initiated: 7/27/2017. A. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Monetary fine of $225,000.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-04 (Incl. 20140417491, 20140399393, and 20140435497) 07/27/2017 FINRA, Department of Market Regulation The Registrant has not been the subject of this matter: Date Initiated: 7/27/2017. A.20140399393: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with market access based on observations from the Firm's 2014 TMMS examination for the trade date of April 23, 2014. The findings indicated that the Firm did not have adequate written supervisory procedures related to: (1) the escalation of certain unusually sized orders for its "high touch" order flow, (2) monitoring changes to certain customer trading limits, (3) monitoring for erroneous orders on a pre-trade basis, and (4) monitoring changes to user system access. B.20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. C. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with Smart Order Routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $575.000.00. Monetary fine of $575,000.00. The fine was paid on August 7, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $575.000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant PHLX Enforcement No. 2017-08; FINRA No. 20130393135-07 [Incl. 20140417491 AND 20 07/27/2017 NASDAQ PHLX LLC The Registrant has not been the subject of this matter: Date Initiated: 7/27/2017. A. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the Firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with smart order routing), the firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Monetary fine of $225,000.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-05 [Incl. 20130393135, 20140417491, and 20140435497] 07/27/2017 NASDAQ Stock Market LLC The Registrant has not been the subject of this matter: Date Initiated: 7/27/2017. A. 20130393135: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with market access on December 23, 2014. The findings indicated that the Firm failed to have adequate controls in place to prevent the transmission of erroneous orders, because (i) its limit order controls did not take into consideration wide spreads that are quoted at the market open and are not an accurate representation of the trading price of a security; (ii) its controls failed to prevent the entry of a large pre-open market order that resulted in the execution of orders far away from the normal trading price of the security; and (iii) the Firm used an incorrect process to adjudicate a transaction. Specifically, the findings stated that on December 3, 2013, the Firm sent a clearly erroneous filing to NASDAQ in PTC, Inc. When it entered an order at 9:30:00, which resulted in a 100-share execution at $2.21 when the previous close on that stock was $32.58 and the NASDAQ official opening print at that time, but after the Firm's trade, was $32.43. The findings state further that on December 23, 2014, trades occurred between 9:33:00 and 9:34:00, in which the Firm received an electronic buy order for 50,000 shares at market price, and the Firm's Smart Order Router sent high-priced limit orders to various exchanges. Finally, the findings stated that on December 3, 2014, the Firm sent a CE Filing to NASDAQ in market vectors gold miners ETF when trades occurred between 15:59:00 and 16:00:00 in which a 250,000-share sell market order fully executed at $17.72, but NASDAQ declined to act, advising that the CE Filing did not meet the parameters to justify breaking the trade. B. 20140417491: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with its Direct Market Access (DMA) business because the firm failed to include a customer's DMA trading activity in its post-trade market abuse surveillance between March 1, 2014 and April 30, 2014, and, in doing so, failed to detect potential layering activity by this customer. C. 20140435497: the findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with Smart Order Routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Monetary fine of $225,000.00. The fine will be paid. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $225,000.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20130393135-09 (Incl. 20130393135 and 20140435497) 05/19/2017 BATS BYX Exchange, Inc. The Registrant has not been the subject of this matter: Date Initiated: 5/19/2017. A. 20130393135: The findings stated that the Firm failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the regulatory risks in connection with market access on December 23, 2014. The findings indicated that the Firm failed to have adequate controls in place to prevent the transmission of erroneous orders, as its controls failed to prevent the entry of a large pre-open market order that resulted in the execution of orders far away from the normal trading price of the security, specifically, the findings stated that the Firm sent a clearly erroneous filing to NASDAQ in TARGA Resources Partners LP when trades occurred between 9:30:00 and 9:34:00, in which the Firm received an electronic buy order for 50,000 shares at market price, and the Firm's Smart Order Routers sent high-priced orders to various exchanges. B. 20140435497: The findings state that the Firm discovered and self-reported to FINRA that due to an error during a change in the Firm's internal systems, certain post-trade market abuse surveillance was not run on the firm's customer equity DMA business when utilizing two separate systems. The findings indicated that in transitioning to one system (a customer DMA platform with Smart Order Routing), the Firm failed to feed its DMA order data into the surveillance models. With only executed trades considered by the Firm's post-trade surveillance, potential manipulative order activity was not captured as part of the Firm's obligation to monitor for manipulation, fraud, and other illegal activity. The findings stated that the gap in post-trade market abuse surveillance occurred from July 1, 2012 through November 30, 2014 on one system, and from July 1, 2013, through December 31, 2014 on another. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. Monetary fine of $168,750.00. The fine was paid on August 7, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. consented to the imposition of a censure and a fine in the amount of $168,750.00. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2014040946501 08/21/2017 FINRA The Registrant has not been the subject of this matter: Date Initiated: 8/21/2017. A. 2014040946501: A. 2014040946501: FINRA alleged that DBSI during the review period, from January 1, 2014 through March 31, 2014, which was later expanded to include the period of January 1, 2011 through June 30, 2014 failed to timely report to the FINRA/NASDQ trade reporting facility (TRF) by 8:00 p.m. Eastern Time transactions that required an .rx modifier. The findings stated that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to applicable securities laws and regulations, and FINRA rules, concerning the reporting of physically settled OTC options exercises to the TRF. Without admitting or denying the allegations, Deutsche Bank Securities Inc. agreed to a letter of Acceptance, Waiver and Consent (AWC) consenting to a censure and a fine in the amount of $32,500.00. The fine was paid on September 1, 2017. Without admitting or denying the allegations, Deutsche Bank Securities Inc. agreed to a letter of Acceptance, Waiver and Consent (AWC) consenting to a censure and a fine in the amount of $32,500.00. The fine was paid on September 1, 2017. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File no. CFE 17-0005 09/07/2017 CBOE Futures Exchange, LLC ("CFE") The Registrant has not been the subject of this matter: Date Initiated: 9/7/2017. File no. CFE 17-0005 CBOE Futures Exchange, LLC ("CFE") alleges that from September 2012 through December 2012, DBSI violated CFE Rule 403(c) and 502, in that DBSI failed to maintain front-end audit trail information for all electronic orders into the CBOE system and to keep all books and records required by rules of the exchange. DBSI neither admitted nor denied the rule violation upon which the penalty is based. The fine of $20,000.00 was paid on September 15, 2017. DBSI consented to a fine of $20,000.00. The fine was paid on September 15, 2017. DBSI neither admitted nor denied the rule violation upon which the penalty is based. The fine of $20,000.00 was paid on September 15, 2017. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 2015044324901 12/13/2017 FINRA The Registrant has not been the subject of this matter: Date Initiated: 12/13/2017. Docket/Case number: 2015044324901. The FINRA AWC alleges that, during the period from October 1, 2014 through December 31, 2016, DBSI inadequately supervised its compliance with trace reporting requirements, and that in nineteen separate matters during the same period DBSI had failed to comply with trace reporting requirements by failing to timely or accurately report, or by failing to report, certain transactions in eligible securities. Without admitting or denying the allegations, DBSI agreed to an AWC accepting and consenting to a censure and fine of $1,100,000.00. The fine was paid on December 15, 2017. Without admitting or denying the allegations, DBSI agreed to an AWC accepting and consenting to a censure and fine of $1,100,000.00. The fine was paid on December 15, 2017. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 20150443242-01 02/13/2018 NYSE ARCA The Registrant has not been the subject of this matter: Date Initiated: 02/13/2018. Docket/Case number: No. 20150443242-01. on February 13, 2018, NYSE ARCA found that Deutsche Bank Securities Inc. violated: (i) Exchange Act Rule 17a-3 and NYSE ARCA options rule 6.68 by failing to show the time of order transmission on an estimated 2,550 memoranda of its brokerage orders; and (ii) NYSE ARCA rule 11.18 by failing to implement a supervisory system reasonably designed to ensure compliance with applicable federal securities laws and regulations, and the rules of the exchange, relating to creating and maintaining accurate and complete books and records. This settlement was one of a set of four related settlements in which, without admitting or denying the allegations, Deutsche Bank Securities Inc. agreed to pay a total fine of $315,000, of which $33,500 was paid to NYSE ARCA Inc., and the remaining amounts were paid to NASDAQ PHLX LLC, NYSE AMERICAN LLC, and Chicago Board Options Exchange. The Firm was fined $33,500.00. The fine was paid to NYSE ARCA on February 20, 2018. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant File No. 18-0002 (Star No. 20150443242) 02/13/2018 CHICAGO BOARD OF OPTIONS EXCHANGE ("CBOE") The Registrant has not been the subject of this matter: Date Initiated: 02/13/2018. Docket/Case number: File No. 18-0002 (Star No. 20150443242). On February 13, 2018, CBOE found that Deutsche Bank Securities Inc. violated: (i) exchange act rule 17a-3 and CBOE Exchange rules 4.2 and 15.1 by failing to show the time of order transmission on 51,000 memoranda of its brokerage orders; and (ii) CBOE Exchange rule 4.24 by failing to implement a supervisory system reasonably designed to ensure compliance with applicable federal securities laws and regulations, and the rules of the exchange, relating to creating and maintaining accurate and complete books and records. This settlement was one of a set of four related settlements in which, without admitting or denying the allegations, Deutsche Bank Securities Inc. agreed to pay a total fine of $315,000, of which $142,000 was paid to Chicago Board Options Exchange, and the remaining amounts were paid to NYSE ARCA, NASDAQ PHLX LLC, and NYSE AMERICAN LLC. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 20150443242-03 02/13/2018 NASDAQ PHLX LLC The Registrant has not been the subject of this matter: Date Initiated: 02/13/2018. Docket/Case number: 20150443242-03. On February 13, 2018, NASDAQ PHLX found that Deutsche Bank Securities Inc. violated: (i) Exchange Act Rule 17a-3 and PHLX Rule 760 by failing to show the time of order transmission on certain memoranda of its brokerage orders; and (ii) PHLX Rule 748 by failing to implement a supervisory system reasonably designed to ensure compliance with applicable federal securities laws and regulations, and the rules of the exchange, relating to creating and maintaining accurate and complete books and records. This settlement was one of a set of four related settlements in which, without admitting or denying the allegations, Deutsche Bank Securities Inc. agreed to pay a total fine of $315,000, of which $74,000 was paid to NASDAQ PHLX LLC, and the remaining amounts were paid to, NYSE AMERICAN LLC, NYSE ARCA, Inc. and Chicago Board Options Exchange. The firm was fined $74,000.00. The fine was paid to NASDAQ PHLX LLC via Deutsche Bank Securities Inc. February invoice. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant No. 20150443242-02 02/12/2018 NYSE AMERICAN LLC The Registrant has not been the subject of this matter: Date Initiated: 02/12/2018. Docket/Case number: 20150443242-02. On February 12, 2018, NYSE AMERICAN found that Deutsche Bank Securities Inc. violated: (i) exchange act rule 17a-3 and NYSE AMERICAN Rule 956.ny by failing to show the time of order transmission on an estimated 7,650 memoranda of its brokerage orders; and (ii) NYSE AMERICAN Rule 320 by failing to implement a supervisory system reasonably designed to ensure compliance with applicable federal securities laws and regulations, and the rules of the exchange, relating to creating and maintaining accurate and complete books and records. This settlement was one of a set of four related settlements in which Deutsche Bank Securities Inc. agreed to pay a total fine of $315,000, of which $65,500 was paid to NYSE AMERICAN LLC, and the remaining amounts were paid to NASDAQ PHLX LLC, NYSE ARCA, Inc., and Chicago Board Options Exchange. The firm was fined $65,500.00. The fine was paid to NYSE AMERICAN LLC on February 20, 2018. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-01 05/01/2018 FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") The registrant has not been the subject of this matter: Date initiated: 05/01/2018. Docket/Case number: 20130379938-01. FINRA alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. Limitations in the firm's systems also led to time stamps on orders being improperly recorded. Lastly, on several occasions the firm failed to report transactions as trade-through exempt, and the firm failed to comply with sec rule 602 and had deficient procedures with respect to that rule. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with FINRA and five exchanges. FINRA and the five exchanges all approved the settlement as of May 1, 2018. Under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, of which $100,000 is payable to FINRA, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-06 05/01/2018 NYSE ARCA, INC. ("ARCA") The registrant has not been the subject of this matter: Date Initiated: 04/27/2018. Docket/Case number: 20130379938-06. ARCA alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with ARCA, FINRA and four other exchanges. ARCA, FINRA and the four other exchanges all approved the settlement as of May 1, 2018. Under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, of which $75,000 is payable to ARCA, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-05 05/01/2018 CBOE EDGX EXCHANGE, INC. ("EDGX") The Registrant has not been the subject of this matter: Date Initiated: 05/01/2018. Docket/Case number: 20130379938-05. EDGX alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with EDGX, FINRA and four other exchanges. EDGX, FINRA and the four other exchanges all approved the settlement as of May 1, 2018. under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-02 05/01/2018 CBOE BZX EXCHANGE, INC. ("BZX") The Registrant has not been the subject of this matter: Date Initiated: 05/01/2018. Docket/Case number: 20130379938-02. BZX alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with BZX, FINRA and four other exchanges. BZX, FINRA and the four other exchanges all approved the settlement as of May 1, 2018. Under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, of which $75,000 is payable to BZX, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-03 05/01/2018 CBOE BYX EXCHANGE, INC. ("BYX") The Registrant has not been the subject of this matter: Date Initiated: 05/01/2018. Docket/Case number: 20130379938-03. BYX alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with BYX, FINRA and four other exchanges. BYX, FINRA and the four other exchanges all approved the settlement as of May 1, 2018. Under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, of which $75,000 is payable to BYX, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant Docket/Case number: 20130379938-04 05/01/2018 CBOE EDGA EXCHANGE, INC. ("EDGA") The Registrant has not been the subject of this matter: Date Initiated: 05/01/2018. Docket/Case number: 20130379938-04. EDGA alleged that as the result of various proprietary system flaws and deficiencies, the firm on numerous occasions routed ISOS through protected quotations. On May 1, 2018, DBSI, without admitting or denying the findings or conclusions therein, entered into a settlement with EDGA, FINRA and four other exchanges. EDGA, FINRA and the four other exchanges all approved the settlement as of May 1, 2018. Under the terms of the settlement, DBSI agreed to pay a total fine of $475,000, of which $75,000 is payable to EDGA, which is in the process of being paid, to accept a censure, and to comply with undertakings regarding improving its written supervisory procedures and correcting a system issue. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20140418941-01 06/27/2018 FINRA FINRA alleged that, from the time period June 2006 to April 2017, the firm, due to systemic deficiencies, failed to have reasonable supervisory procedures in place that resulted numerous oats and equity trade reporting violations. FINRA also alleged that the firm violated municipal bond trading and other supervision requirements. The AWC included an undertaking to revise relevant firm SWPS by September 25, 2018, and an undertaking to provide additional corrective action report to FINRA by December 24, 2018. Without admitting or denying the allegations, DBSI agreed to an AWC accepting and consenting to a censure, undertaking and fine of $1,400,000.00. The fine was paid on July 9, 2018. See above Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2017-058-00037 09/17/2018 New York Stock Exchange LLC From October 1, 2015 to March 31, 2017, NYSE alleges that Deutsche Bank Securities Inc.("DBSI") violated NYSE Rule 3110(b)(4) by failing to establish and maintain reasonably designed procedures for the review of electronic communications because the lexicons used by DBSI as part of its review process were not reasonably designed. Pursuant to a letter of acceptance, waiver, and consent with the New York Stock Exchange LLC ("NYSE") that became final on September 18, 2018, DBSI, without admitting or denying the findings, consented to a censure and $65,000 fine to resolve allegations Deutsche Bank AG (DBAG) CME 17-0729 10/26/2018 Chicago Mercantile Exchange The action was resolved by decision of CME business conduct committee dated October 24, 2018, which became effective on October 26, 2018. The decision accepted an offer of settlement from Deutsche Bank AG and directed Deutsche Bank AG to pay a fine of $75,000 on or before November 9, 2018. Without admitting or denying the allegations, Deutsche Bank AG paid the fine in full on November 6, 2018. See above. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2016051138301 11/06/2018 NASDAQ Stock Exchange Without admitting or denying the allegations, Deutsche Bank Securities Inc. (DBSI) consented to the sanctions and to the entry of findings that DBSI failed to maintain a continuous two-sided trading interest, during regular market hours, at prices within certain percentages away from the national best bid or offer (NBBO). The findings stated that these violations occurred from DBSI failing to properly submit a market maker peg order due to a manual process, and from internal system errors. The findings also stated that DBSI's supervisory system was not reasonably designed to achieve compliance with NASDAQ quoting obligations. Specifically, DBSI's written supervisory procedures (WSPS) failed to establish a procedure for review of the manual process that DBSI used to determine its daily quoting obligation. Without admitting or denying the allegations, Deutsche Bank Securities Inc. ("DBSI") consented to the AWC and to pay a fine in the amount of $22,500.00 Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant FILE NO. CFE 19-0007 01/16/2020 CHICAGO FUTURES EXCHANGE, LLC ("CFE") CFE ALLEGED THAT IN FEBRUARY 2019, DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO PROPERLY REPORT OPEN INTEREST TO THE OPTIONS CLEARING CORPORATION, RESULTING IN OVERSTATEMENTS OF THE FEBRUARY 2019 VX06 OPEN INTEREST FOR FOUR DAYS PROXIMATE TO THE CONTRACT'S FINAL SETTLEMENT DATE WHICH IS A VIOLATION OF CFE RULE 410A. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI AGREED TO PAY THE FINE OF $22,500.00. THE FINE WAS PAID ON 2/3/20. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant NO. 2019-05-00003 06/30/2020 NEW YORK STOCK EXCHANGE LLC ("NYSE") NEW YORK STOCK EXCHANGE LLC ("NYSE") Description: NYSE ALLEGED RULE VIOLATIONS RELATED TO TECHNICAL ISSUES ASSOCIATED WITH HOW THE FIRM USED TO ROUTE ORDERS TO NYSE FLOOR BROKERS FOR EXECUTION BETWEEN JANUARY 1, 2018 TO AUGUST 31, 2018. NYSE ALLEGED THAT THESE TECHNICAL ISSUES CAUSED THE FIRM TO INADVERTENTLY ROUTE CERTAIN ORDERS IN VIOLATION OF NYSE RULE 122, WHICH, IN CERTAIN INSTANCES, PROHIBITS ROUTING ORDERS FOR THE SAME PRINCIPAL TO MULTIPLE FLOOR BROKERS. NYSE ALSO ALLEGED THAT DBSI FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY RULES IN CONTRAVENTION OF NYSE RULE 3110(A) AND (B). W/OUT ADMITTING/DENYING ALLEGATIONS, DBSI CONSENTED TO THE AWC & PAY A FINE OF $65,000.00. THESE FINDINGS RELATED TO HISTORICAL ACTIVITY & THE FIRM HAS NOT OPERATED AS A NYSE FLOOR BROKER SINCE APPROX. SEPT. 2018. NO ADDITIONAL TERMS OR CONDITIONS. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2016050292001 11/03/2020 NASDAQ PHLX LLC ("PHLX") NASDAQ PHLX LLC ("PHLX") ALLEGED THAT DEUTSCHE BANK SECURITIES INC.'S ("DBSI") SUPERVISORY SYSTEM INCLUDING ITS WRITTEN SUPERVISORY PROCEDURES ("WSPS"), WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FIRM'S BEST EXECUTION OBLIGATIONS UNDER PHLX RULE 764 WHEN MANUALLY EXECUTING AND/OR FACILITATING OPTIONS ORDERS. AS A RESULT, PHLX ALLEGED THAT DBSI VIOLATED PHLX RULE 748. 11/3/20 DBSI ENTRD A LETTER OF ACCEPTANCE, WAIVER & CONSENT. PHLX ALLEGED 6/16-8/18, SUPERVISORY SYSTEM & WSPS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE W/ BEST EXECUTION OBLNS. W/OUT ADMTTNG OR DENYING, DBSI AGREED TO A CENSURE & $55K FINE TO BE PAID Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 20170700081 12/21/2017 NYSE/ARCA NYSE/ARCA ALLEGED THAT DBSI (1) FAILED TO MAINTAIN CONTINUOUS, TWO-SIDED Q ORDERS IN SECURITIES IN WHICH DBSI IS REGISTERED TO TRADE, IN VIOLATION OF NYSE ARCA, INC. RULE 7.23(A)(1); AND (2) FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS AND NYSE ARCA, INC. RULE 6.18. NYSE ARCA PROVIDED A NOTICE OF FINES FOR MINOR RULE PLAN VIOLATIONS AND THE FIRM CONSENTED TO THE IMPOSITION OF THE FINE OF $3,750. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2019-03-00110 12/28/2020 THE NEW YORK STOCK EXCHANGE LLC ("NYSE") THE NEW YORK STOCK EXCHANGE LLC ("NYSE") ALLEGED THAT DEUTSCHE BANK SECURITIES INC.'S ("DBSI") ERRONEOUS-ORDER CONTROLS WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, AND THAT DBSI'S SUPERVISORY SYSTEM, INCLUDING ITS WRITTEN SUPERVISORY PROCEDURES, WERE NOT REASONABLY DESIGNED TO MANAGE THE FINANCIAL RISKS IN CONNECTION WITH MARKET ACCESS. 12/28/20, DBSI ENTRD AWC. NYSE ALLGD FRM 3/18 & 3/19, DBSI'S CNTRLS WERENT REASNBLY DESIGND TO PRVNT ENTRY OF ERRNEOUS ORDRS & SPRVSRY SYSTM WASNT REASNBLY DESIGND TO MANAGE RISKS. W/OUT ADMIT OR DENY, DBSI AGRD TO A CENSURE & FINE $60000 PAID 1/11/21. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant 2017055691901 12/31/2020 FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS RECORD RETENTION OBLIGATIONS. 12/31/20, DBSI ENTRD AWC W/ FINRA. FINRA ALLEGD BTWN '98 & '17, DBSI FAILD TO EST. & MAINTAIN SPRVISRY SYSTM REASNBLY DESIGND TO ACHIEVE COMPL W/ RECRD RETNTION. W/OUT ADMTTNG OR DENYNG, DBSI AGRD TO A CENSURE, CERT. REQ'MNT, & FINE $2500000 PAID 1/13/21 DEUTSCHE BANK AG, a Control Affiliate of the Registrant DQA-21-0626 06/18/2021 CME GROUP THE CME GROUP ALLEGED THAT DEUTSCHE BANK AG'S ("DB AG") ELECTRONIC AUDIT TRAIL RELATING TO ELECTRONIC ORDER ROUTING FOR FRONT-END SYSTEMS FAILED TO MEET A CME GROUP REQUIREMENT TO MAINTAIN A COMPLETE ELECTRONIC AUDIT TRAIL FOR A MINIMUM OF FIVE YEARS. THE CME GROUP ACKNOWLEDGED THAT DB AG SUBSEQUENTLY APPLIED NEW MEASURES TO ITS RECORD KEEPING PROCESSES TO ENSURE COMPLIANCE WITH THE RELEVANT REQUIREMENT. 6/18/21, DB AG ENTERED A SUMMARY FINE NOTICE BY THE CME GROUP, ALLEGING THAT DB AG'S ELECTRONIC AUDIT TRAIL FAILED TO MEET A CME GROUP REQUIREMENT. DB AG HAS APPLIED NEW MEASURES TO ENSURE COMPLIANCE. DB AG AGREED TO A FINE OF USD $1,000. DEUTSCHE BANK AG (DBAG), a Control Affiliate of the Registrant CASE NO. 2021-1 06/25/2021 BLOOMBERG SEF LLC BLOOMBERG SEF LLC ("BSEF") ALLEGED THAT DEUTSCHE BANK AG ("DB AG") EXECUTED OFFSETTING AND CORRECTING TRADES FOR A JANUARY 21, 2021 TRADE AFTER THE PERMITTED TIMEFRAME OF THREE BUSINESS DAYS AND FAILED TO USE APPROPRIATE OFFSETTING TERMS AS REQUIRED UNDER BSEF RULES. 6/25/21,W/O ADMITTING OR DENYING FINDINGS, DBAG ENTERD A DECISION W/ BSEF ALLEGING THAT DBAG EXECUTED OFFSETTING & CORRECTING TRADES FOR A TRADE AFTER PERMITTED TIMEFRAME & DID NOT USE TERMS UNDER BSEF RULES. DBAG AGRD TO A FINE OF $7500, PAID ON 7/15/21. DEUTSCHE BANK AG (DBAG), a Control Affiliate of the Registrant CASE NO. 2020-012 08/31/2021 ICE FUTURES U.S., INC. ICE FUTURES U.S., INC. ("IFUS") ALLEGED THAT DEUTSCHE BANK AG ("DB AG") MAY HAVE VIOLATED IFUS RULE 4.02(C) ON FEBRUARY 28, 2020 BY EXECUTING A BLOCK TRADE BETWEEN TWO ACCOUNTS THAT SHARED THE SAME BENEFICIAL OWNER FOR THE PURPOSE OF MOVING A POSITION FROM ONE CLEARING MEMBER TO ANOTHER. 8/31/21, DB AG, W/OUT ADMITTING OR DENYING, ENTERED INTO A SETTLEMENT AGREEMENT W/ IFUS, ALLEGING THAT DB AG MAY HAVE VIOLATED IFUS RULE 4.02(C). PURSUANT TO THE SETTLEMENT AGREEMENT, DB AG AGREED TO A FINE OF $7,500, WHICH WAS TIMELY PAID ON 9/14/21. N N Y Deutsche Securities Australia Limited, a Control Affiliate of the Registrant Occurrence 1347474 01/24/2007 Australian Securities Exchange The Registrant has not been the subject of this matter: The Australian Securities Exchange ("ASX") determined that Deutsche Securities Australia Limited ("DSAL") contravened ASX Market Rule 20.8.3 as a result of executing five special crossings in derivative market A fine of a A$45,000 was imposed upon Deutsche Securities Australia Limited. Deutsche Bank AG (London), a Control Affiliate of the Registrant Occurrence 1340615 12/19/2006 Comision Nacional Del Mercado The Registrant has not been the subject of this matter: Initiation date: 02/03/2006. The Comision Nacional Del Mercado ("CNMV") alleged Deutsche Bank AG London Branch ("DB London") engaged in a breach of its obligation not to carry out market sounding or wall crossing activities until the close of the Madrid market and approval of a short prospectus for an equity placement (block trade) executed in shares of Spanish company Ebro Puleva on February 26, 2004. On December 19, 2006, DB London received notice that the CNMV received approval to sanction DB London in respect of an equity placement (block trade) executed in shares of Spanish company Ebro Puleva in February 2004. The CNMV alleged that, pursuant, to prospectus describing the placement, DB London imposed upon itself an obligation not to carry out any market sounding or wall crossing activities prior to the close of the Madrid market and approval of the short prospectus by the CNMV on the date of the transaction. The CNMV argued that DB London breached this obligation by approaching three investors to determine market interest prior to the market close. DB London was suspended from accelerated book built deals in Spanish securities for a period of three months from 19 December 2006 through 19 March 2007. A monetary fine of 1,000,000 Euros was ordered. Suspended from accelerated book built deals in Spanish securities for a period of three months from 19 December 2006 through 19 March 2007. A monetary fine of 1,000,000 Euros was ordered. Morgan Grenfell & Co Limited (MG & CO), a Control Affiliate of the Registrant FSA Unknown 03/18/2004 Financial Services Authority ("FSA") of London, U.K. The Registrant has not been the subject of this matter: The Financial Services Authority ("FSA") of London, U.K., found that MG & Co to have been in breach of FSA Principle 6 and Principle 8 wherein MG & Co failed to act in its customer's best interests and failed to manage conflicts of interests. The FSA found that MG & Co had commenced proprietary trading in certain of the constituent securities of a client's programme trade, prior to its award, based on limited information provided to enable MG & Co to quote for the business. The FSA found that the proprietary trading resulted in the client, a fund manager, paying more for the programme trade than they would otherwise have done. The FSA noted that MG & Co agreed compensation for the customer on the same day. The current status is: closed on 18 March 2004. Pursuant to section 206 of the Financial Services and Markets Act 2000, FSA imposed a fine of UK pounds 190,000 (US $350,000) which was paid on 1 April 2004. Pursuant to section 206 of the Financial Services and Markets Act 2000, FSA imposed a fine of UK pounds 190,000 (US $350,000) which was paid on 1 April 2004. Deutsche Bank AG (London Branch) (DBL), a Control Affiliate of the Registrant Docket/Case Number: FSA/PN/036/006 04/11/2006 The Financial Services Authority ("FSA") The Registrant has not been the subject of this matter: The Financial Services Authority ("FSA") fined DBL for breaches of FSA Principle 5 (duty to observe proper standards of market conduct) and breaches of Principle 2 (duty to act with due skill, care and diligence) regarding two separate equity capital market transactions conducted by DBL in March 2004. DBL internally identified and self reported to the FSA issues relating to both transactions. DBL appointed external advisors to undertake a detailed investigation into the transactions, the results of which were provided to the FSA in May 2004. The first transaction involved a book build in Scania AB, B shares. For the purposes of the settlement with FSA, DBL has admitted breaches of FSA Principle 5, in that DBL had purchased high volumes of Scania AB, B shares using external brokers, rather than trading in DBL's own name, thereby increasing and stabilizing the share price. For the purposes of the settlement, DBL has also admitted breaches of FSA Principle 2, in that (1) DBL allowed the purchase of shares by an employee without pre-notification (2) DBL issued three coverage statements that were incomplete or inaccurate with respect to the actual degree of coverage, and (3) DBL issued an internal statement on the day following the transaction that DBL would be reporting to the Stockholm Stock Exchange that it currently held a 9.6% stake in Scania AB; this information was not properly embargoed, as a number of DBL employees disclosed it to clients, prior to the information being made public. The second transaction involved the stabilization of Cytos Biotechnology AG shares. For the purposes of the settlement with FSA, DBL has admitted breaches of FSA Principle 2 because (1) DBL failed to ensure that the stabilization trader followed DBL's internal procedures on stabilization; and (2) DBL failed to ensure that the London staff escalated trading issues to Compliance in a timely manner. The current status is closed on 4/11/2006. For the purposes of the settlement, DBL agreed to a total financial penalty of GBP 6,363,643 for breaches of FSA Principle 5 in respect to one of the transactions, and FSA Principle 2 in respect of both transactions. This fine was paid to the FSA on 13 April 2006. DBL agreed to pay: (i) a fine of GBP 3,500,000, and a "loss avoidance" figure of GBP 2,363,643 with respect to the Scania transaction due to the DBL purchases and the inaccurate coverage statements (ii) a fine of GBP 500,000 with respect to the Cytos Biotechnology transaction for failure to follow internal procedures on stabilization, and failure to escalate issue to Compliance in a timely manner. For the purposes of the settlement, DBL agreed to a total financial penalty of GBP 6,363,643 for breaches of FSA Principle 5 in respect to one of the transactions, and FSA Principle 2 in respect of both transactions. This fine was paid to the FSA. Morgan Grenfell Asia & Partners Securities PTE Ltd., a Control Affiliate of the Registrant SES Unknown 05/30/1995 Disciplinary Committee of the Stock Exchange of Singapore Ltd. The Registrant has not been the subject of this matter: Initiation date: April 27, 1995. On April 27, 1995, the Disciplinary Committee of the Stock Exchange of Singapore Ltd.("SES") found that MGAPS ratio of Aggregate Indebtedness to Adjusted Net Capital had exceeded 500% for two days, on January 19 & 20, 1994, in violation of SES Rule 57(1). The current status is: closed on May 30, 1995. Pursuant to SES Rule 46.1(a), the Disciplinary Committee imposed a fine of 75,000 Singapore dollars on MGAPS. Closed on May 30, 1995. Pursuant to SES Rule 46.1(a), the Disciplinary Committee imposed a fine of 75,000 Singapore dollars on MGAPS. Deutsche Bank AG (London), a Control Affiliate of the Registrant Autorite Des Marches Financiers - Unknown 06/07/2007 Autorite Des Marches Financiers The Registrant has not been the subject of this matter: Initiation date: December 13, 2002. Autorite Des Marches Financiers ("AMF") alleged certain abuses arising out of a convertible offer by Vivendi which took place in November 2002. The allegations centered on whether hedge funds acted on information offered by DBAG London before the issuance of the bond was publicly announced. The AMF alleged that DBAG London, which handled a 1 billion Euro convertible bond issue for Vivendi in November 2002, did not fully respect the rules of good conduct which apply to market testing in passing on information about the issue to four hedge funds prior to the information becoming publicly known. The AMF found that the funds used this information to trade Vivendi shares. Without admitting or denying the allegations, DBAG London was sanctioned for technical and procedural reasons and there were no findings that DBAG London violated insider trading rules. Likewise, DBAG London was not sanctioned for passing information to the hedge funds. The AMF alleged that there were also material inaccuracies in the prospectus. However, this was viewed by the AMF as a formal breach, which on its own, would not warrant a high penalty. The AMF alleged that DBAG London failed to retain proper records of its "Market Sounding" communications and failed to retain relevant tape recordings. The AMF did not allege that the mistaken erasure of the tapes was intentional. Without admitting or denying the allegations, DBAG London was sanctioned for technical and procedural reasons and accepted a fine of E750,000.00. Deutsche Bank AG (London), a Control Affiliate of the Registrant Docket/Case Number: Autorite Des Marches Financiers - Unknown 11/23/2007 Autorite Des Marches Financiers ("AMF") The Registrant has not been the subject of this matter: Initiation date: 10/18/2006. The Autorite Des Marches Financiers alleged certain abuses arising out of the convertible bond offer for French telecommunications equipment maker Alcatel which took place in December 2002. The allegations centered on whether hedge funds acted on the basis of information communicated by DB London before the issuance of the bonds was publicly announced, during its market sounding activities. The AMF concluded that DB had no culpability in relation to alleged insider dealing activities, but alleged procedural, record keeping omissions by DB, in relation to the records it maintained of the market soundings. On December 22, 2006, the AMF notified DB London that it would be sanctioned for technical and procedural violations in connection with a convertible bond offering by Alcatel, DB lead managed the transaction. There was no case to answer for insider trading. DB London conducted market soundings with several hedge funds ahead of the offering in December 2002. DB London was able to produce documentation sufficient to attest that it was engaged in market sounding which is permitted under AMF Rules. However, since the times the telephone contacts with the hedge funds were made were not evidenced in the documentation and the names of certain third parties were missing from the firm's records, AMF found that DB London acted contrary to French Market soundings regulations. AMF imposed a monetary sanction of 300,000 Euros, which has been paid in full. AMF imposed a monetary sanction of 300,000 Euros, which has been paid in full. Deutsche Bank Securities Inc. (DBSI), a Control Affiliate of the Registrant N/A 11/18/2008 Bourse De Montreal The Registrant has not been the subject of this matter: Initiation date 1/25/2008. During the period from June 16, 2006 to May 8, 2007, Deutsche Bank Securities Inc. ("DBSI") was alleged to have contravened paragraph A) of Article 6366 of the Rules of Bourse De Montreal Inc. (The Bourse), by providing access to its designated personnel to the electronic trading system of the Bourse without having obtained the prior approval of the Bourse thereof, rendering DBSI subject to a disciplinary complaint and to the penalties listed in Article 4101 and following of the rules of the Bourse. Without admitting or denying the allegations, DBSI consented to the Bourse De Montreal decision, and to a fine of $53,759.60. This amount includes costs of the investigation of $3,759.60. The fine was paid on 12/8/08. Without admitting or denying the allegations, DBSI consented to the Bourse De Montreal decision, and to a fine of $53,759.60. Deutsche Securities Korea Co. (DSK), a Control Affiliate of the Registrant Index Arbitrage 03/25/2011 Korea Exchange (Market Oversight Commission of KRX) ("KRX") The Registrant has not been the subject of this matter: Initiation date: 2/25/11. Receiving and placing large quantity of quotations and orders linked to listed derivatives trades that undermined the Fair Market Trade System; and failure to comply with reporting requirements including the delay of reporting by 1 minute. 1. DSK paid the fine by due date of March 25, 2011 2. DSK sanctioned the relevant employees as required by KRX: (1) reprimanded relevant dealers (2) who placed relevant orders of the client (DB London)(March 30, 2011) (2) Place index ARB trader on six (6) month suspension from April 1, 2011 to September 30, 2011. The actual amount of the fine was 1 billion Korean won (KRW), the approximate conversion to U.S. dollars using the conversion date of 7/21/2011 is $947,000. Administrative fine of KRW 1 billion as KRX member required DSK to discipline relevant employees. Resolution detail: 1) Fine (as explained above) 2) KRX requirement to discipline relevant employees: (1) censure (reprimand) of dealers who placed the orders (2) 6 month suspension of duty of index ARB trader at DSK. DSK paid 1 billion in Korean won fine. DSK sanctioned the relevant employees: (1) reprimanded relevant dealers (2) who placed relevant orders of the client (DB London)(3/30/11) (2) Place index ARB trader on 6 month suspension from 4/1/11 to 9/30/11. Deutsche Securities Korea Co. (DSK), a Control Affiliate of the Registrant Index Arbitrage 04/01/2011 Korean Financial Services Commission The Registrant has not been the subject of this matter: Initiation date: 4/1/2011. Following the decline of the Korea Composite Stock Price Index 200 ("KOSPI 200") in the closing auction on November 11, 2010, by approximately 2.7%, the Korean Financial Supervisory Service ("FSS") commenced an investigation and expressed concerns that the fall in the KOSPI 200 was attributable to a sale by Deutsche Bank AG ("Deutsche Bank") of a basket of stocks, worth approximately "EUR 1.6 Billion", that was held as part of an index arbitrage position on the KOSPI 200. On February 23, 2011, the Korean Financial Services Commission, which oversees the work of the FSS, reviewed the FSS' findings and recommendations and resolved to take the following action: (I) to file a criminal complaint to the Korean Prosecutor's Office for alleged market manipulation against five employees of the Deutsche Bank Group and Deutsche Bank's subsidiary Deutsche Securities Korea Co. ("DSK") for vicarious liability; and (II) to impose a suspension of six months, commencing April 1, 2011, of DSK's business for proprietary trading of cash equities and listed derivatives and DMA (Direct Market Access) cash equities trading, and the requirement that DSK suspends the employment of one named employee for six months. There is an exemption to the business suspension to permit DSK to continue acting as liquidity provider for existing derivatives linked securities. The Korean Prosecutor's Office will now undertake its own investigation to determine whether to indict DSK and/or the relevant employees. Korean Financial Services Commission imposed a suspension of six months, commencing April 1, 2011, of DSK's business for proprietary trading of cash equities and listed derivatives and DMA (Direct Market Access) cash equities trading, and the requirement that DSK suspends the employment of one named employee for six months. There is an exemption to the business suspension to permit DSK to continue acting as liquidity provider for existing derivatives linked securities. Korean Financial Services Commission imposed a suspension of six months, commencing April 1, 2011, of DSK's business for proprietary trading of cash equities and listed derivatives and DMA (Direct Market Access) cash equities trading, and the requirement that DSK suspends the employment of one named employee for six months. There is an exemption to the business suspension to permit DSK to continue acting as liquidity provider for existing derivatives linked securities. Korean Fin. Serv. Comm. imposed a suspension of 6 mnths, commencing 4/1/11, of DSK's business for prop. trading of cash equities and listed deriv. and DMA cash eq. trading, and the requirement that DSK suspends the employment of one employee for 6 mnths. DB UK Bank Limited, a Control Affiliate of the Registrant FSA's Principles 3 & 6 and certain MCOB Rules 12/08/2010 The Financial Services Authority, United Kingdom (the "FSA") The Registrant has not been the subject of this matter: Initiation date: 2/22/2011. DB UK Bank Limited breached Principle 3 (Management and Control) and Principle 6 (Customers' Interests) of the FSA's Principles for Businesses and Rules 11.3.1 R, 12.4.1R, 13.3.1R, and 13.4.1R of the Mortgages and Home Finance: Conduct of Business Sourcebook ("MCOB") in the period between January 13, 2006 and December 1, 2008. A settlement agreement dated December 8, 2010 was agreed between DB UK Bank Limited and the FSA. The final notice dated December 15, 2010 was made public on February 22, 2011. The settlement agreement is in full and final settlement of the investigation initiated by the FSA's Memorandum of Appointment of Investigators dated August 7, 2009. Redress and remediation program financial penalty in the amount of 840,000 (pound sterling) was paid to the FSA in February 2011. In addition an ongoing customer contact exercise has lead to further customer redress although the amount cannot be quantified at this time as the customer contact exercise has not concluded. Financial penalty in the amount of 840,000 (pound sterling) was paid to the FSA in February 2011. In addition an ongoing customer contact exercise has lead to further customer redress although the amount cannot be quantified at this time. DWS Investment GmbH (DWS), a Control Affiliate of the Registrant WA 17-WP 3210-2011/0094,3120-2011/0128,3120-2012/0007,0008,0017 03/13/2012 Bundesanstalt Fuer Finanzdienstleistungsaufsicht ("BaFin") The Registrant has not been the subject of this matter: Initiation date: 2/14/2012. BaFin alleged that DWS Investment GmbH ("DWS") violated position monitoring rule 21 sections 1 and 2 of the Securities Trading Act on several occasions during the period of March 2011 through December 2011. BaFin (the "Regulator") further alleged that DWS failed to file correct information in their initial reports and failed to notify the Regulator and company issuers in a timely manner of position limits which exceeded or fell below the allowable threshold held in the companies, JAXX SE, Adler Modemarkte, Axel Springer AG and Prime Office REIT-AG. The Regulator fined DWS a total of 100,000 euros for these violations. DWS accepted the fine of 100,000 euros and has proactively implemented new controls including staff training and hiring of subject matter experts. Further, in the future, DWS will arrange for the use of an automated system which will prevent similar violations. The Regulator fined DWS a total of 100,000 euros. DWS accepted the fine and has proactively implemented new controls including staff training and new hiring. Further, DWS will arrange for an automated system which will prevent similar violations. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant IIROC Allegation 02/08/2013 Investment Industry Regulatory Organization of Canada ("IIROC") The Registrant has not been the subject of this matter: Date Initiated: 02/08/2013. The IIROC proceedings related to the collapse of the Canadian asset backed commercial paper ("ABCP") market in august 2007. IIROC alleged that DBSI breached an IIROC policy relating to the operation of the Canadian debt markets. Without admitting or denying the allegations, DBSI consented to the fine of $1,000,000. The fine was paid on 2/11/13. Without admitting or denying the allegations, DBSI consented to the fine of $1,000,000. The fine was paid on 2/11/13. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant FinMA Allegation 05/02/2012 Swiss Financial Market Supervisory Authority ("FinMA") The Registrant has not been the subject of this matter: Initiation date: 3/3/2011. FinMA alleged DBAG filed late disclosures on shareholdings in Adecco SA on March 26, March 30, and April 13, 2010, and late disclosure of shareholdings in Peach Property Group on November 25, 2010, in violation of Art. 20 of Stock Exchange Act. The fine of 50,000 Swiss francs was paid. The fine of 50,000 Swiss francs was paid. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant 1:16-CV-06544 SOUTHERN DISTRICT OF NEW YORK ("SDNY") 06/17/2020 U.S. COMMODITY FUTURES TRADING COMMISSION THE CFTC ALLEGED THAT, WITH RESPECT TO THE REPORTING OF SWAP DATA, DEUTSCHE BANK AG ("DBAG") FAILED TO PROPERLY REPORT AND CORRECT ERRORS IN REAL-TIME DATA, TO CORRECT ERRORS AND OMISSIONS IN PREVIOUSLY REPORTED DATA, PROVIDE DILIGENT SUPERVISION, AND MAINTAIN AN ADEQUATE BUSINESS CONTINUITY AND DISASTER RECOVERY PLAN. THE CFTC ALSO ALLEGED THAT DBAG VIOLATED A 2015 CFTC ORDER THAT RESOLVED A CFTC INVESTIGATION INTO A DIFFERENT TYPE OF SWAP REPORTING ERROR. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO A PERMANENT INJUNCTION REQUIRING IT TO COMPLY WITH THE 2015 CFTC ORDER. DBAG ALSO AGREED TO PAY A $9,000,000 CIVIL MONEY PENALTY. THE FINE WAS PAID ON JULY 1, 2020. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant N/A 01/12/2021 THE RESERVE BANK OF INDIA ("RBI") THE RESERVE BANK OF INDIA ("RBI") FOUND THAT DEUTSCHE BANK AG ("DB AG") FAILED TO OFFER UNIFORM RATES OF INTEREST PAID ON DEPOSITS OF SIMILAR AMOUNT AND TENURE ACCEPTED ON THE SAME DATES IN SEVEN INSTANCES FROM FINANCIAL YEARS 2017 TO 2019. IN ADDITION, THE RBI FOUND THAT DB AG COMMUNICATED INTEREST RATES OF BULK DEPOSITS BEFORE PUBLISHING THE INTEREST RATE SCHEDULE ON ITS WEBSITE, AND FAILED TO MAINTAIN THE BULK DEPOSIT INTEREST RATE CARD FOR CORPORATE CUSTOMERS IN ITS CORE BANKING SYSTEM PRIOR TO JULY 20,2020. 1/12/21, RBI ENTRD AN ORDER FINDING DBAG FAILD TO OFFER UNIFRM RATES OF INTEREST PAID ON DEPOSITS OF SIMILAR AMNT & TENURE ACCPTD ON THE SAME DATES IN 7 INSTANCES FROM FINANCIAL YEARS '17-'19. DBAG TIMELY PAID TWO CORE RUPEES (APPROX $276000) ON 1/19/21. DEUTSCHE BANK AG (TAIPEI BRANCH) (DBTP), a Control Affiliate of the Registrant TAI-YANG-WEI-CHI-TZU-1100006870 02/05/2021 CENTRAL BANK OF THE REPUBLIC OF CHINA (TAIWAN) THE CENTRAL BANK OF THE REPUBLIC OF CHINA (TAIWAN) ("CBC") FOUND THAT DEUTSCHE BANK AG, TAIPEI BRANCH("DBTP") FAILED TO REVIEW TRANSACTIONAL DOCUMENTS TO VERIFY THAT ITS CLIENTS' TWD/FOREIGN CURRENCY FORWARD TRADES WERE DRIVEN BY "FOREIGN EXCHANGE GENUINE NEED" FOR TAIWAN DOLLARS, RESULTING IN THE CLIENTS ENGAGING IN SPECULATIVE TRADING IN TWD/FOREIGN CURRENCY FORWARDS. IN ADDITION, CERTAIN OF THOSE TRANSACTIONS, WHEN MATCHED WITH SPOT FX TRANSACTIONS UPON MATURITY OF THE FORWARD TRANSACTIONS, WERE FOUND TO BE IN THE NATURE OF SYNTHETIC NDF TRANSACTIONS WITH COUNTERPARTIES OTHER THAN THOSE ALLOWED BY CBC REGULATIONS. 2/5/21, CBC REVOKED DBTP'S ABILITY TO ENGAGE IN CERTAIN TRADES & SUSPENDED DBTP FOR 2 YRS FROM FX DERIV TRANSACTIONS. DBTP CAN APPLY TO RESUME SAID ACTIVITIES BEFORE THE END OF THE 2-YR PERIOD UPON SHOWING "CONCRETE IMPROVEMENT." NO MONETARY SANCTION. DEUTSCHE BANK AG ( JOHANNESBURG BRANCH), a Control Affiliate of the Registrant REF.: 15/1/1_DBAG 02/26/2021 SOUTH AFRICAN RESERVE BANK THE SOUTH AFRICAN RESERVE BANK ("SARB") FOUND THAT DEUTSCHE BANK AG ("DB AG"), JOHANNESBURG BRANCH, IN CONNECTION WITH ITS ANTI-MONEY LAUNDERING ("AML") AND COUNTER-FINANCING OF TERRORISM ("CFT") COMPLIANCE PROGRAM, FAILED TO COMPLY WITH CERTAIN RESPONSIBILITIES AND REQUIREMENTS RELATING TO DB AG'S RISK MANAGEMENT AND COMPLIANCE PROGRAM, CUSTOMER DUE DILIGENCE, RECORDKEEPING, AND GOVERNANCE. 2/26/21, SARB ENTRD AN ORDR FINDING DB AG, JOHANNESBURG BRANCH FAILD TO COMPLY W/ ITS AML & CFT PRGRMS. SARB ISSUED CAUTIONS, A REPRIMAND, & FINE OF ZAR 38 MILLION (ZAR 28 MILLION PAID ON 3/23/21; ZAR 10 MILLION SUSPENDED FOR 3 YRS IF NO SIMILAR ISSUES). DEUTSCHE BANK AG (PRAGUE BRANCH), a Control Affiliate of the Registrant REF. NO. 2021 / 25856 / 570; FILE NO.: SP/2020/49/573 03/10/2021 CZECH NATIONAL BANK THE CZECH NATIONAL BANK ("CNB") FOUND THAT DEUTSCHE BANK AG ("DB AG"), PRAGUE BRANCH FAILED TO IMPLEMENT AND APPLY APPROPRIATE INTERNAL CONTROL PROCEDURES TO MITIGATE RISKS RELATING TO ANTI-MONEY LAUNDERING AND TERRORIST FINANCING BY FAILING TO VERIFY CERTAIN CLIENT DATA AGAINST SANCTION LISTS, ESTABLISHING UNREASONABLY LONG DEADLINES FOR CHECKING POTENTIALLY SUSPICIOUS TRANSACTION ALERTS, AND FAILING TO ENSURE THAT CONTROL PROCEDURES COULD BE ADEQUATELY RECONSTRUCTED. IN ADDITION, THE CNB FOUND THAT DBAG, PRAGUE BRANCH FAILED TO PERFORM CLIENT CHECKS TO THE EXTENT NECESSARY TO ASSESS SUCH RISKS BY SETTING INADEQUATE PARAMETERS FOR THE GENERATION OF SUSPICIOUS TRANSACTION ALERTS, AND IN AT LEAST ONE CASE, FAILING TO FLAG CROSS-BORDER TRANSACTIONS THAT DID MEET THE PARAMETERS. 3/10/21, CNB ENTRD AN ORDR FINDING: DB AG, PRAGUE BRANCH FAILED TO IMPLEMENT & APPLY APPROPRIATE INTERNAL CNTRLS TO MITIGATE RISKS RELATED TO AML & TERRORIST FINANCING. CNB IMPOSED A FINE OF 5 MILLION CZECH CROWNS (APPROX USD $225,000), TO BE TIMELY PAID. DEUTSCHE BANK AG, DB GROUP SERVICES (UK) LIMITED, & DEUTSCHE SECURITIES INC (TOGETHER, DB), a Control Affiliate of the Registrant AT.40346 04/28/2021 EUROPEAN COMMISSION THE EUROPEAN COMMISSION ("COMMISSION") FOUND THAT DEUTSCHE BANK AG, DB GROUP SERVICES (UK)LIMITED, AND DEUTSCHE SECURITIES INC. (TOGETHER, "DB") AND THREE OTHER BANKS TOOK PART IN ANTI COMPETITIVE CONDUCT RELATING TO THE SECONDARY TRADING MARKET WITHIN THE EUROPEAN ECONOMIC AREA OF SUPRA-SOVEREIGN, SOVEREIGN AND AGENCY ("SSA") BONDS DENOMINATED IN U.S.DOLLARS. IN PARTICULAR, THE COMMISSION FOUND THAT FROM 2010 TO 2014, CERTAIN DB TRADERS PARTICIPATED IN A CARTEL WITH TRADERS AT THE THREE OTHER BANKS BY COORDINATING ON PRICES OF SSA BONDS QUOTED TO CLIENTS AND THE MARKET IN GENERAL, IN VIOLATION OF EUROPEAN UNION RULES PROHIBITING ANTI COMPETITIVE BUSINESS PRACTICES. AS A RESULT OF ITS VOLUNTARY DISCLOSURE AND COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DB WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION. 4/28/21, THE COMMISSION FOUND DB & 3 OTHER BANKS TOOK PART IN ANTI COMPETITIVE CONDUCT. DUE TO A VOLUNTARY DISCLOSURE & PURSUANT TO THE COMMISSION'S '06 LENIENCY NOTICE, DB WAS GRANTED FULL IMMUNITY & AGREED TO CEASE & DESIST FROM RELEVANT INFRINGEMENTS. DEUTSCHE BANK AG (MANILA BRANCH), a Control Affiliate of the Registrant AMLC ADMIN. CASE NO. 18-024 05/18/2021 REPUBLIC OF THE PHILIPPINES ANTI-MONEY LAUNDERING COUNCIL THE PHILIPPINES ANTI-MONEY LAUNDERING COUNCIL ("AMLC") ALLEGED THAT DEUTSCHE BANK AG ("DBAG"), MANILA BRANCH FAILED TO REPORT ALL COVERED TRANSACTIONS TO THE AMLC WITHIN FIVE WORKING DAYS, AS REQUIRED UNDER THE PHILIPPINES ANTI-MONEY LAUNDERING ACT OF 2001, AS AMENDED. IN PARTICULAR, THE AMLC ALLEGED THAT 2,069 COVERED TRANSACTION REPORTS WERE FILED BEYOND THE FIVE-DAY PERIOD DURING THE FIRST SEMESTER OF 2017. THE AMLC FOUND THAT DB AG SHOWED "GOOD CAUSE" IN ADEQUATELY REMEDIATING AML SYSTEM ISSUES, INCLUDING THE COVERED TRANSACTION REPORTS AT ISSUE. ACCORDINGLY, THE AMLC AGREED TO WITHDRAW THE CASE UPON RECEIPT OF AN ASSESSMENT PAYMENT AND CONFIRMATION OF DB AG'S REMEDIAL MEASURES. 5/18/21, AMLC APPROVED A RESOLUTION ALLEGING DB AG'S MANILA BRANCH FAILED TO REPORT ALL COVERED TRANSACTIONS TO AMLC W/IN 5 WORKING DAYS. AMLC W/DREW THE CASE DUE TO DB AG'S REMEDIATION & TIMELY RECEIPT OF ASSESSMENT PAYMENT (1 MILLION PHILIPPINE PESOS). DEUTSCHE SECURITIES ASIA LIMITED (DSAL),a Control Affiliate of the Registrant 508/EN/6136 06/23/2021 SECURITIES AND FUTURES COMMISSION OF HONG KONG THE SECURITIES AND FUTURES COMMISSION OF HONG KONG (THE "HONG KONG SFC") FOUND THAT DEUTSCHE SECURITIES ASIA LIMITED ("DSAL") ISSUED INCORRECT PERIODIC STATEMENTS TO ITS PRIME BROKERAGE CLIENTS WHEN THEY WERE HOLDING POSITIONS REGARDING THEIR ENTITLEMENTS TO BONUS SHARES OF LISTED COMPANIES THAT HAD NOT YET BECOME TRADABLE. THE STATEMENTS DISPLAYED THESE BONUS SHARES AS SETTLED AND TRADABLE AS OF THE EX-ENTITLEMENT DATES WHEN IN FACT THEY HAD NOT BECOME UNCONDITIONALLY TRADABLE FOR LONG SALE UNTIL THE SETTLEMENT DATES. 6/23/21, HONG KONG SFC FOUND THAT DSAL ISSUED INCORRECT PERIODIC STATEMENTS TO ITS PRIME BROKERAGE CLIENTS & IMPOSED A FINE OF 2,450,000 HONG KONG DOLLARS, WHICH IS APPROX. USD $315,000, PAID TIMELY ON 6/24/21. DEUTSCHE BANK AG (DB AG), a Control Affiliate of the Registrant 442.2-358 06/04/2021 SWISS FEDERAL DEPARTMENT OF FINANCE (EFD) THE SWISS FEDERAL DEPARTMENT OF FINANCE (THE "SWISS EFD") FOUND THAT DEUTSCHE BANK AG ("DB AG") FAILED TO MAKE TIMELY REPORTS TO THE SIX SWISS EXCHANGE ("SIX") WHEN DB AG'S HOLDINGS OF TWO SIX-LISTED COMPANIES HAD FALLEN BELOW THE THRESHOLD REQUIRING NOTIFICATION TO THE SIX WITHIN FOUR TRADING DAYS. IN ADDITION, THE SWISS EFD FOUND THAT DB AG FAILED TO CORRECT INACCURATE DISCLOSURE REPORTS RELATING TO ITS HOLDINGS IN ANOTHER SIX-LISTED COMPANY. 6/4/21, THE SWISS EFD FOUND THAT DB AG FAILED TO MAKE TIMELY REPORTS TO THE SIX SWISS EXCHANGE & FAILED TO CORRECT INACCURATE DISCLOSURE REPORTS. THE SWISS EFD IMPOSED A FINE OF 30 THOUSAND SWISS FRANCS (APPROX. USD $33,000), WHICH WILL BE TIMELY PAID. Deutsche Bank AG (Portugal), a Control Affiliate of the Registrant Proceeding NO. 44/20/CO 10/19/2021 Bank of Portugal THE BANK OF PORTUGAL ALLEGED THAT THREE EMPLOYEES AT A BRANCH AGENCY OF DEUTSCHE BANK AG-PORTUGAL BRANCH ("DB AG PORTUGAL") HAD NOT COMPLETED REQUIRED TRAINING FOR MANAGING CASH (EURO BANKNOTES AND COINS). THE BANK OF PORTUGAL FURTHER ALLEGED THAT DB AG PORTUGAL THUS MADE EURO NOTES AVAILABLE TO THE PUBLIC THAT WERE NOT VERIFIED BY PROFESSIONALS PROPERLY QUALIFIED TO VERIFY AUTHENTICITY AND QUALITY. 10/19/21, DBAG PORTUGAL ACCEPTED A DECISION FROM THE BANK OF PORTUGAL (BOP) ALLEGING THAT 3 EMPLOYEES OF DBAG DIDN'T COMPLETE TRAINING & THAT DBAG THUS MADE UNVERIFIED EURO NOTES AVAILABLE TO THE PUBLIC. DBAG AGREED TO A FINE OF 6000 EUROS, PAID 10/19/21. Deutsche Bank SPA (DB SPA), a Control Affiliate of the Registrant DECRETO N. 401822/A 01/26/2021 Ministry of Economy and Finance of Italy THE MINISTRY OF ECONOMY AND FINANCE OF ITALY ("MEF") ALLEGED THAT DEUTSCHE BANK SPA ("DB SPA") FAILED TO REPORT TO THE FINANCIAL INTELLIGENCE UNIT OF ITALY ("UIF") CERTAIN SUSPICIOUS TRANSACTIONS RELATING TO A CLIENT ACCOUNT OF DB SPA'S UDINE BRANCH. IN PARTICULAR, THE MEF ALLEGED THAT 62 CASH WITHDRAWALS FROM JUNE 2014 THROUGH SEPTEMBER 2014 TOTALING EUR 66,890 WERE NOT REPORTED TO UIF AS REQUIRED UNDER THEN-CURRENT ITALIAN LEGISLATIVE DECREE NO. 231/2007. 1/26/21, THE MEF ISSUED AN ORDER FOR DB SPA'S ALLEGED FAILURE TO REPORT TO UIF CERTAIN SUSPICIOUS TRANSACTIONS RELATED TO A CLIENT ACCOUNT. A FINE WAS IMPOSED AS JOINTLY AND SEVERALLY LIABLE WITH A FORMER EMPLOYEE OF EUR 6709 (PAID TIMELY ON 5/11/21). Deutsche Bank SPA (DB SPA), a Control Affiliate of the Registrant DECRETO N. 401823/A 01/26/2021 MINISTRY OF ECONOMY AND FINANCE OF ITALY THE MINISTRY OF ECONOMY AND FINANCE OF ITALY ("MEF") ALLEGED THAT DEUTSCHE BANK SPA ("DB SPA") FAILED TO REPORT TO THE FINANCIAL INTELLIGENCE UNIT OF ITALY ("UIF") CERTAIN SUSPICIOUS TRANSACTIONS RELATING TO A CLIENT ACCOUNT OF DB SPA'S UDINE BRANCH. IN PARTICULAR, THE MEF ALLEGED THAT 86 CASH WITHDRAWALS FROM MARCH 2013 THROUGH JUNE 2014 TOTALING EUR 78,569 WERE NOT REPORTED TO UIF, AS REQUIRED UNDER THEN-CURRENT ITALIAN LEGISLATIVE DECREE NO. 231/2007. 1/26/21, THE MEF ISSUED AN ORDER FOR DB SPA'S ALLEGED FAILURE TO REPORT TO UIF CERTAIN SUSPICIOUS TRANSACTIONS RELATED TO A CLIENT ACCOUNT. A FINE WAS IMPOSED AS JOINTLY AND SEVERALLY LIABLE WITH A FORMER EMPLOYEE OF EUR 7876.9, WHICH WAS PAID TIMELY. DEUTSCHE BANK AG (DBAG), a Control Affiliate of the Registrant WA 17 - WP 3139-2021/0001. 12/28/2021 GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY (BAFIN) THE GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") ALLEGED THAT FROM APRIL 24, 2019 TO APRIL 23, 2020, DEUTSCHE BANK AG ("DB AG"), AS A SUPERVISED CONTRIBUTOR TO THE EURIBOR BENCHMARK RATE, DID NOT HAVE SUFFICIENTLY EFFECTIVE CONTROLS FOR THE SUBMISSION OF DATA PURSUANT TO ARTICLE 16(2)(A) OF THE REGULATION (EU) 2016/1011 (EU BENCHMARK REGULATION). 12/28/21, BAFIN ALLEGED THAT FROM 4/24/19-4/23/20, DBAG DID NOT HAVE SUFFICIENTLY EFFECTIVE CONTROLS FOR THE SUBMISSION OF DATA PURSUANT TO EU BENCHMARK REGULATION. DBAG AGREED TO PAY A FINE OF 8663200 EUROS (APPROX USD 9800000), TIMELY PAID ON 1/14/22. DEUTSCHE BANK SAE (DB SAE), a Control Affiliate of the Registrant RA.0123.21 01/26/2022 SPANISH NATIONAL SECURITIES MARKET COMMISSION ("CNMV") THE SPANISH NATIONAL SECURITIES MARKET COMMISSION ("CNMV") FOUND THAT, FROM 2013 TO 2017, DEUTSCHE BANK SAE ("DB SAE") FAILED TO APPROPRIATELY MANAGE THE CONFLICT OF INTEREST ASSOCIATED WITH REPURCHASING STRUCTURED BONDS ISSUED BY DEUTSCHE BANK GROUP FROM DB SAE'S CUSTOMERS, RESULTING IN A VIOLATION OF ARTICLES 193.2(C) AND 195 OF THE SPANISH SECURITIES MARKET ACT (THE "TRLMV"). 4/21/21, DB SAE RECEIVED A NOTICE FROM THE CNMV FINDING A FAILURE TO MANAGE THE CONFLICT OF INTEREST ASSOCIATED WITH REPURCHASING STRUCTURED BONDS. DB SAE APPEALED & RECEIVED A DECISION ON 2/3/22 WITH A FINE OF 3,000,000 EUROS TO BE PAID TIMELY. FIDUCIARIA S. ANDREA S.R.L. (FIDUCIARIA), A SUBSIDIARY OF DEUTSCHE BANK S.P.A., a control affiliate of the registrant. DECREE. NO. 401804/A 07/14/2020 ITALIAN MINISTRY OF THE ECONOMY ("MEF") THE ITALIAN MINISTRY OF THE ECONOMY ("MEF") FOUND THAT FIDUCIARIA S. ANDREA S.R.L. ("FIDUCIARIA"), A SUBSIDIARY OF DEUTSCHE BANK S.P.A., FAILED TO REPORT SUSPICIOUS TRANSACTIONS PURSUANT TO ARTICLE 41 OF THE ITALIAN LEGISLATIVE DECREE N. 231/2007, AND THAT VALENTINO AMENDOLA-PROVENZANO ("PROVENZANO"), THE FORMER CHIEF EXECUTIVE OFFICER OF FIDCUIARIA, WAS RESPONSIBLE FOR SUCH FAILURES. 7/14/20, THE MEF FOUND THAT FIDUCIARIA FAILED TO REPORT SUSPICIOUS TRANSACTIONS & ASSESSED A FINE OF 300,000 EUROS (APPROX USD 333,000), PAID TIMELY. 9/4/20, FIDUCIARIA FILED AN APPEAL; IT WAS REJECTED ON 1/25/22. IT WAS APPEALED ON 2/24/22. DEUTSCHE BANK AG (DBAG), a control affiliate of the registrant 13938/DBK/02/2022 02/28/2022 STATE BANK OF PAKISTAN ("SBP") THE STATE BANK OF PAKISTAN ("SBP") FOUND THAT IN 2011, DEUTSCHE BANK AG ("DB AG"), THROUGH ITS KARACHI BRANCH, FAILED TO REPORT DISBURSEMENT OF, AND INTEREST CHARGED ON, CERTAIN LOANS TO THE SBP IN MONTHLY FOREIGN EXCHANGE RETURNS AS REQUIRED BY FOREIGN EXCHANGE CIRCULAR LETTER NO. 5. 2/28/22, THE SBP, FOUND THAT IN 2011, DB AG, THROUGH ITS KARACHI BRANCH, FAILED TO REPORT DISBURSEMENT OF, AND INTEREST CHARGED ON, CERTAIN LOANS TO THE SBP. THE SBP IMPOSED AN ADMINISTRATIVE PENALTY OF PKR 1,030,000 (APPROX USD 5,682, TO BE TIMELY PAID). Y Control Affiliates of the Registrant Varies by jurisdiction 05/12/1999 Varies by jurisdiction In the ordinary course of business, certain Control Affiliates of the Registrant are named as defendants in lawsuits or other proceedings in which allegations of violations of federal and/or state securities laws and regulations or in which allegations of violation of self-regulatory organization or commodity exchange rules are made. Allegations are dismissed or are settled and separately reported. Deutsche Bank Securities, Inc.'s (DBSI) , a Control Affiliate of the Registrant Bourse Action 01/25/2019 BOURSE DE MONTREAL INC. ("BOURSE") DURING THE PERIOD FROM OCTOBER 15, 2014 TO OCTOBER 15, 2017, DBSI WAS ALLEGED TO HAVE CONTRAVENED ARTICLES 6366 A, "ACCESS TO ELECTRONIC TRADING," AND 7403, "APPLICATION FOR APPROVAL," OF THE RULES OF THE BOURSE (THE "RULES"), BY PROVIDING ACCESS TO FIFTEEN (15) OF ITS EMPLOYEES TO THE ELECTRONIC TRADING SYSTEM WITHOUT HAVING OBTAINED THE PRIOR APPROVAL OF THE BOURSE THEREOF. DBSI WAS ALSO ALLEGED TO HAVE CONTRAVENED ARTICLE 3011 OF THE RULES BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES REQUIRING THAT ONLY DESIGNATED PERSONNEL APPROVED BY THE BOURSE RECEIVE ACCESS TO TRADE ELECTRONICALLY ON THE EXCHANGE. THESE ALLEGED VIOLATIONS HAVE RENDERED DBSI SUBJECT TO A DISCIPLINARY COMPLAINT. Pending -- DBSI IS REVIEWING THE ALLEGATIONS AND IS IN DISCUSSIONS WITH THE BOURSE REGARDING THE COMPLAINT. Deutsche Bank AG (DBAG), a Control Affiliate of the Registrant CR. NO. 20-584 (RPK) (RML). 01/07/2021 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK ON JANUARY 7, 2021, A DEFERRED PROSECUTION AGREEMENT (DPA) WAS FILED BETWEEN DBAG AND DOJ WHICH DEFERRED PROSECUTION OF THE CHARGES AGAINST DBAG FOR THREE YEARS. DBAG ENTERED A PLEA OF NOT GUILTY TO THE CHARGES. SUBJECT TO DBAG'S FULL COMPLIANCE WITH THE TERMS OF THE DPA, THREE YEARS FROM JANUARY 7, 2021, THE DPA SHALL EXPIRE, AND WITHIN SIX MONTHS AFTER THE DPA'S EXPIRATION, DOJ WILL SEEK DISMISSAL WITH PREJUDICE OF THE CRIMINAL INFORMATION FILED AGAINST DBAG, AND AGREE NOT TO FILE CHARGES IN THE FUTURE AGAINST THE COMPANY BASED ON THE CONDUCT DESCRIBED IN THE DPA AND THE STATEMENT OF FACTS. REGARDING THE FOREIGN CORRUPT PRACTICES ACT (FCPA) CHARGE, DBAG AGREED TO A CRIMINAL MONETARY PENALTY OF $79,561,206, WHICH WAS TIMELY PAID ON JANUARY 15, 2021, AND, AMONG OTHER THINGS, A CORPORATE COMPLIANCE REPORTING REQUIREMENT FOR THREE YEARS. REGARDING THE COMMODITIES-TRADING CHARGE, DBAG AGREED TO A CRIMINAL MONETARY PENALTY OF $5,625,000, WHICH WAS FULLY CREDITED AGAINST A CIVIL MONETARY PENALTY PAID IN CONNECTION WITH A JANUARY 29, 2018 CFTC SETTLEMENT, AS WELL AS A DISGORGEMENT OF $681,480 AND THE ESTABLISHMENT OF A VICTIM COMPENSATION PAYMENT OF $1,223,738. THE DISGORGEMENT WAS TIMELY PAID ON JANUARY 15, 2021. THE VICTIM COMPENSATION PAYMENT WAS TIMELY DEPOSITED IN AN ESCROW ACCOUNT ON JANUARY 20, 2021; ANY AMOUNT REMAINING UNCLAIMED FROM THE ESCROW ACCOUNT 12 MONTHS AFTER THE EXECUTION OF THE DPA WILL REVERT TO THE UNITED STATES AS AN ADDITIONAL CRIMINAL MONETARY PENALTY. REGARDING THE FCPA CHARGE, THE DOJ ALLEGED THAT DBAG IMPROPERLY USED THIRD PARTY INTERMEDIARIES TO OBTAIN AND RETAIN GLOBAL BUSINESS FROM ABOUT 2009 THROUGH AT LEAST 2016. THE DOJ ALLEGED THAT DBAG MAINTAINED FALSE BOOKS, RECORDS, AND ACCOUNTS THAT DID NOT ACCURATELY AND FAIRLY REFLECT THE TRANSACTIONS AND DISPOSITIONS OF DBAG'S ASSETS. THE DOJ ALSO ALLEGED THAT DBAG FAILED TO IMPLEMENT AND MAINTAIN SUFFICIENT INTERNAL ACCOUNTING CONTROLS TO HELP DETECT AND STOP SUCH TRANSACTIONS. REGARDING THE COMMODITIES-TRADING CHARGE, THE DOJ ALLEGED THAT, FROM ABOUT 2008 THROUGH AT LEAST 2013, FORMER DBAG EMPLOYEES CONSPIRED AND SCHEMED TO DECEIVE OTHER PRECIOUS METALS MARKET PARTICIPANTS BY CREATING AND COMMUNICATING MATERIALLY FALSE AND MISLEADING INFORMATION REGARDING SUPPLY OR DEMAND, IN ORDER TO INDUCE SUCH OTHER MARKET PARTICIPANTS INTO TRADING PRECIOUS METALS FUTURES CONTRACTS. DBAG ENTERED A PLEA OF NOT GUILTY TO THE CHARGES AND PROSECUTION OF THE CHARGES WAS DEFERRED PURSUANT TO THE DPA. 1/7/21, DPA BETWN DBAG & DOJ FOR 3 YEAR DEFRRL W/PLEA OF NOT GUILTY. W/IN 6 MO. OF DPA'S EXPIRTION, SBJCT TO DBAG'S COMPL. W/DPA, DOJ WILL SEEK DSMISSL W/PREJ. OF CRIM. INFO FILED AGAINST DBAG, & AGREE NOT TO FILE FUTURE CHRGS AGAINST DBAG BASED ON DPA. N N Kenneth Spruill 904-645-4858 Analyst 06/17/2022