X0405 TA-1/A 0000913181 XXXXXXXX 084-05475 true LIVE SEC MUFG Investor Services (US) LLC MUFG Investor Services (US), LLC 269647 805 King Farm Blvd. Suite 600 Rockville MD 20850 N 240-614-4800 N N N N Other MUFG Fund Services (USA) LLC 07/01/2017 Sole Owner 100% ownership of MUFG Investor Services Limited Liability Company Y Kelly Dudley Interim Chief Compliance Officer of MUFG Investor Services (US) LLC James Fisher Chief Executive Officer of MUFG Investor Services (US) LLC George Hall Chief Risk Officer of MUFG Investor Services (US) LLC MUFG Americas Holding Corporation 100% ownership stake in MUFG Fund Services (USA) LLC MUFG Bank, Ltd. 95.11% ownership stake in MUFG Americas Holding Corporation Mitsubishi UFJ Trust & Banking Corporation Provides strategic planning for the Global MUFG Investor Services Division, including MUFG Investor Services (US) LLC Mitsubishi UFJ Financial Group, Inc. 100% ownership stake in MUFG Bank, Ltd. and Mitsubishi UFJ Trust & Banking Corporation; 4.89% ownership stake in MUFG Americas Holding Corporation Gregory Cohen Head of Transfer Agent, MUFG Investor Services (US) LLC Young Kim Chief Financial Officer, MUFG Investor Services (US) LLC Hiroshi Nakazawa Chairman of the Board, MUFG Investor Services (US) LLC Michael Scalzi President, MUFG Investor Services (US) LLC Jun Kawakubo Board Manager of MUFG Investor Services (US) LLC N N N N N N Y MUFG Securities Americas Inc. f.k.a. Mitsubishi UFJ Securities (USA) Inc. Docket/Case Number 3-17094 02/02/2016 US Securities & Exchange Commission SEC alleged that Mitsubishi UFJ Securities (USA) Inc. ("MUS(USA)") violated Section 17(A)(2) of the Securities Act in connection with its underwriting of certain municipal securities offerings. Without admitting or denying the findings, MUS(USA) consented to (1) cease and desist from further violations; (2) pay a civil monetary penalty of $20,000. MUFG Securities Americas Inc. Docket/Case Number 3-18914 12/10/2018 US Securities & Exchange Commission MUFG Securities Americas Inc. ("MUSA") allegedly submitted incomplete or deficient information in response to SEC electronic blue sheet (EBS) requests. The Order requires that MUSA: 1. Cease and desist from committing or causing any violations and any future violations of Section 17(a)(1) of the Exchange Act; 2. Receive a censure; and 3. Pay a civil monetary fine of $1.4 million USD. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. Docket/Case Number 17-21 08/07/2017 Commodity Futures Trading Commission (CFTC) Bank of Tokyo-Mitsubishi UFJ, Ltd. ("BTMU") self-disclosed to the CFTC that one of its traders engaged in the disruptive trading practice of "spoofing" various futures products on designated contract markets in the US, in violation of Commodity Exchange Act Section 4C(A)(5). BTMU consented to cease and desist from violating the Commodity Exchange Act's prohibition against spoofing, and was fined $600,000 USD. N N N Y MUFG Securities Americas Inc. f.k.a. Mitsubishi UFJ Securities (USA) Inc. Docket/Case Number 13-011 03/21/2013 Ohio Division of Securities Ohio Division of Securities alleged that Mitsubishi UFJ Securities (USA) Inc. ("MUS(USA)") had been operating as a securities dealer in the state of Ohio without an Ohio dealer's license. MUS(USA) consented to cease and desist from further violations, and also agreed to disgorge the commissions and markups for all transactions made during the period. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. Consent Order under New York Banking Law 39 and 44 11/18/2014 New York State Department of Financial Services (NYDFS) NYDFS alleged that Bank of Tokyo-Mitsubishi UFJ, Ltd. ("BTMU") misled NYDFS in reaching settlement terms of a prior 2013 consent order. BTMU also allegedly failed to maintain accurate books at its NY Branch. BTMU consented to pay a civil monetary penalty of $315 million USD. The NYDFS investigation led to the resignation from BTMU of the NY Branch Compliance Manager. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. Consent Order under New York Banking Law 44 06/19/2013 New York State Department of Financial Services (NYDFS) NYDFS alleged that Bank of Tokyo-Mitsubishi UFJ, Ltd. ("BTMU") committed violations of Economic Sanctions laws. The alleged violations were involving Iran, Sudan, Myanmar, and certain entities on OFAC's Specially Designated Nationals list. BTMU consented to pay a civil monetary penalty of $250 million USD. BTMU also consented to hire an independent consultant, who will review its Compliance Program. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. Enforcement Action for 12/12/2012 12/12/2012 Office of Foreign Asset Control (OFAC) OFAC alleged that Bank of Tokyo-Mitsubishi UFJ, Ltd. ("BTMU") violated the Burmese Sanctions Regulations, 31 CFR part 537; the Iranian Transactions Regulations, 31 CFR part 560; and Executive Order 13382. BTMU consented to pay a civil monetary penalty of $8,571,634 USD. BTMU also consented to undertake significant remediation to improve its OFAC compliance policies and procedures. MUFG Bank, Ltd. Consent Order #2019-004 02/22/2019 Office of the Comptroller of the Currency (OCC) The OCC found that the New York, Chicago, and Los Angeles branches of MUFG Bank, Ltd. had deficiencies in their Bank Secrecy Act compliance programs. The order requires the MUFG Bank, Ltd. branches to take comprehensive corrective actions to improve their Bank Secrecy Act and anti-money laundering compliance programs. Mitsubishi UFJ Financial Group, Inc. & MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. Docket/Case Number 06-028 WA/RB (Fed/NYS Banking Dept) 12/18/2006 Federal Reserve Board, NY State Banking Dept., & Federal Deposit Insurance Corp. The joint release order determined that Bank of Tokyo-Mitsubishi UFJ, Ltd. failed to implement adequate Bank Secrecy Act and anti-money laundering compliance programs. Mitsubishi UFJ Financial Group, Inc entered into a written agreement with the Federal Reserve Banks of SF and NY, and the NY State Banking Dept. Bank of Tokyo-Mitsubishi UFJ, Ltd. consented to an order to cease and desist issued by the FDIC. MUFG Bank, Ltd. Docket/Case # 1:17-CV-08691 06/24/2019 New York State Department of Financial Services (NYDFS) Following MUFG Bank, Ltd.'s (MUFGBK) conversion of its state banking licenses issued by NYDFS to federal banking licenses issued by the Office of the Comptroller of the Currency (OCC) in November 2017, NYDFS issued an order asserting continuing regulatory authority over MUFGBK. MUFGBK thus filed a lawsuit seeking a declaration that NYDFS did not have continuing authority over it. In response, NYDFS filed counterclaims against MUFGBK under banking and related laws. Under the terms of the settlement, MUFGBK and NYDFS released all of their claims against each other, NYDFS agreed not to challenge the validity of the licenses issued by the OCC, and MUFGBK agreed to make a $33m settlement payment. N N N N N Y MUFG Securities Americas Inc. f.k.a. Mitsubishi UFJ Securities (USA) Inc. Docket/Case Number 2007008490201 03/04/2009 Financial Industry Regulatory Authority, Inc. Mitsubishi UFJ Securities (USA) Inc. ("MUS(USA)") allegedly permitted an employee to perform certain functions requiring principal registration while he was not registered with FINRA in that capacity. Without admitting or denying the findings, MUS(USA) consented to the described sanctions and to entry of findings; therefore, the firm is censured and fined $15,000 USD. MUFG Securities Americas Inc. f.k.a. Mitsubishi UFJ Securities (USA) Inc. Docket/Case Number 2006005325701 07/11/2007 Financial Industry Regulatory Authority, Inc. f.k.a. NASD The National Association of Securities Dealers ("NASD") alleged that Mitsubishi UFJ Securities (USA) Inc. ("MUS(USA)") failed to report to the trade reporting and compliance engine (TRACE) the lower of yield to call or yield to maturity for TRACE-eligible securities. MUS(USA) failed to enforce its written supervisory procedures. Without admitting or denying the findings, MUS(USA) consented to the described sanctions and to the entry of findings; therefore, the firm was censured and fined $10,000 USD. N N Y MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. JFSA Administrative Order 11/13/2009 Japan Financial Services Agency (JFSA) The JFSA noted that there were deficiencies in the compliance management programs at certain Bank of Tokyo-Mitsubishi, Ltd. ("BTMU") branches. An administrative order was issued for business improvement and partial business suspension in respect to compliance management issues at certain BTMU branches. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. JFSA Administrative Order 09/11/2009 Japan Financial Services Agency (JFSA) The JFSA noted that there were deficiencies in Bank of Tokyo-Mitsubishi, Ltd. ("BTMU") overseas business and domestic investment operations. An administrative order was issued for business improvement with respect to BTMU overseas business and domestic investment operations. MUFG Bank, Ltd. f.k.a. Bank of Tokyo-Mitsubishi UFJ, Ltd. & MUFG Securities EMEA PLC PRA Enforcement Order 02/09/2017 Prudential Regulation Authority (PRA) The PRA alleged that the Bank of Tokyo-Mitsubishi, Ltd. ("BTMU") and MUFG Securities EMEA PLC failed to be open and cooperative with the PRA in relation to an enforcement action into BTMU by the New York Department of Financial Services. The PRA imposed a fine of 17.85M GBP on BTMU and a fine of 8.925M GBP on MUFG Securities EMEA PLC. MUFG Bank, Ltd. Docket/Case Number AT.40135 05/16/2019 European Commission The European Commission, in a settlement decision, fined MUFG Bank, Ltd. (along with a number of other banks) for alleged violations of European Union anti-trust rules. The total fine issued by the European Commission was 1.07b euros. The portion required to be paid by MUFG Bank, Ltd. was 69.75m euros (approx. $77.865 USD). MUFG Bank, Ltd. Settlement with Competition Commission 06/06/2019 Competition Commission (Switzerland) Switzerland's Competition Commission concluded amicable settlements with several banks, including MUFG Bank, Ltd., and fined the banks for alleged participation in anti-competitive arrangements in foreign exchange spot trading. The total fine issued by Switzerland's Competition Commission against the banks was approx. CHF 90m, and the portion required to be paid by MUFG Bank, Ltd. was approx. CHF 1.5m. N N N Kelly Dudley (203)-848-7081 Interim Chief Compliance Officer 01/09/2024