X0405 TA-1/A 0001028988 XXXXXXXX 084-05681 true LIVE SEC PRUDENTIAL MUTUAL FUND SERVICES LLC /TA PRUDENTIAL MUTUAL FUND SERVICES LLC /TA 410019 655 Broad Street Prudential Tower - 6th Floor Newark NJ 07102 N 973-367-2396 Y TCS Letterkenny Business & Tech Park Letterkenny Co Donnegal L2 F92 W8CY Y Y National Financial Services, LLC 084-05888 499 Washington Blvd. 5th FL Jersey City NJ 07310 Alight Solutions LLC (formerly Hewitt Associates LLC) 084-01996 4 Overlook Point Lincolnshire IL 60069 The Vanguard Group, Inc. 084-00772 100 Vanguard Blvd. Malvern PA 19355 BNY Mellon Investment Servicing (U.S.) Inc. 084-01761 118 Flanders Road Westborough MA 01581 Valic Retirement Services Co. 084-06057 2929 Allen Parkway L4-01 Houston TX 77109 Edward D Jones & Co LP 084-01496 12555 Manchester Rd St. Louis MO 63131 Fidelity Investments Institutional Operations Co Inc. 084-01839 245 Summer Street Boston MA 02210 Nationwide Fund Management LLC (formerly Nationwide Financial Services Inc) 084-00825 10 West Nationwide Blvd 5-02-210T Columbus OH 43215 Goldman Sachs & Co LLC 084-01100 71 S Wacker Drive Ste 500 Chicago IL 60606 Wells Fargo Bank NA 085-10133 600 South 4th Street 7th Floor Minneapolis MN 55415-1526 SS&C GIDS, Inc (formerly DST Systems Inc) 084-00448 1055 Broadway 7th FL Kansas City MO 64105 N Not Applicable N N N N N N Y PGIM Investments LLC; AST Investments Services, Inc. In the Matter of AST Investment Services, Inc. and PGIM Investments LLC 09/16/2019 U.S. Securities and Exchange Commission, Washington, D.C. On September 16, 2019, it was announced that PGIM Investments LLC and AST Investment Services, Inc. entered into an agreement with the SEC relating to certain securities lending and foreign tax reclaim practices (the "Order"). PGIM Investments and AST Investment Services, Inc. self-reported the practices to the SEC, revised its procedures, and made restitution payments to affected funds. PGIM Investments has enhanced its securities lending and foreign tax reclaim policies and procedures to address the findings described in the Order. Pursuant to the Order, PGIM Investments agreed to a censure and to pay the SEC disgorgement of fees of $27.6 million and a civil penalty of $5 million N/A In the Matter of Pruco Securities, LLC 12/23/2020 Securities and Exchange Commission On December 23, 2020, Pruco Securities, LLC ("Pruco") entered into a settlement with the Securities and Exchange Commission ("SEC") resulting in the SEC issuing an administrative order (the "Order"). Pruco consented to the entry of the Order, which found that Pruco violated Sections 206(2) and 206(4), and Rule 206(4)-7 thereunder, of the Advisers Act in connection with Pruco's wrap fee programs, in which clients pay an all-inclusive fee for asset management and trade execution. The Order found that, beginning in January 2014, Pruco at various times breached its fiduciary duty to its clients by: (a) failing to conduct stated monitoring of client accounts to determine whether the wrap fee programs continued to be suitable for clients; (b) charging certain fees on some clients contrary to its disclosures; (c) recommending that clients purchase and hold certain mutual funds and mutual fund share classes that paid Pruco fees pursuant to Rule 12b-1 of under the Investment Company Act of 1940; (d) failing to disclose that it received revenue sharing payments on client investments pursuant to an agreement with its clearing firm, which also allowed Pruco to avoid paying certain transaction fees for its clients' purchases of mutual funds; (e) recommending bank sweep vehicles for which its clearing firm paid revenue sharing; and (f) violating its duty to seek best execution for certain transactions by selecting or recommending mutual fund and money market fund share classes when share classes of the same funds were available to the clients that presented a more favorable value or better performance. Pruco Securities LLC settled an SEC cease-and-desist administrative proceeding ordering Pruco to pay disgorgement of $12,690,585, prejudgment interest of $3,061,786, and a civil penalty in the amount of $2,500,000. Y PGIM Investments LLC; AST Investment Services, Inc. In the Matter of AST Investment Services, Inc. and PGIM Investments LLC 09/16/2019 U.S. Securities and Exchange Commission, Washington, D.C. On September 16, 2019, it was announced that PGIM Investments LLC and AST Investment Services, Inc. entered into an agreement with the SEC relating to certain securities lending and foreign tax reclaim practices (the "Order"). PGIM Investments and AST Investment Services, Inc. self-reported the practices to the SEC, revised its procedures, and made restitution payments to affected funds. PGIM Investments has enhanced its securities lending and foreign tax reclaim policies and procedures to address the findings described in the Order. Pursuant to the Order, PGIM Investments agreed to a censure and to pay the SEC disgorgement of fees of $27.6 million and a civil penalty of $5 million N/A In the Matter of Pruco Securities, LLC 12/23/2020 Securities and Exchange Commission On December 23, 2020, Pruco Securities, LLC ("Pruco") entered into a settlement with the Securities and Exchange Commission ("SEC") resulting in the SEC issuing an administrative order (the "Order"). Pruco consented to the entry of the Order, which found that Pruco violated Sections 206(2) and 206(4), and Rule 206(4)-7 thereunder, of the Advisers Act in connection with Pruco's wrap fee programs, in which clients pay an all-inclusive fee for asset management and trade execution. The Order found that, beginning in January 2014, Pruco at various times breached its fiduciary duty to its clients by: (a) failing to conduct stated monitoring of client accounts to determine whether the wrap fee programs continued to be suitable for clients; (b) charging certain fees on some clients contrary to its disclosures; (c) recommending that clients purchase and hold certain mutual funds and mutual fund share classes that paid Pruco fees pursuant to Rule 12b-1 of under the Investment Company Act of 1940; (d) failing to disclose that it received revenue sharing payments on client investments pursuant to an agreement with its clearing firm, which also allowed Pruco to avoid paying certain transaction fees for its clients' purchases of mutual funds; (e) recommending bank sweep vehicles for which its clearing firm paid Pruco revenue sharing; and (f) violating its duty to seek best execution for certain transactions by selecting or recommending mutual fund and money market fund share classes when share classes of the same funds were available to the clients that presented a more favorable value or better performance. Pruco Securities LLC settled an SEC cease-and-desist administrative proceeding ordering Pruco to pay disgorgement of $12,690,585, prejudgment interest of $3,061,786, and a civil penalty in the amount of $2,500,000. N N N N N N N N N Y Prudential Investment Management Services, LLC (PIMS) Self-Reported Rule Violation 01/14/2020 Financial Industry Regulatory Authority, Inc. (FINRA) Prudential Investment Management Services LLC, a control affiliate of Prudential Mutual Fund Services LLC, identified and self-reported certain advertising content rule issues to FINRA. Prudential Investment Management Services LLC resolved the matter with FINRAs enforcement staff on January 14, 2020 with a Letter of Acceptance, Waiver and Consent. FINRA censured PIMS and PIMS agreed to pay a penalty of $1 million. N N N N N N /s/ Andrew French 973-367-2396 Vice President and Assistant Secretary 03/10/2025