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Medient Studios, Inc., FONU2, Inc., Manu Kumaran, Joel A. Quadrant 4 System Corp., Nandu Thondavadi, and Dhru Desai Case Number: 17-cv-04883 (United States District Court for the Northern District of Illinois) Date Filed: June 29, 2017 Date of Qualifying Judgment/Order: June 25, 2018 In the Matter of Constant Contact, Inc. Administrative Proceeding File No.: 3-18531 Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 5, 2018 SEC v. Khalfani Case Number: 15-cv-00980 (United States District Court for the Central District of California) Date Filed: June 19, 2015 Date of Qualifying Judgment/Order: March 22, 2018 SEC v. Lotto Net Operating Corp., David Gray, Joseph Vitale a/k/a Donovan Kelly Case Number: 17-cv-21033 (United States District Court for the Southern District of Florida) Date Filed: March 20, 2017 Date of Qualifying Judgment/Order: February 26, 2018 SEC v. P., Jay Peak GP Services Lodge, Inc., Jay Peak Hotel Suites Stateside L. Gallo III Case Number: 12-cv-61731 (United States District Court for the Southern District of Florida) Date Filed: September 5, 2012 Date of Qualifying Judgment/Order: February 15, 2018 SEC v. X Wok Construction LLC, US Investment LLC d/b/a US Investment FL LLC, Top Sun Energy LLC, Ocean Blvd. X Property Management LLC, US1 Real Estate Developments, LLC, and Investor Asset Protection, LLC Case Number: 15-cv-62323 (United States District Court for the Southern District of Florida) Date Filed: November 3, 2015 Date of Qualifying Judgment/Order: January 22, 2018 SEC v. P.; Select Asset Management, LLC; Select Capital Management, LLC; Select Asset Fund I, LLC; and Select Asset Prime Index Fund, LLC Case Number: 11-cv-02830 (United States District Court for the Southern District of Texas) Date Filed: August 1, 2011 Date of Qualifying Judgment/Order: January 8, 2018 In the Matter of Industrial and Commercial Bank of China Financial Services LLC Administrative Proceeding File No.: 3-18341 Date Filed: January 18, 2018 Date of Qualifying Judgment/Order: January 18, 2018 SEC v. Kaplan, Esq., Synchronized Organizational Solutions, LLC, Synchronized Organizational Solutions International, Ltd., and Manna International Enterprises, Inc. Just Info LLC, David Weddle, and Scott Allensworth Case Number: 17-cv-07426 (United States District Court for the Central District of California) Date Filed: October 11, 2017 Date of Qualifying Judgment/Order: October 25, 2017 In the Matter of Augustine Capital Management, LLC (f/k/a Augustine Capital Management, Inc.), John T. Duszynski, CPA Administrative Proceeding File No.: 3-17740 Date Filed: October 26, 2017 Date of Qualifying Judgment/Order: October 26, 2017 SEC v. Case Number: 11-cv-05316 (United States District Court for the Central District of California) Date Filed: June 24, 2011 Date of Qualifying Judgment/Order: September 13, 2017 SEC v. Case Number: 14-cv-01155 (United States District Court for the Northern District of Ohio) Date Filed: May 29, 2014 Date of Qualifying Judgment/Order: September 26, 2017 SEC v. Case Number: 17-cv-11817 (United States District Court for the District of Massachusetts) Date Filed: September 22, 2017 Date of Qualifying Judgment/Order: September 25, 2017 SEC v. Ravichandran Administrative Proceeding File No.: 3-18653 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 In the Matter of Waruna Tivanka Ellawala Administrative Proceeding File No.: 3-18654 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 SEC v. and Mark De Stefano Case Number: 18-cv-05980 (United States District Court for the Southern District of New York) Date Filed: July 2, 2018 Date of Qualifying Judgment/Order: July 9, 2018 SEC v. Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings LLC, Advance Entertainment, LLC, and Advance Entertainment II, LLC Case Number: 17-cv-00632 (United States District Court for the Southern District of New York) Date Filed: January 27, 2017 Date of Qualifying Judgment/Order: July 13, 2018 SEC v. Pacific West Capital Group, Inc.; Andrew B Calhoun IV; PWCG Trust; Brenda Christine Barry; Bak West, Inc.; Andrew B Calhoun Jr.; Eric Christopher Cannon; Century Point, LLC; Michael Wayne Dotta; and Caleb Austin Moody (dba Sky Stone) Case Number: 15-cv-02563 (United States District Court for Central District of California) Date Filed: April 7, 2015 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Gordon Case Number: 18-cv-01587 (United States District Court for the Northern District of Texas) Date Filed: June 19, 2018 Date of Qualifying Judgment/Order: June 28, 2018 SEC v. Case Number: 17-cv-01968 (United States District Court for the Central District of California) Date Filed: September 27, 2017 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Hogan Case Number: 15-cv-00053 (United States District Court for the District of North Dakota) Date Filed: May 5, 2015 Date of Qualifying Judgment/Order: April 25, 2018 SEC v. Steven Ventre, Dedicated Sound and Audio, Inc., Eric Lovy f/k/a Eric Beltran, and Choice Equity Case Number: 18-cv-00323 (United States District Court for the Central District of California) Date Filed: February 26, 2018 Date of Qualifying Judgment/Order: March 2, 2018 SEC v. P., Jay Peak GP Services Golf, Inc., Jay Peak Lodge and Townhouses L. EB-5 Investments LLC, Oakland Office Holdings LLC, B. International Stock Transfer, Inc., and Cecil Franklin Speight Case Number: 14-cv-04435 (United States District Court for the Eastern District of New York) Date Filed: July 23, 2014 Date of Qualifying Judgment/Order: October 6, 2017 SEC v. Caledonian Bank, LTD., Caledonian Securities LTD., Clear Water Securities, Inc., Legacy Global Markets S. We post Notices of Covered Action for each SEC action where a final judgment or order, by itself or together with other prior judgments or orders in the same action issued after July 21, 2010, results in monetary sanctions exceeding

Medient Studios, Inc., FONU2, Inc., Manu Kumaran, Joel A. Quadrant 4 System Corp., Nandu Thondavadi, and Dhru Desai Case Number: 17-cv-04883 (United States District Court for the Northern District of Illinois) Date Filed: June 29, 2017 Date of Qualifying Judgment/Order: June 25, 2018 In the Matter of Constant Contact, Inc. Administrative Proceeding File No.: 3-18531 Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 5, 2018 SEC v. Khalfani Case Number: 15-cv-00980 (United States District Court for the Central District of California) Date Filed: June 19, 2015 Date of Qualifying Judgment/Order: March 22, 2018 SEC v. Lotto Net Operating Corp., David Gray, Joseph Vitale a/k/a Donovan Kelly Case Number: 17-cv-21033 (United States District Court for the Southern District of Florida) Date Filed: March 20, 2017 Date of Qualifying Judgment/Order: February 26, 2018 SEC v. P., Jay Peak GP Services Lodge, Inc., Jay Peak Hotel Suites Stateside L. Gallo III Case Number: 12-cv-61731 (United States District Court for the Southern District of Florida) Date Filed: September 5, 2012 Date of Qualifying Judgment/Order: February 15, 2018 SEC v. X Wok Construction LLC, US Investment LLC d/b/a US Investment FL LLC, Top Sun Energy LLC, Ocean Blvd. X Property Management LLC, US1 Real Estate Developments, LLC, and Investor Asset Protection, LLC Case Number: 15-cv-62323 (United States District Court for the Southern District of Florida) Date Filed: November 3, 2015 Date of Qualifying Judgment/Order: January 22, 2018 SEC v. P.; Select Asset Management, LLC; Select Capital Management, LLC; Select Asset Fund I, LLC; and Select Asset Prime Index Fund, LLC Case Number: 11-cv-02830 (United States District Court for the Southern District of Texas) Date Filed: August 1, 2011 Date of Qualifying Judgment/Order: January 8, 2018 In the Matter of Industrial and Commercial Bank of China Financial Services LLC Administrative Proceeding File No.: 3-18341 Date Filed: January 18, 2018 Date of Qualifying Judgment/Order: January 18, 2018 SEC v. Kaplan, Esq., Synchronized Organizational Solutions, LLC, Synchronized Organizational Solutions International, Ltd., and Manna International Enterprises, Inc. Just Info LLC, David Weddle, and Scott Allensworth Case Number: 17-cv-07426 (United States District Court for the Central District of California) Date Filed: October 11, 2017 Date of Qualifying Judgment/Order: October 25, 2017 In the Matter of Augustine Capital Management, LLC (f/k/a Augustine Capital Management, Inc.), John T. Duszynski, CPA Administrative Proceeding File No.: 3-17740 Date Filed: October 26, 2017 Date of Qualifying Judgment/Order: October 26, 2017 SEC v. Case Number: 11-cv-05316 (United States District Court for the Central District of California) Date Filed: June 24, 2011 Date of Qualifying Judgment/Order: September 13, 2017 SEC v. Case Number: 14-cv-01155 (United States District Court for the Northern District of Ohio) Date Filed: May 29, 2014 Date of Qualifying Judgment/Order: September 26, 2017 SEC v. Case Number: 17-cv-11817 (United States District Court for the District of Massachusetts) Date Filed: September 22, 2017 Date of Qualifying Judgment/Order: September 25, 2017 SEC v. Ravichandran Administrative Proceeding File No.: 3-18653 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 In the Matter of Waruna Tivanka Ellawala Administrative Proceeding File No.: 3-18654 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 SEC v. and Mark De Stefano Case Number: 18-cv-05980 (United States District Court for the Southern District of New York) Date Filed: July 2, 2018 Date of Qualifying Judgment/Order: July 9, 2018 SEC v. Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings LLC, Advance Entertainment, LLC, and Advance Entertainment II, LLC Case Number: 17-cv-00632 (United States District Court for the Southern District of New York) Date Filed: January 27, 2017 Date of Qualifying Judgment/Order: July 13, 2018 SEC v. Pacific West Capital Group, Inc.; Andrew B Calhoun IV; PWCG Trust; Brenda Christine Barry; Bak West, Inc.; Andrew B Calhoun Jr.; Eric Christopher Cannon; Century Point, LLC; Michael Wayne Dotta; and Caleb Austin Moody (dba Sky Stone) Case Number: 15-cv-02563 (United States District Court for Central District of California) Date Filed: April 7, 2015 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Gordon Case Number: 18-cv-01587 (United States District Court for the Northern District of Texas) Date Filed: June 19, 2018 Date of Qualifying Judgment/Order: June 28, 2018 SEC v. Case Number: 17-cv-01968 (United States District Court for the Central District of California) Date Filed: September 27, 2017 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Hogan Case Number: 15-cv-00053 (United States District Court for the District of North Dakota) Date Filed: May 5, 2015 Date of Qualifying Judgment/Order: April 25, 2018 SEC v. Steven Ventre, Dedicated Sound and Audio, Inc., Eric Lovy f/k/a Eric Beltran, and Choice Equity Case Number: 18-cv-00323 (United States District Court for the Central District of California) Date Filed: February 26, 2018 Date of Qualifying Judgment/Order: March 2, 2018 SEC v. P., Jay Peak GP Services Golf, Inc., Jay Peak Lodge and Townhouses L. EB-5 Investments LLC, Oakland Office Holdings LLC, B. International Stock Transfer, Inc., and Cecil Franklin Speight Case Number: 14-cv-04435 (United States District Court for the Eastern District of New York) Date Filed: July 23, 2014 Date of Qualifying Judgment/Order: October 6, 2017 SEC v. Caledonian Bank, LTD., Caledonian Securities LTD., Clear Water Securities, Inc., Legacy Global Markets S. We post Notices of Covered Action for each SEC action where a final judgment or order, by itself or together with other prior judgments or orders in the same action issued after July 21, 2010, results in monetary sanctions exceeding $1 million. Ronald Van Den Heuvel, and Green Box NA Detroit, LLC Case Number: 17-cv-01261 (United States District Court for the Eastern District of Wisconsin) Date Filed: September 19, 2017 Date of Qualifying Judgment/Order: July 18, 2019 SEC v. The inclusion of a Notice means only that an order was entered with monetary sanctions exceeding $1 million. Poppe Case Number: 19-cv-02534 (United States District Court for the Southern District of Texas) Date Filed: July 15, 2019 Date of Qualifying Judgment/Order: July 16, 2019 In the Matter of Robert L. Dwayne Edwards, Todd Barker, Senior Solutions of Social Circle, LLC, Oxton Place of Douglas, LLC d/b/a Oxton Real Estate of Douglass, LLC, Rome Alf, LLC, Savannah ALF, LLC, Gainesville ALF, LLC, Waterford Place ALF, LLC, Montgomery ALF, LLC, Columbus ALF, LLC, and Opelika ALF, LLC Case Number: 17-cv-00393 (United States District Court for the District of New Jersey) Date Filed: January 20, 2017 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. By posting a Notice for a particular case, we are not making any determinations either that (i) a whistleblower tip, complaint or referral led to the SEC opening an investigation or filing an action with respect to the case or (ii) an award to a whistleblower will be paid in connection with the case. Capital Group, LTD., Abraham “Avi” Mirman Case Number: 17-cv-05821 (United States District Court for the Southern District of New York) Date Filed: August 1, 2017 Date of Qualifying Judgment/Order: July 1, 2019 SEC v. Amit Kanodia and Iftikar Ahmed Case Number: 15-cv-13042 (United States District Court for the District of Massachusetts) Date Filed: April 2, 2015 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. Iannelli and Essex Capital Corporation Case Number: 18-cv-05008 (United States District Court for the Central District of California) Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 6, 2019 SEC v. Meenavalli, Amro Izzelden Altahwi a/k/a Andy Altahawi, Suresh Tammineedi, and Dorababu Penumarthi Case Number: 18-cv-02977 (United States District Court for the Southern District of New York) Date Filed: April 4, 2018 Date of Qualifying Judgment/Order: June 7, 2019 SEC v. and CM Capital Management, LLC Case Number: 18-cv-00442 (United States District Court for the Eastern District of Virginia) Date Filed: June 27, 2018 Date of Qualifying Judgment/Order: June 13, 2019 SEC v.

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Medient Studios, Inc., FONU2, Inc., Manu Kumaran, Joel A. Quadrant 4 System Corp., Nandu Thondavadi, and Dhru Desai Case Number: 17-cv-04883 (United States District Court for the Northern District of Illinois) Date Filed: June 29, 2017 Date of Qualifying Judgment/Order: June 25, 2018 In the Matter of Constant Contact, Inc. Administrative Proceeding File No.: 3-18531 Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 5, 2018 SEC v. Khalfani Case Number: 15-cv-00980 (United States District Court for the Central District of California) Date Filed: June 19, 2015 Date of Qualifying Judgment/Order: March 22, 2018 SEC v. Lotto Net Operating Corp., David Gray, Joseph Vitale a/k/a Donovan Kelly Case Number: 17-cv-21033 (United States District Court for the Southern District of Florida) Date Filed: March 20, 2017 Date of Qualifying Judgment/Order: February 26, 2018 SEC v. P., Jay Peak GP Services Lodge, Inc., Jay Peak Hotel Suites Stateside L. Gallo III Case Number: 12-cv-61731 (United States District Court for the Southern District of Florida) Date Filed: September 5, 2012 Date of Qualifying Judgment/Order: February 15, 2018 SEC v. X Wok Construction LLC, US Investment LLC d/b/a US Investment FL LLC, Top Sun Energy LLC, Ocean Blvd. X Property Management LLC, US1 Real Estate Developments, LLC, and Investor Asset Protection, LLC Case Number: 15-cv-62323 (United States District Court for the Southern District of Florida) Date Filed: November 3, 2015 Date of Qualifying Judgment/Order: January 22, 2018 SEC v. P.; Select Asset Management, LLC; Select Capital Management, LLC; Select Asset Fund I, LLC; and Select Asset Prime Index Fund, LLC Case Number: 11-cv-02830 (United States District Court for the Southern District of Texas) Date Filed: August 1, 2011 Date of Qualifying Judgment/Order: January 8, 2018 In the Matter of Industrial and Commercial Bank of China Financial Services LLC Administrative Proceeding File No.: 3-18341 Date Filed: January 18, 2018 Date of Qualifying Judgment/Order: January 18, 2018 SEC v. Kaplan, Esq., Synchronized Organizational Solutions, LLC, Synchronized Organizational Solutions International, Ltd., and Manna International Enterprises, Inc. Just Info LLC, David Weddle, and Scott Allensworth Case Number: 17-cv-07426 (United States District Court for the Central District of California) Date Filed: October 11, 2017 Date of Qualifying Judgment/Order: October 25, 2017 In the Matter of Augustine Capital Management, LLC (f/k/a Augustine Capital Management, Inc.), John T. Duszynski, CPA Administrative Proceeding File No.: 3-17740 Date Filed: October 26, 2017 Date of Qualifying Judgment/Order: October 26, 2017 SEC v. Case Number: 11-cv-05316 (United States District Court for the Central District of California) Date Filed: June 24, 2011 Date of Qualifying Judgment/Order: September 13, 2017 SEC v. Case Number: 14-cv-01155 (United States District Court for the Northern District of Ohio) Date Filed: May 29, 2014 Date of Qualifying Judgment/Order: September 26, 2017 SEC v. Case Number: 17-cv-11817 (United States District Court for the District of Massachusetts) Date Filed: September 22, 2017 Date of Qualifying Judgment/Order: September 25, 2017 SEC v.

million. Ronald Van Den Heuvel, and Green Box NA Detroit, LLC Case Number: 17-cv-01261 (United States District Court for the Eastern District of Wisconsin) Date Filed: September 19, 2017 Date of Qualifying Judgment/Order: July 18, 2019 SEC v. The inclusion of a Notice means only that an order was entered with monetary sanctions exceeding

Medient Studios, Inc., FONU2, Inc., Manu Kumaran, Joel A. Quadrant 4 System Corp., Nandu Thondavadi, and Dhru Desai Case Number: 17-cv-04883 (United States District Court for the Northern District of Illinois) Date Filed: June 29, 2017 Date of Qualifying Judgment/Order: June 25, 2018 In the Matter of Constant Contact, Inc. Administrative Proceeding File No.: 3-18531 Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 5, 2018 SEC v. Khalfani Case Number: 15-cv-00980 (United States District Court for the Central District of California) Date Filed: June 19, 2015 Date of Qualifying Judgment/Order: March 22, 2018 SEC v. Lotto Net Operating Corp., David Gray, Joseph Vitale a/k/a Donovan Kelly Case Number: 17-cv-21033 (United States District Court for the Southern District of Florida) Date Filed: March 20, 2017 Date of Qualifying Judgment/Order: February 26, 2018 SEC v. P., Jay Peak GP Services Lodge, Inc., Jay Peak Hotel Suites Stateside L. Gallo III Case Number: 12-cv-61731 (United States District Court for the Southern District of Florida) Date Filed: September 5, 2012 Date of Qualifying Judgment/Order: February 15, 2018 SEC v. X Wok Construction LLC, US Investment LLC d/b/a US Investment FL LLC, Top Sun Energy LLC, Ocean Blvd. X Property Management LLC, US1 Real Estate Developments, LLC, and Investor Asset Protection, LLC Case Number: 15-cv-62323 (United States District Court for the Southern District of Florida) Date Filed: November 3, 2015 Date of Qualifying Judgment/Order: January 22, 2018 SEC v. P.; Select Asset Management, LLC; Select Capital Management, LLC; Select Asset Fund I, LLC; and Select Asset Prime Index Fund, LLC Case Number: 11-cv-02830 (United States District Court for the Southern District of Texas) Date Filed: August 1, 2011 Date of Qualifying Judgment/Order: January 8, 2018 In the Matter of Industrial and Commercial Bank of China Financial Services LLC Administrative Proceeding File No.: 3-18341 Date Filed: January 18, 2018 Date of Qualifying Judgment/Order: January 18, 2018 SEC v. Kaplan, Esq., Synchronized Organizational Solutions, LLC, Synchronized Organizational Solutions International, Ltd., and Manna International Enterprises, Inc. Just Info LLC, David Weddle, and Scott Allensworth Case Number: 17-cv-07426 (United States District Court for the Central District of California) Date Filed: October 11, 2017 Date of Qualifying Judgment/Order: October 25, 2017 In the Matter of Augustine Capital Management, LLC (f/k/a Augustine Capital Management, Inc.), John T. Duszynski, CPA Administrative Proceeding File No.: 3-17740 Date Filed: October 26, 2017 Date of Qualifying Judgment/Order: October 26, 2017 SEC v. Case Number: 11-cv-05316 (United States District Court for the Central District of California) Date Filed: June 24, 2011 Date of Qualifying Judgment/Order: September 13, 2017 SEC v. Case Number: 14-cv-01155 (United States District Court for the Northern District of Ohio) Date Filed: May 29, 2014 Date of Qualifying Judgment/Order: September 26, 2017 SEC v. Case Number: 17-cv-11817 (United States District Court for the District of Massachusetts) Date Filed: September 22, 2017 Date of Qualifying Judgment/Order: September 25, 2017 SEC v. Ravichandran Administrative Proceeding File No.: 3-18653 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 In the Matter of Waruna Tivanka Ellawala Administrative Proceeding File No.: 3-18654 Date Filed: August 21, 2018 Date of Qualifying Judgment/Order: August 21, 2018 SEC v. and Mark De Stefano Case Number: 18-cv-05980 (United States District Court for the Southern District of New York) Date Filed: July 2, 2018 Date of Qualifying Judgment/Order: July 9, 2018 SEC v. Joseph Meli, Matthew Harriton, 875 Holdings, LLC, 127 Holdings LLC, Advance Entertainment, LLC, and Advance Entertainment II, LLC Case Number: 17-cv-00632 (United States District Court for the Southern District of New York) Date Filed: January 27, 2017 Date of Qualifying Judgment/Order: July 13, 2018 SEC v. Pacific West Capital Group, Inc.; Andrew B Calhoun IV; PWCG Trust; Brenda Christine Barry; Bak West, Inc.; Andrew B Calhoun Jr.; Eric Christopher Cannon; Century Point, LLC; Michael Wayne Dotta; and Caleb Austin Moody (dba Sky Stone) Case Number: 15-cv-02563 (United States District Court for Central District of California) Date Filed: April 7, 2015 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Gordon Case Number: 18-cv-01587 (United States District Court for the Northern District of Texas) Date Filed: June 19, 2018 Date of Qualifying Judgment/Order: June 28, 2018 SEC v. Case Number: 17-cv-01968 (United States District Court for the Central District of California) Date Filed: September 27, 2017 Date of Qualifying Judgment/Order: June 18, 2018 SEC v. Hogan Case Number: 15-cv-00053 (United States District Court for the District of North Dakota) Date Filed: May 5, 2015 Date of Qualifying Judgment/Order: April 25, 2018 SEC v. Steven Ventre, Dedicated Sound and Audio, Inc., Eric Lovy f/k/a Eric Beltran, and Choice Equity Case Number: 18-cv-00323 (United States District Court for the Central District of California) Date Filed: February 26, 2018 Date of Qualifying Judgment/Order: March 2, 2018 SEC v. P., Jay Peak GP Services Golf, Inc., Jay Peak Lodge and Townhouses L. EB-5 Investments LLC, Oakland Office Holdings LLC, B. International Stock Transfer, Inc., and Cecil Franklin Speight Case Number: 14-cv-04435 (United States District Court for the Eastern District of New York) Date Filed: July 23, 2014 Date of Qualifying Judgment/Order: October 6, 2017 SEC v. Caledonian Bank, LTD., Caledonian Securities LTD., Clear Water Securities, Inc., Legacy Global Markets S. We post Notices of Covered Action for each SEC action where a final judgment or order, by itself or together with other prior judgments or orders in the same action issued after July 21, 2010, results in monetary sanctions exceeding $1 million. Ronald Van Den Heuvel, and Green Box NA Detroit, LLC Case Number: 17-cv-01261 (United States District Court for the Eastern District of Wisconsin) Date Filed: September 19, 2017 Date of Qualifying Judgment/Order: July 18, 2019 SEC v. The inclusion of a Notice means only that an order was entered with monetary sanctions exceeding $1 million. Poppe Case Number: 19-cv-02534 (United States District Court for the Southern District of Texas) Date Filed: July 15, 2019 Date of Qualifying Judgment/Order: July 16, 2019 In the Matter of Robert L. Dwayne Edwards, Todd Barker, Senior Solutions of Social Circle, LLC, Oxton Place of Douglas, LLC d/b/a Oxton Real Estate of Douglass, LLC, Rome Alf, LLC, Savannah ALF, LLC, Gainesville ALF, LLC, Waterford Place ALF, LLC, Montgomery ALF, LLC, Columbus ALF, LLC, and Opelika ALF, LLC Case Number: 17-cv-00393 (United States District Court for the District of New Jersey) Date Filed: January 20, 2017 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. By posting a Notice for a particular case, we are not making any determinations either that (i) a whistleblower tip, complaint or referral led to the SEC opening an investigation or filing an action with respect to the case or (ii) an award to a whistleblower will be paid in connection with the case. Capital Group, LTD., Abraham “Avi” Mirman Case Number: 17-cv-05821 (United States District Court for the Southern District of New York) Date Filed: August 1, 2017 Date of Qualifying Judgment/Order: July 1, 2019 SEC v. Amit Kanodia and Iftikar Ahmed Case Number: 15-cv-13042 (United States District Court for the District of Massachusetts) Date Filed: April 2, 2015 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. Iannelli and Essex Capital Corporation Case Number: 18-cv-05008 (United States District Court for the Central District of California) Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 6, 2019 SEC v. Meenavalli, Amro Izzelden Altahwi a/k/a Andy Altahawi, Suresh Tammineedi, and Dorababu Penumarthi Case Number: 18-cv-02977 (United States District Court for the Southern District of New York) Date Filed: April 4, 2018 Date of Qualifying Judgment/Order: June 7, 2019 SEC v. and CM Capital Management, LLC Case Number: 18-cv-00442 (United States District Court for the Eastern District of Virginia) Date Filed: June 27, 2018 Date of Qualifying Judgment/Order: June 13, 2019 SEC v.

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Medient Studios, Inc., FONU2, Inc., Manu Kumaran, Joel A. Quadrant 4 System Corp., Nandu Thondavadi, and Dhru Desai Case Number: 17-cv-04883 (United States District Court for the Northern District of Illinois) Date Filed: June 29, 2017 Date of Qualifying Judgment/Order: June 25, 2018 In the Matter of Constant Contact, Inc. Administrative Proceeding File No.: 3-18531 Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 5, 2018 SEC v. Khalfani Case Number: 15-cv-00980 (United States District Court for the Central District of California) Date Filed: June 19, 2015 Date of Qualifying Judgment/Order: March 22, 2018 SEC v. Lotto Net Operating Corp., David Gray, Joseph Vitale a/k/a Donovan Kelly Case Number: 17-cv-21033 (United States District Court for the Southern District of Florida) Date Filed: March 20, 2017 Date of Qualifying Judgment/Order: February 26, 2018 SEC v. P., Jay Peak GP Services Lodge, Inc., Jay Peak Hotel Suites Stateside L. Gallo III Case Number: 12-cv-61731 (United States District Court for the Southern District of Florida) Date Filed: September 5, 2012 Date of Qualifying Judgment/Order: February 15, 2018 SEC v. X Wok Construction LLC, US Investment LLC d/b/a US Investment FL LLC, Top Sun Energy LLC, Ocean Blvd. X Property Management LLC, US1 Real Estate Developments, LLC, and Investor Asset Protection, LLC Case Number: 15-cv-62323 (United States District Court for the Southern District of Florida) Date Filed: November 3, 2015 Date of Qualifying Judgment/Order: January 22, 2018 SEC v. P.; Select Asset Management, LLC; Select Capital Management, LLC; Select Asset Fund I, LLC; and Select Asset Prime Index Fund, LLC Case Number: 11-cv-02830 (United States District Court for the Southern District of Texas) Date Filed: August 1, 2011 Date of Qualifying Judgment/Order: January 8, 2018 In the Matter of Industrial and Commercial Bank of China Financial Services LLC Administrative Proceeding File No.: 3-18341 Date Filed: January 18, 2018 Date of Qualifying Judgment/Order: January 18, 2018 SEC v. Kaplan, Esq., Synchronized Organizational Solutions, LLC, Synchronized Organizational Solutions International, Ltd., and Manna International Enterprises, Inc. Just Info LLC, David Weddle, and Scott Allensworth Case Number: 17-cv-07426 (United States District Court for the Central District of California) Date Filed: October 11, 2017 Date of Qualifying Judgment/Order: October 25, 2017 In the Matter of Augustine Capital Management, LLC (f/k/a Augustine Capital Management, Inc.), John T. Duszynski, CPA Administrative Proceeding File No.: 3-17740 Date Filed: October 26, 2017 Date of Qualifying Judgment/Order: October 26, 2017 SEC v. Case Number: 11-cv-05316 (United States District Court for the Central District of California) Date Filed: June 24, 2011 Date of Qualifying Judgment/Order: September 13, 2017 SEC v. Case Number: 14-cv-01155 (United States District Court for the Northern District of Ohio) Date Filed: May 29, 2014 Date of Qualifying Judgment/Order: September 26, 2017 SEC v. Case Number: 17-cv-11817 (United States District Court for the District of Massachusetts) Date Filed: September 22, 2017 Date of Qualifying Judgment/Order: September 25, 2017 SEC v.

million. Poppe Case Number: 19-cv-02534 (United States District Court for the Southern District of Texas) Date Filed: July 15, 2019 Date of Qualifying Judgment/Order: July 16, 2019 In the Matter of Robert L. Dwayne Edwards, Todd Barker, Senior Solutions of Social Circle, LLC, Oxton Place of Douglas, LLC d/b/a Oxton Real Estate of Douglass, LLC, Rome Alf, LLC, Savannah ALF, LLC, Gainesville ALF, LLC, Waterford Place ALF, LLC, Montgomery ALF, LLC, Columbus ALF, LLC, and Opelika ALF, LLC Case Number: 17-cv-00393 (United States District Court for the District of New Jersey) Date Filed: January 20, 2017 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. By posting a Notice for a particular case, we are not making any determinations either that (i) a whistleblower tip, complaint or referral led to the SEC opening an investigation or filing an action with respect to the case or (ii) an award to a whistleblower will be paid in connection with the case. Capital Group, LTD., Abraham “Avi” Mirman Case Number: 17-cv-05821 (United States District Court for the Southern District of New York) Date Filed: August 1, 2017 Date of Qualifying Judgment/Order: July 1, 2019 SEC v. Amit Kanodia and Iftikar Ahmed Case Number: 15-cv-13042 (United States District Court for the District of Massachusetts) Date Filed: April 2, 2015 Date of Qualifying Judgment/Order: July 8, 2019 SEC v. Iannelli and Essex Capital Corporation Case Number: 18-cv-05008 (United States District Court for the Central District of California) Date Filed: June 5, 2018 Date of Qualifying Judgment/Order: June 6, 2019 SEC v. Meenavalli, Amro Izzelden Altahwi a/k/a Andy Altahawi, Suresh Tammineedi, and Dorababu Penumarthi Case Number: 18-cv-02977 (United States District Court for the Southern District of New York) Date Filed: April 4, 2018 Date of Qualifying Judgment/Order: June 7, 2019 SEC v. and CM Capital Management, LLC Case Number: 18-cv-00442 (United States District Court for the Eastern District of Virginia) Date Filed: June 27, 2018 Date of Qualifying Judgment/Order: June 13, 2019 SEC v.

Beman Administrative Proceeding File No.: 3-18682 Date Filed: August 27, 2018 Date of Qualifying Judgment/Order: August 27, 2018 In the Matter of Kevin A. Case Number: 18-cv-03942 (United States District Court for the Northern District of California) Date Filed: July 2, 2018 Date of Qualifying Judgment/Order: July 9, 2018 SEC v. Wealth Strategies Case Number: 15-cv-02767 (United States District Court for the Southern District of Texas) Date Filed: September 22, 2015 Date of Qualifying Judgment/Order: July 5, 2018 SEC v. Providence Financial Investments, Inc., Providence Fixed Income Fund, LLC, Jeffory Churchfield, and Jack Jarrell Case Number: 16-cv-01877 (United States District Court for the District of Minnesota) Date Filed: June 7, 2016 Date of Qualifying Judgment/Order: July 11, 2018 SEC v. Handkins, Gilbert Steedley, Breitling Oil & Gas Corporation, Crude Energy, LLC, Patriot Energy, Inc. Cahoon Case Number: 17-cv-01894 (United States District Court for the Western District of Washington) Date Filed: December 19, 2017 Date of Qualifying Judgment/Order: June 7, 2018 SEC v. Gill, and Javier Rios Case Number: 16-cv-02814 (United States District Court for the Northern District of California) Date Filed: May 25, 2015 Date of Qualifying Judgment/Order: September 12, 2017 In the Matter of New York Stock Exchange LLC, NYSE American LLC, and NYSE Arca, Inc. Ariel Quiros, William Stenger, Jay Peak, Inc., Q Resorts, Inc., Jay Peak Hotel Suites L. P., Jay Peak Management, Inc., Jay Peak Penthouse Suites L. The Leonard Vincent Group, Leonard Vincent Lombardo, and Brian A. Oxford City Football Club, Inc., and Thomas Anthony Guerriero Case number: 15-cv-62594 (United States District Court for the Southern District of Florida) Case filed: December 10, 2015 Qualifying Judgment/Order: January 26, 2017 SEC v. Yin Nan "Michael" Wang, Wendy Ko, Velocity Investment Group, Inc., Bio Profit Series I, LLC, Bio Profit Series II, LLC, Bio Profit Series III, LLC, Bio Profit Series V, LLC, and Rockwell Realty Management, Inc.

Team Resources, Inc., Fossil Energy Corporation, Kevin A. Dressner, Michael Eppy, Andrew Stitt, and John Olivia Case Number: 15-cv-01045 (United States District Court for the Northern District of Texas) Date Filed: April 6, 2015 Date of Qualifying Judgment/Order: November 20, 2017 SEC v. Ming Zhao and Liping Zhu Case Number: 12-cv-01316 (United States District Court for the Southern District of New York) Date Filed: February 22, 2012 Date of Qualifying Judgment/Order: July 24, 2015 SEC v. Imperial Petroleum, Inc., Jeffrey Wilson, Craig Ducey, Chad Ducey, Brian Carmichael, Joseph Furando, Evelyn Katirina Pattison (a/k/a Katirina Tracy), Caravan Trading, LLC, CIMA Green, LLC, and CIMA Energy Group Case Number: 13-cv-01489 (United States District Court for the Southern District of Indiana) Date Filed: September 18, 2013 Date of Qualifying Judgment/Order: November 28, 2017 SEC v. Landress Administrative Proceeding File No.: 3-17826 Date Filed: February 7, 2017 Date of Qualifying Judgment/Order: February 7, 2017 SEC v. Hudnall and JBH Consulting Group LLC Case Number: 17-cv-00059 (United States District Court for the Western District of Missouri) Date Filed: January, 27, 2017 Date of Qualifying Judgment/Order: February 9, 2017 SEC v. Yossef Kahlon, a/k/a Jossef Kahlon, and TJ Management Group, LLC Case number: 12-cv-00517 (United States District Court for the Eastern District of Texas) Case filed: August 14, 2012 Qualifying Judgment/Order: September 30, 2016 SEC v. Innovative Advisory Services, Inc., Innovative Advisory Services LLC, Island Trader LLC and Richard H. Sean David Morton, Vajra Productions, LLC, 27 Investments, LLC, and Magic Eight Ball Distributing, Inc. In an Account of Phillip Securities PTE LTD., and Certain Unknown Traders in the Securities of Nexen, Inc. Linton, Esq., Protégé Enterprises, LLC, and Capital Edge Enterprises, LLC Case number: 12-cv-00646 (United States District Court for the Middle District of Florida) Case filed: April 30, 2012 Qualifying Judgment/Order: November 5, 2012 In the Matter of Credit Suisse Securities (USA) LLC; DLJ Mortgage Capital, Inc.; Credit Suisse First Boston Mortgage Acceptance Corp.; Credit Suisse First Boston Mortgage Securities Corp.; and Asset Backed Securities Corporation Administrative Proceeding File No.: 3-15098 Case filed: November 16, 2012 Qualifying Judgment/Order: November 16, 2012 SEC v.

Little Case Number: 14-cv-01106 (United States District Court for the Northern District of Texas) Date Filed: March 28, 2014 Date of Qualifying Judgment/Order: November 30, 2017 SEC v. Case Number: 16-cv-09403 (United States District Court for the District of New Jersey) Date Filed: December 21, 2016 (amended May 11, 2017) Date of Qualifying Judgment/Order: November 21, 2017 SEC v. Debrabandere, Bobby Dwayne Montgomery Case Number: 17-cv-03230 (United States District Court for the District of Maryland) Date Filed: November 2, 2017 Date of Qualifying Judgment/Order: November 7, 2017 SEC v. as successor entity to Liquid Realty Advisors III, LLC and Scott M. Noack Case number: 11-cv-00755 (United States District Court for the Eastern District of Wisconsin) Case filed: August 10, 2011 Qualifying Judgment/Order: December 6, 2016 In the Matter of Ernst & Young LLP, Craig R. Adams, CPA Administrative Proceeding File No.: 3-17628 Case filed: October 18, 2016 Qualifying Judgment/Order: October 18, 2016 SEC v. Richard Weed, Thomas Brazil and Coleman Flaherty III Case number: 14-cv-14099 (United States District Court for the District of Massachusetts) Case filed: November 6, 2014 Qualifying Judgment/Order: October 4, 2016 SEC v. Dalmy Case number: 13-cv-05511 (United States District Court for the Northern District of Illinois) Case filed: August 1, 2013 Qualifying Judgment/Order: October 12, 2016 SEC v. Kaley, and Keith Jablon Case number: 09-cv-01963 (United States District Court for the Middle District of Florida) Case filed: November 18, 2009 Qualifying Judgment/Order: March 29, 2013 In the Matter of Focus Point Solutions, Inc., The H Group, Inc., and Christopher Keil Hicks Administrative Proceeding File No.: 3-15011 Case filed: September 6, 2012 Qualifying Judgment/Order: September 6, 2012 SEC v. Lundstrom Case number: 12-cv-00343 (United States District Court for the District of Nebraska) Case filed: September 25, 2012 Qualifying Judgment/Order: September 27, 2012 SEC v. Case number: 10-cv-00263 (United States District Court for the District of New Mexico) Case filed: March 23, 2010 Qualifying Judgment/Order: February 14, 2013 SEC v. Martel, D/B/A Martel Financial Group, and MFG Funding Case number: 12-cv-11095 (United States District Court for the District of Massachusetts) Case filed: June 19, 2012 Qualifying judgment/order: January 7, 2013 SEC v. Igor Poteroba, Aleksey Koval and Alexander Vorobiev Case number: 10-cv-02667 (United States District Court for the Southern District of New York) Case filed: March 24, 2010 Qualifying judgment/order: January 15, 2013 SEC v. Liskov Case number: 11-cv-11576 (United States District Court for the District of Massachusetts) Case filed: September 8, 2011 Qualifying judgment/order: December 12, 2012 SEC v. Well Advantage Limited, Certain Unknown Traders in the Securities of Nexen, Inc. Private Equity Management Group, Inc.; Private Equity Management Group, LLC; and Danny Pang Case number: 09-cv-2901 (United States District Court for the Central District of California) Case filed: April 24, 2009 Qualifying Judgment/Order: October 22, 2012 SEC v.

Feldman and Romildo Da Cunha Case Number: 15-cv-12857 (United States District Court for the District of Massachusetts) Date Filed: June 30, 2015 Date of Qualifying Judgment/Order: May 14, 2019 SEC v. James Thomas Bramlette; The Pelorus Group, LLC; Anthony Mark Hartman; Private Placement Capital Notes II, LLC; Stone Mountain Equities, LLC; Travis Kozlowski, Entelecus Fund, LLC; Aaron John Wernli Case Number: 18-cv-00761 (United States District Court for the District of Utah) Date Filed: September 26, 2018 Date of Qualifying Judgment/Order: April 29, 2019 SEC v. Case Number: 17-cv-00336 (United States District Court for the Eastern District of Texas) Date Filed: May 15, 2017 Date of Qualifying Judgment/Order: October 9, 2018 In the Matter of CMB Export, LLC; Patrick F. Commodities Online, LLC and Commodities Online Management, LLC Case Number: 11-cv-60702 (United States District Court for the Southern District of Florida) Date Filed: April 1, 2011 Date of Qualifying Judgment/Order: September 24, 2018 In the Matter of Mark R. Mast Case Number:18-cv-02381 (United States District Court for the District of Colorado) Date Filed: September 18, 2018 Date of Qualifying Judgment/Order: September 19, 2018 In the Matter of Putnam Investment Management, LLC and Zachary Harrison Administrative Proceeding File No.: 3-18844 Date Filed: September 27, 2018 Date of Qualifying Judgment/Order: September 27, 2018 SEC v. Baldwin Case Number: 15-cv-01068 (United States District Court for the Middle District of North Carolina) Date Filed: December 16, 2015 Date of Qualifying Judgment/Order: September 26, 2018 SEC v.

Shumway Case Number: 16-cv-01199 (United States District Court for the District of Utah) Date Filed: November 28, 2016 Date of Qualifying Judgment/Order: March 29, 2019 SEC v. Mueller, Kentucky-Tennessee 50 Wells/400 BBLPD Block, Limited Partnership, HP Operations, LLC, C. Steve Qi and Law Offices of Steve Qi & Associates, A Professional Corporation Case Number: 17-cv-08856 (United States District Court for the Central District of California) Date Filed: December 8, 2017 Date of Qualifying Judgment/Order: November 5, 2018 SEC v. Schmidt; Futuregen Company d/b/a Futuregen Capital Commercial Equity Partners, LTD.; FGC Distressed Assets Investment #1, LLC; Futuregen Capital DDA CG Fund LLC; FGC Tax Lien Fund #2, LLC; FGC Trading Fund #1 LLC; FGC SPE NO 1 LLC; FGC SPE NO 2 LLC; and FGC CM Note Fund LLC Case Number: 14-cv-01002 (United States District Court for the District of Columbia) Date Filed: June 12, 2014 Date of Qualifying Judgment/Order: October 3, 2018 SEC v. Emilio Francisco; PDC Capital Group, LLC; Caffe Primo International, Inc.; Sal Assisted Living, LP; Sal Carmichael, LP; Sal Citrus Heights, LP; Sal Kern Canyon, LP; Sal Phoenix, LP; Sal Westgate, LP; Summer place at Sarasota, LP; Summerplace at Clearwater, LP; Summerplace at Correll Palms, LP; TRC Tucson, LP; Clear Currents West, LP; Caffe Primo Management, LP; Caffe Primo Management 102, LP; Caffe Primo Management 103, LP; Caffe Primo Management 104, LP; Caffe Primo Management 105, LP; Caffe Primo Management 106, LP; Caffe Primo Management 107, LP; Caffe Primo Management 108, LP Case Number: 16-cv-02257 (United States District Court for the Central District of California) Date Filed: December 27, 2016 Date of Qualifying Judgment/Order: October 4, 2018 SEC v. Matthew Carl Griffin and William Daniel Griffin Case Number: 16-cv-00902 (United States District Court for the Eastern District of Texas) Date Filed: November 23, 2016 Date of Qualifying Judgment/Order: October 9, 2018 SEC v. Bryant, III, and Bryant United Capital Funding, Inc. Case Number: 18-cv-02253 (United States District Court for the Southern District of California) Date Filed: September 27, 2018 Date of Qualifying Judgment/Order: September 28, 2018 In the Matter of Convergex Execution Solutions, LLC, now known as Cowen Execution Services LLC Administrative Proceeding File No.: 3-18761 Date Filed: September 13, 2018 Date of Qualifying Judgment/Order: September 13, 2018 In the Matter of Heartland Payment Systems, LLC, f/k/a Heartland Payment Systems, Inc. Carr Administrative Proceeding File No.: 3-18819 Date Filed: September 21, 2018 Date of Qualifying Judgment/Order: September 21, 2018 SEC v. Karroum a/k/a Mustapha Karroum, and FX & Beyond Corporation Case Number: 17-cv-00187 (United States District Court for the Eastern District of Virginia) Date Filed: February 21, 2017 Date of Qualifying Judgment/Order: September 10, 2018 In the Matter of Walgreens Boots Alliance, Inc., Gregory D. Miquelon Administrative Proceeding File No.: 3-18850 Date Filed: September 28, 2018 Date of Qualifying Judgment/Order: September 28, 2018 SEC v. Path America, LLC; Path America Sno Co LLC; Path America Farmer's Market, LP; Path America King Co LLC; Path America Tower, LP; Path Tower Seattle, LP; Potala Tower Seattle, LLC; and Lobsang Dargey Case Number: 15-cv-01350 (United States District Court for the Western District of Washington) Date Filed: August 24, 2015 Date of Qualifying Judgment/Order: March 3, 2017 SEC vs. Gray, Jr., Archipel Capital LLC, BIM Management LP Case Number: 15-cv-01465 (United States District Court for the Southern District of New York) Date Filed: Feburary 27, 2015 Date of Qualifying Judgment/Order: January 10, 2017 SEC vs.

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