U.S. Dollar Libor Settlement

There are lawsuits impacting individuals and institutions that entered into over-the-counter financial derivative and non-derivative instruments directly with 18 banks and that received payments tied to U.S. Dollar LIBOR. Settlements totaling $340 million have been reached with Deutsche Bank Aktiengesellschaft (“Deutsche Bank”) and HSBC Bank plc (“HSBC”). Earlier settlements were reached with Barclays and Citibank.

In addition, a court has certified a Litigation Class asserting claims against Bank of America, N.A. (“Bank of America”) and JPMorgan Chase Bank, N.A. (“JPMorgan Chase”).

You may be a member of one or more of the Deutsche Bank Settlement Class, the HSBC Settlement Class, and the Litigation Class.

The Settlement Classes include individuals and institutions who directly purchased certain U.S. Dollar LIBOR-based instruments from Bank of America, Bank of Tokyo-Mitsubishi, Barclays, Citibank, Citizens Bank, Credit Suisse, Deutsche Bank, HBOS, HSBC, JPMorgan Chase, Lloyds, Norinchukin, Rabobank, Royal Bank of Canada, Royal Bank of Scotland, SocGen, UBS, and WestLB (or their subsidiaries or affiliates) in the United States, and owned the instruments at any time between August 2007 and May 2010. The instruments included in the Settlement Classes can be found in Question 11 of the Long Form Notice. The Settlement Class Period is longer than the Litigation Class Period.

The Litigation Class includes individuals and entities who reside in the United States and purchased certain U.S. Dollar LIBOR-based instruments (interest rate swaps or bonds/floating rate notes) from Bank of America, Bank of Tokyo-Mitsubishi, Barclays, Citibank, Credit Suisse, Deutsche Bank, HBOS, HSBC, JPMorgan Chase, Lloyds, Norinchukin, Rabobank, Royal Bank of Canada, Royal Bank of Scotland, SocGen, UBS, and WestLB (or their subsidiaries or affiliates), and pursuant to those instruments, one of these banks paid you interest indexed to a 1-month or 3-month U.S. Dollar LIBOR rate set at any time between August 2007 and August 2009. The Litigation Class does not include Citizens Bank as a Defendant

To share in the Settlements, you must file a claim. If you filed a previous claim in the Barclays Settlement and/or Citibank Settlement, you will need to complete and submit a simple proof of claim by December 20, 2018, even if your previous Proof of Claim is accurate and complete. If you filed a previous claim in the Barclays Settlement and/or Citibank Settlement and want to supplement your original Proof of Claim with additional information, you will need to complete and submit a new Proof of Claim by December 20, 2018.

If you have not previously submitted a claim, you need to ask for a payment, and you will need to complete and submit a Proof of Claim in the Settlements with Deutsche Bank and HSBC by December 20, 2018.

To participate in the Litigation Class, you do not need to do anything at this time. You will be notified if a recovery is obtained for the Litigation Class. You should check this website regularly for updates to the ongoing Litigation.

To learn more about your right to receive payment, or to learn how to object to the Settlements or exclude yourself from the Settlements and/or Litigation Class, read the Long Form Notice.