SCHEDULE II
On May 20, 2015, JPMorgan Chase announced settlements with the U.S. Department of Justice (DOJ) and the Federal
Reserve relating to the JPMorgan Chases foreign exchange (FX) trading business. Under the DOJ resolution, JPMorgan Chase entered a plea of guilty to a single antitrust violation and agreed to pay a fine of $550 million. Judgment
consistent with the terms of the plea agreement was entered on January 10, 2017. Under the resolution with the Federal Reserve, JPMorgan Chase has agreed to a fine of $342 million and has agreed to the entry of a Consent Order. The
settlements also call for certain remedial actions.
On February 29, 2016, JPMorgan Chase and the Indiana Secretary of State,
Securities Division (the Division) entered into a Consent Agreement to resolve the Divisions investigation into JPMorgan Chases residential mortgage backed securities business for the period from 2005 to 2008. The
Division alleged that JPMorgan Chases conduct was outside the standards of honesty and ethics generally accepted in the securities trade and industry. On March 1, 2016, the Division entered an Order to Adopt the Consent Agreement.
On November 17, 2016, JPMorgan Chase entered into a settlement with the SEC under which JPMorgan Chase, without admitting or denying the
allegations, consented to the entry of an order (the Order) that finds that JPMorgan Chase violated Sections 13(B)(2)(A), 13(B)(2)(B) and 30A of the Exchange Act. The Order finds that JPMorgan Chase violated the Anti-Bribery
provisions of the federal securities laws by corruptly providing valuable internships and employment to relatives and friends of foreign government officials (Referral Hires) in order to assist JPMorgan Chase in retaining and
obtaining business. In addition, the Order finds that JPMorgan Chase violated the books and records provisions and the internal accounting controls provisions of the Foreign Corrupt Practices Act (FCPA) in conjunction with certain
Referral Hires. The Order directs JPMorgan Chase to cease-and-desist from committing or causing any violations and any future violations of the above-enumerated
statutory provisions. Additionally, the Order required JPMorgan Chase to pay a total of $105,507,668 in disgorgement and prejudgment interest of $25,083,737, which was paid on November 27, 2016. In addition, JPMorgan Chase was ordered to comply
with certain undertakings, including reporting to the SEC staff periodically, at no less than nine-month intervals during a three-year term, the status of JPMorgan Chases remediation and implementation of compliance measures relating to FCPA
and applicable anti-corruption laws, and certifying that JPMorgan Chase has made a good faith effort to comply with the undertakings.
JPMorgan Chase entered into another settlement on November 17, 2016 related to the same conduct referenced in the immediately preceding
paragraph. JPMorgan Chase entered into a settlement with the Board of Governors of the Federal Reserve System (FRB) resulting in the FRB issuing an order (the FRB Order). The FRB Order directs JPMorgan Chase to cease-and-desist such conduct and to pay a civil money penalty of $61,932,500 which was paid on November 17, 2016. In addition, the FRB Order requires JPMorgan Chase to
take the following steps: (a) submit an acceptable written plan, and timeline for implementation, to improve senior managements oversight of JPMorgan Chases firm-wide compliance risk management program with regard to compliance with
applicable U.S. laws and regulations and applicable internal policies and procedures in connection with the firms hiring of candidates who were referred, directly or indirectly, by foreign government officials and existing or prospective
commercial clients (Referral Hiring Practices); (b) submit an acceptable written plan, and timeline for implementation, to enhance the effectiveness of JPMorgan Chases firm-wide compliance risk management program with regard
to the oversight and implementation of anti-bribery processes and procedures in connection with the firms Referral Hiring Practices; and (c) submit an acceptable written plan, and timeline for implementation, to enhance the effectiveness
of JPMorgan Chases compliance with internal policies and procedures as well as applicable U.S. laws and regulations in its Referral Hiring Practices.