EFTA Document EFTA01386100

AGP LP 519 Alpha Group Capital Paul Barrett Date of Action: August 22, 2011 Entity. UBS Financial Semites, Inc. Brought By: New Hampshire Bureau of Securities Regulation Nlegations: UBS sold Lehman Structured Products to clients (specifically referencing three particular investors), who were not made aware of the risks of these products and failed to inform clients of Lehman's financial condition plot to Lehman's bankruptcy. It was also alleged that the firm's recommendations to a small number of New Hampshire residents to purchase Lehman Structured Products were unsuitable. Disposition: Consent Order Administrative line of $100,000; Investigation costs of $200,000; Administrative payment of $700,000 2. Date of Action: May 4.2011 Brought By: SEC, Internal Revenue Service (IRS), Dept. of Justice (DOJ), State Attorney General of 24 Stales UBS AG and UBS Financial Services Inc. reached settlements with the SEC, the IRS, the Dal and a group of State Attorneys General regarding investigations into the conduct of certain former employees in 1165 Pinar:dal Services' twiner municipal reinvestment and derivatives group from. 2001 to 2006. Nlegations included violations of: Section 15(cR1)() of the Securities Exchange Act of 1934, Section I of the Sherman Act, and IRS regulations in bidding practices and representations mace involving the investment of proceeds of municipal securities transactions. Disposition: SEC: Waiver and Consent to Final Judgment enjoining UBS from violating Section 15(c) of the Act, disgorgement of profits, interest and civil penalty, IRS: Closing Agreement; DOR Non- prosecution Agreement SEC: Disgorgement of 49,606,543 plus Interest of 15,100.637 and civil penalty of $32,500,000; IRS: penalty of $18 million and restitution of 4.3 million; States: $70.8 minion plus $20 million credited from the SEC settlement 3. Date of Action: Dec. 22, 2008 Brought By: Securities and Exchange Commission (SEC), Massachusetts Securities Division, New York State Attorney General (NYAG) and other members of the North American Securities Administrators Association. Auction Rate Securities (ARS): UBS is permanently enjoined from violations of the broker/dealer anti-fraud provisions. Nlegations: Violations of 34 Act Section 15(c) regarding the marketing and sale of Auction Rate Securities. Disposkion: Cease & Desist INunction; CMI Penalty; Consent Judgment Cease & Desist, and Fines in varying amounts currently being paid m all 50 states. UBS Financial Seances Inc. (together with UBS Securities LLC) agreed to pay a fine of $150 mil:ion (575 million to the NYAG and 175 million allocated to the remaining states). 4. Date of Action: luly 16, 2007 Entity: 085 Financial Services B-ought Br Attorney General State of NY Alegations: Non-discretionary fee-based brokerage accounts offered by UBS were unsuitaale for certain clients and fees/commissions were higher than non- fee based accounts Disposition: Remediation to Customers & Penalty to State of NY Remetkation: 521300,000; Penalty: 52.000,030 Page 1 of 2 OBS PS Disciplinary History for Third Party Funds - Dictribution Plasform 9-20-13.dos CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087647 CONFIDENTIAL SDNY_GM_00233831 EFTA01386100