Security Capital Research & Management Incorporated

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
JPMORGAN CHASE & CO. ("JPMC")
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ("DISTRICT COURT"), 3:15-CR-79 (SRU)
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
05/20/2015
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
JPMC WAS CHARGED WITH A ONE COUNT FELONY CRIME CHARGE IN VIOLATION OF THE SHERMAN ANTITRUST ACT, 15 U.S.C. SECTION 1
RELATING TO THE FOREIGN CURRENCY EXCHANGE SPOT MARKET ("FX SPOT MARKET"). JPMC PLED GUILTY PURSUANT TO A PLEA AGREEMENT
WITH THE DOJ.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
01/10/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
JPMC ENTERED A GUILTY PLEA ON MAY 20, 2015 PURSUANT TO A PLEA AGREEMENT WITH THE DOJ. JPMC AGREED TO PAY A CRIMINAL FINE OF $550
MILLION AND A MANDATORY ASSESSMENT OF $400. JPMC AGREED TO BE SUBJECT TO PROBATION FOR 3 YEARS. ON JANUARY 10, 2017 JUDGMENT WAS
ENTERED CONSISTENT WITH THE TERMS OF THE PLEA AGREEMENT. THE FINE WAS PAID ON JANUARY 17, 2017.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
ON MAY 20, 2015, THE DOJ FILED A CRIMINAL INFORMATION IN THE DISTRICT COURT CHARGING JPMC WITH A ONE COUNT CRIME CHARGE IN
VIOLATION OF THE SHERMAN ANTITRUST ACT, 15 U.S.C. § 1 (THE "INFORMATION"). THE INFORMATION CHARGES THAT, FROM JULY 2010 UNTIL AT
LEAST JANUARY 2013, JPMC, THROUGH ONE OF ITS EURO/U.S. DOLLAR ("EUR/USD") TRADERS, ENTERED INTO AND ENGAGED IN A CONSPIRACY TO FIX,
STABILIZE, MAINTAIN, INCREASE OR DECREASE THE PRICE OF, AND RIG BIDS AND OFFERS FOR, THE EUR/USD CURRENCY PAIR EXCHANGED IN THE FX
SPOT MARKET BY AGREEING TO ELIMINATE COMPETITION IN THE PURCHASE AND SALE OF THE EUR/USD CURRENCY PAIR IN THE U.S. AND ELSEWHERE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
UNITED STATES DISTRICT COURT, DISTRICT OF CONNECTICUT
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
2 COUNTS OF WIRE FRAUD, IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1343
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
DEFERRED PROSECUTION AGREEMENT ~$920MM PENALTY WAS PAID ON OCT. 9TH AND THE FIRM IS REQUIRED TO COMPLY WITH THE OBLIGATIONS
SET FORTH IN THE DEFERRED PROSECUTION AGREEMENT FOR A PERIOD OF 3 YEARS
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)

11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION
2.
Principal Sanction:
Restitution
Other Sanctions: 
IN ADDITION TO THE AGREEMENT TO REPURCHASE CERTAIN AUCTION RATE SECURITIES ("ARS") SOLD TO ELIGIBLE INVESTORS PRIOR TO FEBRUARY
13, 2008, THE SETTLEMENT CALLS FOR THE REIMBURSEMENT OF ELIGIBLE INVESTORS WHO SOLD ARS BELOW PAR, REFUNDING OF CERTAIN LOAN
EXPENSES INCURRED BY ELIGIBLE INVESTORS, SPECIAL ARBITRATION PROCEEDINGS CONCERNING CONSEQUENTIAL DAMAGES WITH RESPECT TO
ARS, REFUNDING CERTAIN REFINANCING FEES INCURRED BY MUNICIPAL ISSUERS OF ARS AND A CIVIL PENALTY.
3.
Date Initiated (MM/DD/YYYY): 
01/03/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
12009000013

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE INVESTIGATION CONCERNED ALLEGED MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION
OF AUCTION RATE SECURITIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/03/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 97,706.22
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
IN ADDITION TO THE AGREEMENT TO REPURCHASE CERTAIN AUCTION RATE SECURITIES ("ARS") SOLD TO ELIGIBLE INVESTORS PRIOR TO
FEBRUARY 13, 2008, THE SETTLEMENT CALLS FOR THE REIMBURSEMENT OF ELIGIBLE INVESTORS WHO SOLD ARS BELOW PAR, REFUNDING OF
CERTAIN LOAN EXPENSES INCURRED BY ELIGIBLE INVESTORS, SPECIAL ARBITRATION PROCEEDINGS CONCERNING CONSEQUENTIAL DAMAGES
WITH RESPECT TO ARS, REFUNDING CERTAIN REFINANCING FEES INCURRED BY MUNICIPAL ISSUERS OF ARS AND A CIVIL PENALTY.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, JPMORGAN CHASE & CO CONSENTED TO A FINE OF $97706.22 WHICH WAS PAID ON
01/04/2017. THE FINE REPRESENTS THE NEW HAMPSHIRE PORTION OF A TOTAL FINE OF $25 MILLION NEGOTIATED WITH THE NYAG AND THE
STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE. THE REMAINING AMOUNT WILL BE PAID
SEPARATELY TO OTHER STATES. ALSO PAID WAS $15,000 TO NASAA AS REIMBURSEMENT FOR INVESTIGATIVE COSTS INCURRED BY NASAA.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE ACTION RELATED TO ALLEGATIONS WITH RESPECT TO MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND
DISTRIBUTION OF AUCTION RATE SECURITIES. AS DESCRIBED HEREIN, THE PRINCIPAL TERMS OF THE SETTLEMENT WERE NEGOTIATED WITH THE NYAG
AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE NASAA TASK FORCE THAT CONTEMPLATES SEPARATE SIMILAR
AGREEMENTS WITH OTHER STATES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL MONEY PENALTY AND UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY): 
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
16-22-B-HC AND 16-22-CMP-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE
SYSTEM ("FRB") RESULTING IN THE FRB ISSUING AN ORDER ("ORDER"). THE ORDER FINDS THAT FROM AT LEAST 2008 THROUGH 2013, JPMC'S ASIA-
PACIFIC REGION INVESTMENT BANKING GROUP OPERATED A REFERRAL HIRING PROGRAM WHEREBY CANDIDATES WHO WERE REFERRED, DIRECTLY OR
INDIRECTLY, BY FOREIGN GOVERNMENT OFFICIALS AND EXISTING OR PROSPECTIVE COMMERCIAL CLIENTS, AND WHO IN MOST INSTANCES WERE LESS
QUALIFIED THAN NON-REFERRED CANDIDATES WHO WERE HIRED THROUGH THE JPMC'S STANDARD HIRING PROGRAMS, WERE OFFERED INTERNSHIPS,
TRAINING, AND OTHER EMPLOYMENT OPPORTUNITIES IN ORDER TO OBTAIN IMPROPER BUSINESS ADVANTAGES FOR JPMC.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 61,932,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST AND TO PAY A CIVIL MONEY PENALTY OF $61,932,500, WHICH WAS PAID ON NOVEMBER 17,
2016. IN ADDITION, THE ORDER REQUIRES JPMC TO TAKE THE FOLLOWING STEPS: A) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE
FOR IMPLEMENTATION, TO IMPROVE SENIOR MANAGEMENT'S OVERSIGHT OF JPMC'S 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 FIRM'S 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 JPMC'S FIRM-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM WITH
REGARD TO THE OVERSIGHT AND IMPLEMENTATION OF ANTI-BRIBERY PROCESSES AND PROCEDURES IN CONNECTION WITH THE FIRM'S
REFERRAL HIRING PRACTICES; AND C) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO ENHANCE THE
EFFECTIVENESS OF THE FIRM'S COMPLIANCE WITH INTERNAL POLICIES AND PROCEDURES AS WELL AS APPLICABLE U.S. LAWS AND
REGULATIONS IN ITS REFERRAL HIRING PRACTICES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12. IN COORDINATION WITH
THE FRB SETTLEMENT, JPMC AND CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH OTHER AGENCIES TO RESOLVE CONCURRENT
INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE SETTLEMENTS ARE AS FOLLOWS: JPMORGAN APAC ENTERED INTO A NON-
PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE AND CONSENTED TO THE ISSUANCE OF A CRIMINAL FINE FOR VIOLATIONS OF
FEDERAL ANTI-BRIBERY LAWS AND THE U.S. SECURITIES AND EXCHANGE COMMISSION ENTERED AN ADMINISTRATIVE CEASE-AND-DESIST ORDER
AGAINST JPMC FINDING VIOLATIONS OF FEDERAL ANTI-BRIBERY AND SECURITIES LAWS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:

11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SEC
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
DISGORGEMENT, PRE-JUDGMENT INTEREST, AND UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY): 
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-17684

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION
("SEC") UNDER WHICH JPMC CONSENTED TO THE ENTRY OF AN ORDER (THE "ORDER") THAT FINDS THAT JPMC VIOLATED SECTIONS 13(B)(2)(A), 13(B)
(2)(B) AND 30A OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"). THE ORDER FINDS THAT JPMC 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 JPMC IN RETAINING AND OBTAINING BUSINESS. IN ADDITION, THE
ORDER FINDS THAT JPMC 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.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE
ABOVE-ENUMERATED STATUTORY PROVISIONS. ADDITIONALLY, THE ORDER REQUIRES JPMC 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, JPMC 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 JPMC'S REMEDIATION AND IMPLEMENTATION OF COMPLIANCE MEASURES RELATING TO
FCPA AND APPLICABLE ANTI-CORRUPTION LAWS, AND CERTIFYING THAT JPMC HAS MADE A GOOD FAITH EFFORT TO COMPLY WITH THE
UNDERTAKINGS. THE SEC DID NOT IMPOSE A CIVIL PENALTY BASED UPON THE IMPOSITION OF A $72,000,000 CRIMINAL FINE AS PART OF
JPMORGAN SECURITIES (ASIA PACIFIC) LIMITED'S ("JPMORGAN APAC") SETTLEMENT WITH THE UNITED STATES DEPARTMENT OF JUSTICE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SOLELY FOR THE PURPOSE OF SETTLING THESE PROCEEDINGS, JPMC ADMITTED THE SEC'S JURISDICTION AND THE SUBJECT MATTER OF THESE
PROCEEDINGS AND CONSENTED TO THE ORDER. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE
IN ITEMS 7 AND 12. IN COORDINATION WITH THE SEC SETTLEMENT, JPMC AND CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH
OTHER AGENCIES TO RESOLVE CONCURRENT INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE SETTLEMENTS ARE AS FOLLOWS:
JPMORGAN APAC ENTERED INTO A NON-PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE THAT ACKNOWLEDGES RESPONSIBILITY FOR
CRIMINAL CONDUCT RELATING TO CERTAIN FINDINGS IN THE ORDER AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ENTERED AN
ADMINISTRATIVE CEASE-AND-DESIST ORDER AGAINST JPMC.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JPMORGAN CHASE & CO.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY): 
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
CFTC DOCKET NO. 20-69
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
PRECIOUS METALS, FUTURES CONTRACTS, AND U.S. TREASURY FUTURES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CFTC ENTERED AN ORDER RESOLVING AN ACTION AGAINST JPMORGAN CHASE & CO., AN AFFILIATED BANK (THE "BANK") AND AN AFFILIATED
BROKER-DEALER (THE "BROKER-DEALER") (COLLECTIVELY, "JPM"). ACCORDING TO THE ORDER, FROM AT LEAST 2008 THROUGH 2016, NUMEROUS
TRADERS ON THE PRECIOUS METALS AND U.S. TREASURIES TRADING DESKS AT THE BANK AND THE BROKER-DEALER ENGAGED IN A MANIPULATIVE AND
DECEPTIVE SCHEME BY ENGAGING IN THE PRACTICE OF "SPOOFING" (BIDDING OR OFFERING WITH THE INTENT TO CANCEL THE BID OR OFFER BEFORE
EXECUTION) WHILE PLACING ORDERS FOR FUTURES CONTRACTS ON A REGISTERED ENTITY, RESULTING IN SIGNIFICANT BENEFIT TO THEMSELVES AND
HARM TO OTHER MARKET PARTICIPANTS. BY VIRTUE OF THIS CONDUCT, JPM ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN
VIOLATION OF SECTION 9(A)(2) OF THE ACT, 7 U.S.C. § 13(A)(2) (2018); FOR CONDUCT OCCURRING ON OR AFTER JULY 16, 2011, ENGAGED IN
SPOOFING IN VIOLATION OF SECTION 4C(A)(5)(C) OF THE ACT, 7 U.S.C. § 6C(A)(5)(C) (2018); AND FOR CONDUCT OCCURRING ON OR AFTER AUGUST
15, 2011, ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN VIOLATION OF SECTION 6(C)(1) AND 6(C)(3) OF THE ACT, 7 U.S.C. § 9(1),
(3) (2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019). FURTHER, IN CONJUNCTION WITH THE
ABOVE-REFERENCED MISCONDUCT, THE BROKER-DEALER FAILED TO DILIGENTLY SUPERVISE IN VIOLATION OF COMMISSION REGULATION 166.3, 17
C.F.R. § 166.3 (2019). THE BANK AND THE BROKER­DEALER DO NOT CONTROL, NOR ARE THEY CONTROLLED BY, THE ADVISER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 436,431,811.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE ORDER DIRECTS JPM TO CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C) (3), AND 9(A)(2) OF THE ACT, 7 U.S.C. §§
6C(A)(5)(C), 9(1), (3), 13(A)(2) (2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019).
ADDITIONALLY, THE ORDER REQUIRES THE BANK AND JPMC & CO. TO PAY RESTITUTION IN THE AMOUNT OF $205,992,102, AND THE BROKER-
DEALER AND JPMC & CO. TO PAY ADDITIONAL RESTITUTION IN THE AMOUNT OF $105,744,906. THE ORDER FURTHER REQUIRES JPM TO PAY A
CIVIL MONETARY PENALTY IN THE AMOUNT OF $436,431,811. THE ORDER ALSO REQUIRES THE BANK AND JPMC & CO. TO PAY DISGORGEMENT IN
THE AMOUNT OF $120,332,430 AND THE BROKER-DEALER AND JPMC & CO. TO PAY DISGORGEMENT IN THE AMOUNT OF $51,702,360.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
RESPONDENTS JPM HAVE SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. ACCORDINGLY, IT IS HEREBY
ORDERED THAT JPM SHALL CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C)(3), AND 9(A)(2) OF THE ACT AND REGULATIONS
180.1(A)(1) AND (3) AND 180.2, AND THE BROKER-DEALER SHALL CEASE AND DESIST FROM VIOLATING REGULATION 166.3. THE BROKER-DEALER
SHALL PAY RESTITUTION OF ONE HUNDRED FIVE MILLION SEVEN HUNDRED FORTY-FOUR THOUSAND NINE HUNDRED SIX DOLLARS ($105,744,906),
JOINTLY AND SEVERALLY WITH JPMC & CO; A CIVIL MONETARY PENALTY OF FOUR HUNDRED THIRTY-SIX MILLION FOUR HUNDRED THIRTY-ONE
THOUSAND EIGHT HUNDRED ELEVEN DOLLARS ($436,431,811), JOINTLY AND SEVERALLY WITH THE BANK AND JPMC & CO; DISGORGEMENT IN THE
AMOUNT OF FIFTY ONE MILLION SEVEN HUNDRED TWO THOUSAND THREE HUNDRED SIXTY DOLLARS ($51,702,360), JOINTLY AND SEVERALLY WITH

JPMC & CO; ADDITIONALLY, THE BANK AND JPMC & CO SHALL PAY TWO HUNDRED FIVE MILLION NINE HUNDRED NINETY-TWO THOUSAND ONE
HUNDRED TWO DOLLARS ($205,992,102) IN RESITUTION AND ONE HUNDRED TWENTY MILLION THREE HUNDRED THIRTY-TWO THOUSAND FOUR
HUNDRED THIRTY DOLLARS ($120,332,430) IN DISGORGEMENT, JOINTLY AND SEVERALLY; JPM SHALL COMPLY WITH THE UNDERTAKINGS SET FORTH IN
THE ORDER.