In re SSA Bonds Antitrust Litigation

If You Transacted in SSA Bonds Between January 1, 2005 and March 6, 2019, You May Be Affected by Class Action Settlements.

• The Notice is to alert you to proposed Settlements reached with Defendants Bank of America Corporation, Bank of America, N.A., Merrill Lynch International, Bank of America Merrill Lynch International Limited, Merrill Lynch, Pierce, Fenner & Smith Incorporated (collectively, “Bank of America”), Deutsche Bank AG, Deutsche Bank Securities Inc. (collectively, “Deutsche Bank”), HSBC Securities (USA) Inc. and HSBC Bank plc (collectively, “HSBC,” and together with Bank of America and Deutsche Bank, “Settling Defendants”) in a class action against the Settling Defendants; and Barclays Bank plc, Barclays Capital Inc., Barclays Services Limited, Barclays Capital Securities Limited, BNP Paribas S.A., BNP Paribas Securities Corp., Citigroup Inc., Citibank N.A., Citigroup Global Markets Inc., Citigroup Global Markets Limited, Crédit Agricole Corporate and Investment Bank, Credit Suisse AG, Credit Suisse Securities (USA) LLC, Credit Suisse Securities (Europe) Limited, Credit Suisse International, Nomura Securities International, Inc., Nomura International plc, Royal Bank of Canada, RBC Capital Markets, LLC, RBC Europe Limited, The Toronto-Dominion Bank, TD Securities (USA) LLC, Hiren Gudka, Bhardeep Singh Heer, Amandeep Singh Manku, Gary McDonald, and Shailen Pau (“Non-Settling Defendants,” and together with Settling Defendants, “Defendants”).
• The lawsuit alleges that the Defendants engaged in anticompetitive acts that affected the market for SSA Bonds in violation of Section 1 of the Sherman Act, 15 U.S.C. §1. The lawsuit was brought by, and on behalf of, Persons who transacted in SSA Bonds. The Defendants deny doing anything wrong.
• Proposed Settlements have been reached with the Settling Defendants. The Settling Defendants have agreed to pay a total of $95.5 million (the “Settlement Fund”). Before any money is paid, the Court will have a hearing to decide whether to approve the Settlements. Court approval of these Settlements will resolve all claims against the Settling Defendants.
• The Class Plaintiffs and the Settling Defendants disagree on how much money could have been won if the Class Plaintiffs had won at trial against the Settling Defendants. The Class Plaintiffs’ claims against the Non-Settling Defendants (other than Hiren Gudka) were recently dismissed, and Class Plaintiffs are evaluating their appellate rights with regard to the dismissed claims. The Class Plaintiffs’ claims against Hiren Gudka were not dismissed because the release that is part of the Settlement Agreement with Settling Defendants Deutsche Bank and Bank of America, if approved, would apply to Mr. Gudka due to his employment history with Deutsche Bank and Bank of America.
• Your legal rights will be affected whether or not you act. Please read the entire Notice carefully.
• The Court in charge of this case must decide whether to approve the Settlements. Payments will be made if the Court approves the Settlements and, if there are any appeals, after appeals are resolved.

The Court has appointed the lawyers listed below to represent you and the Settlement Classes:

YOUR LEGAL RIGHTS AND OPTIONS IN THESE SETTLEMENTS
SUBMIT A CLAIM FORM	The only way to receive your share of the Settlement Fund.
EXCLUDE YOURSELF	Get no payment. This is the only option that allows you to ever be part of any other lawsuit against the Settling Defendants about the legal claims in this case.
OBJECT	Write to the Court about why you do or do not like the Settlements.
GO TO A HEARING	Ask to speak in Court about the fairness of the Settlements. By order dated March 18, 2021, the Court has decided to hold the April 2, 2021 Fairness Hearing by telephone only. Please do not try to attend in person. Please check the public docket or contact the Settlement Administrator for dial-in information.
DO NOTHING	Get no payment and give up your rights to be part of any other lawsuit against the Settling Defendants about the legal claims in this case.