The opinion
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
IN RE LIBOR-BASED FINANCIAL MDL No. | 1-md-2262 (NRB)
INSTRUMENTS ANTITRUST LITIGATION
THIS DOCUMENT RELATES TO:
The OTC Action
[PROPOSED] FINAL JUDGMENT AND ORDER GRANTING
FINAL APPROVAL OF SETTLEMENT WITH DEFENDANTS COOPERATIEVE
RABOBANK U.A., LLOYDS BANKING GROUP PLC, LLOYDS BANK PLC,
HBOS PLC, BANK OF SCOTLAND PLC, ROYAL BANK OF CANADA,
PORTIGON AG, AND WESTDEUTSCHE IMMOBILIEN SERVICING AG
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WHEREAS, an action is pending before this Court styled Mayor and City Council of
Baltimore v. Credit Suisse AG, et al., No. 1:11-md-2262-NRB (the “OTC Action”);
WHEREAS, OTC Plaintiffs' have moved, pursuant to Federal Rule of Civil Procedure
23(e), for an order (a) granting final approval to the $101 million settlement with Defendants
Coéperatieve Centrale Raiffeisen-Boerenleenbank B.A. (n/k/a Codperatieve Rabobank U.A.)
(“Rabobank”), Lloyds Banking Group ple, Lloyds Bank plc, HBOS ple, and Bank of Scotland ple
(together, “Lloyds”), Royal Bank of Canada (“RBC”), and WestLB AG (n/k/a Portigon AG) and
Westdeutsche Immobilienbank AG (n/k/a Westdeutsche Immobilien Servicing AG) (together,
“Portigon”) (the “Settlement” or the “Settlement Agreement”);? (b) certifying the Settlement Class
(defined in {| 6, infra); (c) granting final approval to the Plan of Distribution (defined in 5, infra);
(d) appointing Hausfeld LLP and Susman Godfrey L.L.P. as co-lead counsel for the Settlement
Class; and (e) granting final approval to the Class Notice (defined in § 11, infra);
WHEREAS, persons or entities who entered into qualifying transactions with non-settling
Defendants* (or their subsidiaries and affiliates) can participate in this Settlement in part because
' Paragraph | of Settlement Agreement, ECF No. 3696-1, defines “OTC Plaintiffs” as: “Plaintiffs
Mayor and City Council of Baltimore, City of New Britain, Vistra Energy Corp., Yale University,
and Jennie Stuart Medical Center, Inc.”
* The Settlement Agreement memorializing the terms of the settlement with Rabobank, Lloyds,
RBC, and Portigon was entered into on July 21, 2023 and submitted to the Court as Exhibit A of
Seth Ard’s Declaration in Support of OTC Plaintiffs’ Motion for Preliminary Approval of the
Settlement. ECF No. 3696-1. All references to docket entries in this Final Judgment and Order are
references to Case No. 11-md-2262 (S.D.N.Y).
> Paragraph 2(j) of the Settlement Agreement defines “Defendants” as: “Barclays Bank plc;
Citigroup Inc.; Citibank, N.A.; Credit Suisse AG; Credit Suisse Group AG; Credit Suisse
International; Credit Suisse (USA) Inc.; Bank of America Corporation; Bank of America, N.A.;
JPMorgan Chase & Co.; JPMorgan Chase Bank, NA; HSBC Holdings plc; HSBC Bank ple;
Lloyds Banking Group ple; Lloyds Bank plc; HBOS ple; Bank of Scotland ple; WestLB AG n/k/a
Portigon AG; Westdeutsche Immobilienbank AG n/k/a Westdeutsche Immobilienservicing AG;
UBS AG; The Royal Bank of Scotland Group ple; Citizens Bank of Massachusetts a/k/a RBS
Citizens Bank N.A.; Deutsche Bank AG; Codéperatieve Centrale Raiffeisen-Boerenleenbank B.A.;
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the OTC Action includes antitrust claims under which Rabobank, Lloyds, RBC, and Portigon can
allegedly be held jointly and severally liable for the alleged conduct of all Defendants;
WHEREAS, the Court has considered the Settlement Agreement and other documents
submitted in connection with OTC Plaintiffs’ Motion for Final Approval of Settlement with
Rabobank, Lloyds, RBC, and Portigon, and good cause appearing therefor;
NOW, THEREFORE, IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
te This Court has subject matter jurisdiction over this action and personal jurisdiction
over Rabobank, Lloyds, RBC, and Portigon for purposes of this settlement, and all members of
the OTC Class (defined in § 6, infra).
2. All terms in initial capitalization used in this Final Judgment and Order shall have
the same meanings as set forth in the Settlement Agreement, unless otherwise defined herein.
I. FINAL APPROVAL OF SETTLEMENT
3. Upon review of the record, including the order preliminarily approving the
Settlement and the submissions in support of the Settlement and preliminary certification, the
Court finds that the Settlement resulted from arm’s-length negotiations between highly
experienced counsel and falls within the range of possible approval.
4, Pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, the Court hereby
grants final approval of the Settlement on the basis that it is fair, reasonable, and adequate as to,
and in the best interests of, all OTC Class Members,‘ within the meaning of, and in compliance
Codperatieve Rabobank U.A.; The Norinchukin Bank; The Bank of Tokyo-Mitsubishi UFJ, Ltd.,
n/k/a MUFG Bank, Ltd.; Société Générale $.A.; Royal Bank of Canada; and any other Person or
Persons who are or were named as defendants in the OTC Action at any time up to and including
the date a Preliminary Approval Order is issued.” ECF No. 3696-1 § 2(j).
* Paragraph 2(z) of the Settlement Agreement defines “OTC Class Member” as: “A Person who is
a member of the OTC Class and has not timely and validly excluded himself, herself, or itself in
accordance with the procedures established by the Court.” Jd. § 2(z).
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with all applicable requirements of, Federal Rule of Civil Procedure 23; the Court directs the
Settlement’s consummation according to the terms of the Settlement Agreement. In reaching this
conclusion, the Court has considered the factors set forth in Federal Rule of Civil Procedure 23(e)
and City of Detroit v. Grinnell Corp., 495 F.2d 448, 463 (2d Cir. 1974), abrogated on other
grounds by Goldberger v. Integrated Res., Inc., 209 F.3d 43 (2d Cir. 2000). Moreover, the Court
concludes as follows:
a. The Settlement was negotiated by counsel with significant experience
litigating antitrust class actions and is the result of vigorous arm’s length
negotiations undertaken in good faith and with the assistance of a
professional mediator experienced in complex cases;
b. This action is likely to involve contested and serious questions of law and
fact, such that the value of immediate monetary recovery, in conjunction
with the value of the prospective relief set forth in the Settlement, outweigh
the uncertain possibility of future relief after protracted and expensive
litigation; and
c Co-Lead Counsel’s° judgment that the Settlement is fair and reasonable,
and the OTC Class Members’ reaction to the Settlement, is entitled to great
weight.
> “Co-Lead Counsel” refers to Susman Godfrey L.L.P. and Hausfeld LLP, co-lead counsel for the
OTC Class.
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Il. FINAL APPROVAL OF THE PLAN OF DISTRIBUTION
5; Upon review of the record, the Court finds that the pro rata Plan of Distribution®
has a reasonable, rational basis and is fair and adequate. Therefore, the Plan of Distribution is
hereby finally approved.
Ill. CERTIFICATION OF THE SETTLEMENT CLASS
6. Pursuant to Rule 23 of the Federal Rules of Civil Procedure, the Court certifies,
solely for purposes of effectuating the Settlement set forth in the Settlement Agreement, the
settlement class (the “Class” or “OTC Class” or “Settlement Class”) that is defined as follows:
All persons or entities (other than Defendants and their employees,
affiliates, parents, and subsidiaries) that purchased in the United
States, directly from a Defendant (or a Defendant’s subsidiaries or
affiliates), a U.S. Dollar LIBOR-Based Instrument and that owned
the U.S, Dollar LIBOR-Based Instrument any time during the period
August 2007 through May 2010 (the “Class Period”).’
© The Plan of Distribution is found at ECF No. 3696-2.
"ECF No. 3696-1 3(a). “Specifically excluded from the Class are Defendants; Released Parties;
co-conspirators; the officers, directors, or employees of any Defendant, Released Party, or co-
conspirator; any entity in which any Defendant, Released Party, or co-conspirator has a controlling
interest; any affiliate, legal representative, heir, or assign of any Defendant, Released Party, or co-
conspirator and any person acting on their behalf. Also excluded from the Class are any judicial
officers presiding over this action and the members of their immediate families and judicial staff,
and any juror assigned to the OTC Action.” /d. § 3(b).
Paragraph 2(pp) of the Settlement Agreement defines “U.S. Dollar LIBOR-Based Instrument” as:
“An instrument that includes any term, provision, obligation or right to be paid by or to receive
interest from a Defendant (or its subsidiaries or affiliates) based upon the U.S. Dollar LIBOR rate,
including but not limited to asset swaps, bonds/floating rate notes, collateralized debt obligations,
credit default swaps, forward rate agreements, inflation swaps, interest rate swaps, total return
swaps, options or floating rate notes. For the avoidance of doubt, U.S. Dollar LIBOR-Based
Instrument does not include instruments for which a Defendant (or a Defendant’s subsidiaries or
affiliates) does not pay interest based upon any U.S. Dollar LIBOR rate, such as corporate or
municipal bonds issued by non-Defendants. Nor does it include instruments that include only a
term, provision, or obligation requiring the purchaser to pay interest based upon the U.S. Dollar
LIBOR rate, such as business, home, student or car loans, or credit cards.” Id. § 2(pp).
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7. The Court’s certification of the Class as provided herein is without prejudice to, or
waiver of the rights of, any defendant to contest certification of any other class proposed in these
actions (i.e., the actions included in the above-captioned multi-district litigation). The Court’s
findings in this Final Judgment and Order shall have no effect on the Court’s order certifying for
class treatment OTC Plaintiffs’ antitrust claims or any certification order that may be issued in this
action in the future. The findings that follow in §§ 8-9 are limited to this particular order and are
made only in the context of this particular settlement.
8. The Court finds that the requirements of Rule 23 are satisfied solely for the purpose
of effectuating the Settlement as follows:
a. Pursuant to Rule 23(a)(1), the Court determines that the members of the
Class are so numerous that their joinder before the Court would be
impracticable;
b. Pursuant to Rule 23(a)(2), the Court determines that OTC Plaintiffs have
alleged one or more questions of fact or law common to the Class;
□□ Pursuant to Rule 23(a)(3), the Court determines that OTC Plaintiffs’ claims
are typical of the claims of the Class;
d. Pursuant to Rule 23(a)(4), the Court determines that OTC Plaintiffs will
fairly and adequately protect the interests of the Class;
Pursuant to Rule 23(b)(3), the Court determines that common questions of
law and fact predominate over questions affecting only individual members;
and
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fh Pursuant to Rule 23(b)(3), the Court determines that a class resolution is
superior to other available methods for the fair and efficient adjudication of
this action.
9. If the Effective Date® does not occur with respect to the Settlement because of the
failure of a condition that affects the Settlement, this certification of the corresponding Settlement
Class shall be deemed null and void as to the parties subject to the relevant Settlement without the
need for further action by the Court or Rabobank, Lloyds, RBC, and Portigon.
IV. CLASS COUNSEL
10. Pursuant to Rule 23(g) of the Federal Rules of Civil Procedure, and solely for
settlement purposes, the following firms are designated as settlement class counsel (“Class
Counsel”) for the Class:
HAUSFELD LLP SUSMAN GODFREY L.L.P.
888 16th Street, N.W., Suite 300 1301 Avenue of the Americas, 32nd Floor
Washington, DC 20006 New York, NY 10019
Tel: 202-540-7200 Tel: 212-336-8334
Pursuant to § 6(a) of the Settlement Agreement: “The Effective Date of Settlement shall be the
date when all of the following events shall have occurred and shall be conditioned on the
occurrence of all of the following events: (i) The contribution to the Settlement Fund has been
made pursuant to this Agreement; (ii) Entry of the Preliminary Approval Order; (iii) Final approval
by the Court of the settlement set forth in this Agreement, following Class Notice and the Fairness
Hearing; (iv) No Party has exercised his, her, or its rights to terminate this Agreement pursuant to
Paragraphs 10(c) or 13(a); and (v) Entry by the Court of a Final Judgment and Order of Dismissal,
and the Final Judgment and Order of Dismissal becomes final, or, in the event that the Court enters
an Alternative Judgment and neither Class Plaintiffs nor any Settling Defendant elects to terminate
this Agreement, and such Alternative Judgment becomes final.” Jd. § 6(a).
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V. FINAL APPROVAL OF CLASS NOTICE
Mi Upon review of the record, the Court finds that the Class Notice? constituted due,
adequate, and sufficient notice of the Settlement and was the best notice practicable under the
circumstances and satisfied the requirements of Federal Rules of Civil Procedure 23(c)(2)(B) and
23(e)(1), due process, and any other applicable law. Therefore, the Class Notice is finally
approved.
VI. OTHER PROVISIONS
12. The Court further finds that Rabobank, Lloyds, RBC, and Portigon have complied
with the obligations imposed by the Class Action Fairness Act of 2005, 28 U.S.C. § 1715.
13. The Court approves and directs the implementation of all the terms of the
Settlement.
Class Notice is defined in the Settlement Agreement as: “The Notice and Summary Notice,
collectively.” /d. 2(f). The Settlement Agreement define the “Notice” as “The Notice of Proposed
Settlement of Class Action to be provided to the Class as provided in this Agreement and the
Preliminary Approval Order” and the “Summary Notice” as “The summary notice of proposed
settlement and hearing for publication.” Jd. 4] 2(w), 2(Il). The Class Notice is described in detail
in OTC Plaintiffs’ Memorandum of Law in Support of their Motion for an Order Approving Joint
Notice Plan for Settlement with Rabobank, Lloyds, RBC, and Portigon, ECF No. 3699, and
Declaration of Steven Weisbrot, ECF No. 3700.
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14. Except as to any individual claim of those Persons who have validly and timely
requested exclusion from the Class (“Opt-Outs”),!° all Released Parties!! and Releasing Parties!”
are bound by this Final Judgment and Order and by the Settlement Agreement.
15. | The Court dismisses the OTC Action, as well as all of the Released Claims, !
against any of the Released Parties by the Releasing Parties, with prejudice. The Parties are to bear
The Opt-Outs to the Rabobank, Lloyds, RBC, and Portigon Settlement are listed in Exhibit A to
this Order.
'' Pursuant to § 2(ff) of the Settlement Agreement, “Released Parties” are defined as: “Settling
Defendants, and each of their respective past or present direct and indirect parents (including
holding companies), subsidiaries, affiliates, associates (including, but not limited to, all as defined
or used in SEC Rule 12b-2, 17 C.F.R. § 240.12b-2, promulgated pursuant to the Securities
Exchange Act of 1934), joint ventures, predecessors, successors, and each of their respective
current and former officers, directors, employees, members, agents, attorneys, insurers, legal or
other representatives, trustees, heirs, executors, administrators, advisors, and assigns. Released
Parties does not include: (i) any of the other Defendants that are unaffiliated with Settling
Defendants; or (ii) any other Person unaffiliated with Settling Defendants formerly named as a
party in the OTC Action.” ECF No. 3696-1 4j 2(ff).
Pursuant to § 2(gg) of the Settlement Agreement “Releasing Parties” are defined as:
“Individually and collectively, Class Plaintiffs and each OTC Class Member, on behalf of
themselves and any of their respective past or present officers, directors, stockholders, agents,
employees, legal representatives, partners, associates, trustees, beneficiaries, beneficial owners,
parents, subsidiaries, divisions, affiliates, heirs, executors, administrators, purchasers,
predecessors, successors, and assigns, whether or not they object to the settlement set forth in this
Agreement and whether or not they make a claim for payment from the Net Settlement Fund.” Jd.
2(gg).
' Pursuant to § 2(ee) of the Settlement Agreement “Released Claims” are defined as: “Any and
all manner of claims, causes of action, cross-claims, counter-claims, charges, liabilities, demands,
judgments, suits, obligations, debts, setoffs, rights of recovery, or liabilities for any obligations of
any kind whatsoever (however denominated), whether class or individual, in law or equity or
arising under constitution, statute, regulation, ordinance, contract, or otherwise in nature, for fees,
costs, penalties, fines, debts, expenses, attorneys’ fees, and damages, whenever incurred, and
liabilities of any nature whatsoever (including joint and several), known or unknown, suspected or
unsuspected, accrued or unaccrued, asserted or unasserted, arising from or relating in any way to
any conduct alleged or that could have been alleged in and arising from the factual predicate of
the OTC Action; provided, however, that Released Claims does not include (1) claims concerning
Eurodollar futures contracts or options arising from or relating in any way to the conduct alleged
in the Exchange-Based Plaintiffs’ Action; (2) claims concerning U.S. Dollar LIBOR-Based Debt
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their own costs, except as otherwise provided in the Settlement, provided that such dismissal shall
not affect, in any way, the right of the Releasing Parties to pursue claims, if any, outside the scope
of the Released Claims.
16. Any Opt-Outs that have timely and validly requested exclusion from the Class and
are hereby excluded from that Class, are not bound by this Final Judgment and Order as it relates
to the Settlement, and may not make any claim or receive any benefit from that Settlement, whether
monetary or otherwise.
□□□ Upon the Effective Date, the Releasing Parties: (a) shall be deemed to have hereby
fully and irrevocably waived, released, relinquished, and discharged all Released Claims against
the Released Parties, regardless of whether such Releasing Party executes and delivers a proof of
claim; (b) shall be forever enjoined from prosecuting in any forum any Released Claim against
any of the Released Parties; and (c) agree and covenant not to sue any of the Released Parties on
the basis of any Released Claims or to assist any third party in commencing or maintaining any
suit against any Released Party related in any way to any Released Claims.
Securities that were not issued or sold directly to the claimant by a Defendant (or its subsidiaries
or affiliates) arising from or relating to conduct that was alleged in the Non-OTC Bondholder
Action; (3) claims arising solely under foreign law related to transactions entirely outside the
United States; or (4) claims to enforce any of the terms of this Agreement. Additionally, excluded
from the release are any claims that OTC Plaintiffs or any absent class members may have arising
out of the purchase, sale or ownership of any U.S. Dollar LIBOR-linked instruments that were
issued by a non-panel bank or which were not directly sold to a claimant by or purchased from a
Defendant (or its subsidiaries or affiliates). For the avoidance of doubt, Released Claims does not
include claims relating to or arising out of the purchase of non-U.S. Dollar LIBOR-Based
Instruments or any other claims that do not arise out of the factual predicate of the OTC Action,
such as a claim to complete the settlement of, or otherwise enforce the terms of, a U.S. Dollar
LIBOR-Based Instrument.” /d. § 2(ee). This term is subject to the limitations in {| 19-20 infra.
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18. This Final Judgment and Order shall not affect, in any way, the right of the OTC
Plaintiffs or OTC Class Members to pursue claims, if any, outside the scope of the Released
Claims.
19. The Settlement, acts performed in furtherance of the Settlement and/or documents
executed in furtherance of the Settlement may not be deemed or used as evidence of an admission
or other statement supporting: (a) the validity of any claim made by OTC Plaintiffs, OTC Class
Members, or Class Counsel (including the appropriateness of class certification); (b) any
wrongdoing or liability of the Released Parties; or (c) any fault or omission of the Released Parties
in any court, administrative agency, or other proceeding.
20. The Settlement shall not be offered or be admissible in evidence against Released
Parties in any action or proceeding, except in an action or proceeding that is in furtherance of the
Settlement’s terms or brought to enforce its terms. Notwithstanding the foregoing, the Settlement
may be filed in an action to enforce or interpret the terms of the respective Settlement and any
other documents executed in connection with the performance of the agreements embodied therein,
The Released Parties may file the Settlement and/or this Final Judgment and Order in any action
that may be brought against them in order to support a defense or counterclaim based on the
principles of res judicata, collateral estoppel, full faith and credit, release, good faith settlement,
judgment bar, or reduction or any other theory of claim preclusion or issue preclusion or similar
defense or counterclaim.
21. Any order entered regarding the motion for attorneys’ fees and expenses in this
action shall in no way disturb or affect this Final Judgment and Order and shall be considered
separate from this Final Judgment and Order.
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22. If this Final Judgment and Order is set aside, materially modified, or overturned by
this Court or on appeal, and is not fully reinstated on further appeal, this Final Judgment and Order
shall be deemed vacated and shall have no force or effect whatsoever. In the event a Settlement is
terminated in accordance with its terms, is vacated, is not approved, or the Effective Date fails to
occur for any reason, then the Parties shall be deemed to have reverted to their respective status as
of the Execution Date without prejudice and shall comply with all applicable provisions of the
Settlement Agreement including, the provisions of paragraphs 9(b) and 13(c).
23. Without affecting the finality of this Final Judgment and Order in any way, this
Court hereby retains exclusive continuing jurisdiction over: (a) implementation of the Settlement
and any award or distribution of monies under the claims-made Settlement; (b) hearing and
determining applications for attorneys’ fees, costs, expenses, and service awards to the OTC
Plaintiffs; and (c) all parties hereto for the purpose of construing, enforcing, and administering the
Settlement.
24. To the extent permitted by law, the Court bars claims against the Released Parties
for contribution or indemnification (however denominated) for all or a portion of any amounts
paid or awarded in the OTC Action by way of any settlement, judgment, or otherwise by any of
the following:
a. Any of the other Defendants currently named in the OTC Action;
b. Any other Person'* formerly named as a party in the OTC Action; or
4 Serhenenr Asawement defities “Person(s)” as: “An individual, corporation, limited liability
corporation, professional corporation, limited liability partnership, partnership, limited
partnership, association, joint stock company, estate, legal representative, trust, unincorporated
association, municipality, state, state agency, any entity that is a creature of any state, any
government or any political subdivision, authority, office, bureau or agency of any government,
and any business or legal entity, and any spouses, heirs, predecessors, successors, representatives,
or assignees of the foregoing.” Jd. § 2(bb).
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□□ Any other Person subsequently added or joined as a party in the OTC
Action.
25. To the extent permitted by law, the Court bars claims by the Released Parties for
contribution or indemnification (however denominated) for all or a portion of any amounts paid or
awarded in the OTC Action by way of any settlement, judgment or otherwise against any of the
following:
a. Any of the other Defendants currently named in the OTC Action;
b. Any other Person formerly named as a party in the OTC Action; or
Any other Person subsequently added or joined as a party in the OTC
Action.
26. There is no just reason for delay in the entry of this Final Judgment and Order, and
immediate entry by the Clerk of the Court is expressly directed pursuant to Rule 54(b) of the
Federal Rules of Civil Procedure.
IT IS SO ORDERED.
pATED:Yj Chu) 2023 how Lee. 2
HON. NAOMI REICE BUCHWALD
UNITED STATES DISTRICT JUDGE
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EXHIBIT A
Rabobank, Lloyds, RBC, and Portigon Settlement
Requests for Exclusion
|__| Federal National Mortgage Association (“Fannie Mac”) SSS
2 National Credit Union Administration Board as Liquidating Agent of US
Central Federal Credit Union, Western Corporate Federal Credit Union,
Members United Corporate Federal Credit Union, Southwest Corporate
Federal Credit Union, and Constitution Cooperate Federal Credit Union
“NCUA Parties”
4 The City of Philadelphia (“The City”) and The Pennsylvania
Intergovernmental Cooperation Authority (““PICA”
5 Federal Deposit Insurance Corporation as Receiver for:
a. Amcore Bank, N.A.
b. AmTrust Bank
c. California National Bank
d. Colonial Bank
e. Corus Bank, N.A.
f. Guaranty Bank
g. Imperial Capital Bank
h. Indy Mac Bank, F.S.B.
i. Integra Bank, N.A.
j. Lydian Private Bank
k. Pacific National Bank
1. Park National Bank
m. R-G Premier Bank of Puerto Rico
n. San Diego National Bank
o. Silverton Bank, N.A.
p. Superior Bank
q. United Commercial Bank
r. United Western Bank
s. Washington Mutual Bank
t. _Westernbank Puerto Rico
| __6 __| The Federal Home Loan Mortgage Corporation (“Freddie Mac”)
The City of Houston does not request exclusion as to the settlement between the proposed OTC
Class and Defendants Rabobank, Lloyds and Portigon.
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| eerie tome
the Successor Agency to the Richmond Community Redevelopment Agency
collectively, “Richmond”)!®
Schwab Entities:
a. The Charles Schwab Corporation
b. Charles Schwab Bank, N.A.
c. Charles Schwab & Co., Inc.
d. Schwab Money Market Fund, a series of The Charles Schwab Family
of Funds
□□ Schwab Value Advantage Money Fund, a series of The Charles Schwab
Family of Funds
f. Schwab Retirement Advantage Money Fund, a series of The Charles
Schwab Family of Funds
g. Schwab Investor Money Fund, a series of The Charles Schwab Family
of Funds
h. Schwab Cash Reserves, a series of The Charles Schwab Family of
Funds
i. Schwab Advisor Cash Reserves, a series of The Charles Schwab
Family of Funds
j. Schwab U.S. Dollar Liquid Assets Fund, a series of Charles Schwab
Worldwide Funds ple
k. Schwab Short-Term Bond Market Fund, a former series of Schwab
Investments
1. Schwab Total Bond Market Fund, a former series of Schwab
Investments
m. Schwab YieldPlus Fund, a former series of Schwab Investments
n. Schwab YieldPlus Fund Liquidation Trust
'® Richmond does not request exclusion as to the settlement between the proposed OTC Class and
Defendants Rabobank, Lloyds and Portigon.
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