$2.416 BILLION SETTLEMENT WITH LEHMAN ON BEHALF OF 14 INSTITUTIONAL INVESTORS

On March 17, 2017, the firm reached a settlement with the Plan Administrator for Lehman Brothers Holdings Inc. and the other Debtors in the Lehman bankruptcy proceeding on behalf of 14 institutional investor clients.  The agreement obligates Lehman to make a binding offer to the trustees of 244 RMBS trusts issued by Lehman (or into which Lehman contributed mortgages) to settle mortgage repurchase claims.  The RM BS trustees have until June 1, 2017 to accept or reject the settlement offer. If accepted by the trustees, the settlement provides for allowance of a claim in the Lehman bankruptcy proceeding in an amount to be determined by the bankruptcy court in an estimation proceeding to be conducted in October 2017.  In the estimation proceeding, Lehman has agreed to request that the trusts’ claims be allowed in the amount of $2.416 billion, where as the trustees are permitted to offer evidence and argue for a higher claim allowance.