Iowa Public Employees’ Retirement System, et al. v. Bank of America Corp., et al.

If you, directly or through an agent, entered into Stock Loan Transactions with Goldman Sachs, Morgan Stanley, JPMorgan, UBS, Credit Suisse, or Bank of America Merrill Lynch (collectively, “Prime Broker Defendants”), direct or indirect parents, subsidiaries, or divisions of the Prime Broker Defendants in the United States from January 7, 2009 through August 22, 2023, inclusive, you may be eligible to receive a payment from the settlements in this Action (combined, the “Settlements”).

The first settlement is with the “Credit Suisse Settling Defendants,” which are: Credit Suisse Group AG; Credit Suisse AG; Credit Suisse Securities (USA) LLC; Credit Suisse First Boston Next Fund, Inc.; and Credit Suisse Prime Securities Services (USA) LLC. This settlement agreement is referred to in this website as the “Credit Suisse Settlement Agreement.” The “Settlement Class Period” for the Credit Suisse Settlement Agreement is January 7, 2009 through January 20, 2022, inclusive.

The second settlement is with the “Newly Settling Defendants,” which are Goldman Sachs & Co. LLC and Goldman Sachs Execution & Clearing, L.P. (merged into Goldman Sachs & Co. LLC as of June 12, 2017) (collectively, the “Goldman Sachs Defendants”); J.P. Morgan Securities LLC; J.P. Morgan Prime, Inc.; J.P. Morgan Strategic Securities Lending Corp.; and JPMorgan Chase Bank, N.A. (collectively, the “JPMorgan Defendants”); Morgan Stanley; Morgan Stanley Capital Management, LLC; Morgan Stanley & Co. LLC; Morgan Stanley Distribution, Inc.; Prime Dealer Services Corp.; and Strategic Investments I, Inc. (collectively, the “Morgan Stanley Defendants”); UBS AG; UBS Americas Inc.; UBS Securities LLC; and UBS Financial Services Inc. (collectively, the “UBS Defendants”); and EquiLend LLC; EquiLend Europe Limited; and EquiLend Holdings LLC (collectively, the “EquiLend Defendants”). This settlement agreement is referred to in this website as the “New Settlement Agreement.” The “Settlement Class Period” for the New Settlement Agreement is January 7, 2009 through August 22, 2023, inclusive. Collectively, the Credit Suisse Settling Defendants and the Newly Settling Defendants are referred to on this website as the “Settling Defendants.”

Combined, the Settling Defendants have paid Settlement Funds totaling $580,008,750 ($81,000,000 for the Credit Suisse Settlement and $499,008,750 for the New Settlement). The action is Iowa Public Employees’ Retirement System, et al., v. Bank of America Corp. et al., Case No. 17-cv-6221 (KPF-SLC) (the “Action”).

PLEASE READ THIS WEBSITE AND THE NOTICE CAREFULLY. This website and the Notice explain important rights you may have, including the possible receipt of cash from the Settlements. If you are a member of the Settlement Class, your legal rights will be affected whether or not you act.

The Frequently Asked Questions page of this website has more information on your rights as a Settlement Class Member in this Action.

Your Legal Rights and Options in These Settlements

Do Nothing	If you do nothing in connection with the Settlements, you will receive no payment from the Settlements and you will be bound by past and any future Court rulings, including rulings on the Settlements, if approved, and the settlement releases. See FAQ 15.
File a Claim Form	The only way to receive your share of either or both of the Net Settlement Funds is to complete and electronically submit a timely and valid Claim Form to the Settlement Administrator online no later than July 8, 2024, or to mail your completed Claim Form so that it is postmarked no later than July 8, 2024. See FAQ 9.
Exclude Yourself from the Settlements	If you wish to exclude yourself from either or both of the Settlement Classes for the Settlements, you must submit by U.S. first class mail or deliver a written request to the Settlement Administrator so that it is received by June 7, 2024. If you exclude yourself from a Settlement, you will not be bound by that Settlement, if approved, or that Settlement’s release, and you will not be eligible for any payment from that Settlement. See FAQs 16-20.
Object to the Settlements	If you wish to object to either or both of the Settlements, you must file a written objection with the Court and serve copies on Class Counsel and Settling Defendants’ counsel so that the written objection is received by June 7, 2024. You must be and remain within a Settlement Class in order to object to that Settlement. See FAQs 21 and 22.
Participate at the Fairness Hearing	You may ask the Court for permission to speak about either or both Settlements at the Fairness Hearing by including such a request in your written objection, which you must file with the Court and serve on Class Counsel and Settling Defendants’ counsel so that it is received by June 7, 2024. The Fairness Hearing is scheduled for September 4, 2024. See FAQs 25-27.
Appear through an Attorney	You may enter an appearance through your own counsel at your own expense. See FAQ 27.