Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 1 of 29

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8 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 8 of 29 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA If you made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage on the same property, and you were not a member of the settlement class in Banks, et al. v. JP Morgan Chase Bank, N.A., your rights could be affected and you could receive payment from a class-action settlement. A federal court authorized this Notice. This is not a solicitation from a lawyer. If you are a Settlement Class Member, there are deadlines for you to object to the settlement or exclude yourself from the settlement, and your legal rights are affected whether you act or don t act. Please Read This Notice Carefully. This Notice provides information about a proposed class action settlement (the Settlement ) concerning allegations that JPMorgan Chase Bank, N.A. d/b/a Chase ( Chase ) violated the California Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq., and the California Unfair Competition Law, Cal. Bus. & Prof. Code et seq., by collecting and accepting payments on junior mortgages after foreclosing nonjudicially on a first mortgage secured by the same property. Chase denies the allegations and denies any wrongdoing whatsoever. The Court has not ruled on the merits of Plaintiff s claims or Chase s defenses and by entering into the Settlement, Chase has not conceded the truth or validity of any of the claims against it. The Settlement is with JPMORGAN CHASE BANK, N.A. See Question 3 for more detail. The Settlement covers borrowers on 309 loans that were not included in a prior settlement of claims in Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.). See Question 5 for more detail. The Court in charge of this case still has to decide whether to approve the Settlement. SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT NO CLAIM FORM REQUIRED EXCLUDE YOURSELF FROM THE SETTLEMENT OBJECT TO THE SETTLEMENT GO TO A HEARING TAX CONSEQUENCES This Settlement does not require a Settlement Class Member to make a claim in order to recover a payment under the Settlement. The amount you will receive, provided you do not opt out of the Settlement, will be based on the amount you paid to Chase on your junior mortgage following the foreclosure since December See Questions Excluding yourself means you get no payment. Excluding yourself is the only way you can ever be a part of any other case against JPMorgan Chase Bank, N.A., or its respective parents and affiliates, about the claims being resolved by this Settlement. See Question 11. Write to the Court about why you don t like the Settlement. You cannot object in order to ask the Court for a higher payment for yourself personally, although you can object to any other terms that apply generally to the Settlement Class. See Questions The Court will hold a hearing for the Settlement to decide whether to approve it. You may ask to speak in Court about the fairness of the Settlement. See Question 16. Cancellation of debt may have tax consequences. See Page

9 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 9 of 29 WHAT THIS NOTICE CONTAINS BASIC INFORMATION Why did I get this Notice? What is this lawsuit about? What is a class action and who are the Parties? Why is there a Settlement?... 3 WHO IS IN THE SETTLEMENT? How do I know if I am part of the Settlement? What is the Class definition?... 3 THE SETTLEMENT BENEFITS WHAT YOU GET What does the proposed Settlement provide? How will payments be calculated? When will payments be issued? How will my payment be sent? What am I giving up to get a payment or stay in the Settlement?... 4 EXCLUDING YOURSELF FROM THE SETTLEMENT ( OPTING OUT ) How do I get out of the Settlement?... 5 THE LAWYERS REPRESENTING YOU Do I have a lawyer in this case? How will the lawyers be paid? Are the Class Representatives being paid?... 5 OBJECTING TO THE SETTLEMENT How do I tell the Court that I don t like the Settlement? What s the difference between objecting and excluding yourself ( opting-out )?... 6 THE COURT S SETTLEMENT HEARING When and where will the Court decide whether to approve the Settlement? Do I have to come to the Settlement Hearing? May I speak at the Settlement Hearing?... 7 GETTING MORE INFORMATION How do I get more information about the Settlement?... 7 NOTICE REGARDING POTENTIAL TAX CONSEQUENCES

10 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 10 of WHY DID I GET THIS NOTICE? BASIC INFORMATION You were sent this Notice because you are a Settlement Class Member. Settlement Class Members are California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the settlement class in the action entitled Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.) and related actions subject to the separate prior class action settlement in that case ( Banks ). As a Settlement Class Member, you have a right to know about the proposed class action Settlement, and about all your options, before the Court decides whether to give final approval to the Settlement. See Question 5 for more details about who is in the Settlement Class. 2. WHAT IS THIS LAWSUIT ABOUT? Plaintiff claims that Chase violated California law by collecting and accepting payments on junior mortgages after it nonjudicially foreclosed on a first mortgage secured by the same property. Specifically, Plaintiff alleges that Chase violated the Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq., and the Unfair Competition Law, Cal. Bus. & Prof. Code et seq. Chase denies the allegations and denies any wrongdoing whatsoever. The Court has not ruled on the merits of Plaintiff s claims or Chase s defenses. 3. WHAT IS A CLASS ACTION AND WHO ARE THE PARTIES? In a class action lawsuit, one or more people, called class representatives, sue on behalf of people who have similar claims. All these people together are a class or class members. One court resolves the issues for all class members, except for those who choose to exclude themselves from the Class (see Question 11). The Settlement Class Representative involved in this Settlement is a Chase borrower who, like you, made payments to Chase on a junior mortgage after Chase nonjudicially foreclosed on a senior mortgage secured by the same property. The Settlement Class Representative is Glenn Pacheco. The Settling Defendant is JPMorgan Chase Bank, N.A. Together, the Settlement Class Representative and the Settling Defendant are called the Parties. 4. WHY IS THERE A SETTLEMENT? Chase denies all liability in the lawsuit. The Court did not decide in favor of any party on the legal claims being resolved here. Instead, all sides agreed to a Settlement, which avoids the risk and cost of a trial, but still provides compensation to the people affected. The Settlement Class Representative and Class Counsel think that the Settlement is in the best interests of the Settlement Class Members and that the proposed Settlement is fair, adequate, and reasonable. WHO IS IN THE SETTLEMENT? 5. HOW DO I KNOW IF I AM PART OF THE SETTLEMENT? WHAT IS THE CLASS DEFINITION? Chase has identified 309 junior mortgage loans on which payments were made to Chase since December 2011 following its nonjudicial foreclosure of a senior mortgage secured by the same California property ( Challenged Payments ) where the borrower was not a settlement class member in Banks. If you received this notice, you are the borrower for one of those 309 loans and eligible for a cash payment and the other benefits of the Settlement, if you do not opt out. See Question 7 for more details about how payment amounts will be calculated. Settlement Class Definition: The class is defined in the Settlement Agreement as California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the Banks settlement class. Excluded from the Settlement Class are (a) the Judge to whom the Action is assigned and any member of the Judge s staff and immediate family members, (b) any person who is not a borrower on any of the 309 loans that Chase identified in connection with discovery in this case, and (c) all persons who validly request exclusion from the Settlement Class

11 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 11 of 29 THE SETTLEMENT BENEFITS WHAT YOU GET 6. WHAT DOES THE PROPOSED SETTLEMENT PROVIDE? Settlement Fund. Chase will pay $1,500,000 to cover all costs of settlement including: (1) cash payments to Settlement Class Members; (2) an award of attorneys fees and costs to Class Counsel, in an amount not to exceed twenty-five percent (25%) of the Settlement Fund, as approved by the Court; (3) a service award to Plaintiff in an amount not to exceed a cash payment of $5,000, as approved by the Court; (4) the costs of notice and administration of the Settlement; and (5) under certain circumstances as described below, a charitable contribution. Settlement Awards. Settlement Class Members will receive cash awards calculated as set forth below. See Question 7. This amount is subject to pro rata adjustment depending on the final amount of costs of the Settlement and the number of Settlement Class Members who exclude themselves from the Settlement. Chase will also permanently forego collection of any remaining balances on the junior mortgages described above. No Portion of the Settlement Fund Will Return to Chase. Any money remaining in the Settlement Fund after paying cash awards to Settlement Class Members, attorneys fees and costs to Class Counsel, any service award to Plaintiff and the costs of notice and administration of the Settlement, or money that the Settlement Administrator is unable to distribute for lack of a current and valid mailing address, will be paid either: (1) in a second distribution, on a pro-rata basis, to those Settlement Class Members who have cashed their settlement checks; or (2) if there are not enough funds to justify a second distribution, or if there are funds remaining after a second distribution, the remaining funds will be donated to a charitable organization proposed by Plaintiff and approved by the Court. No portion of the Settlement Fund will be returned to Chase. 7. HOW WILL PAYMENTS BE CALCULATED? According to Chase s records, Settlement Class Members paid a total of $1,344,191 in Challenged Payments. The cut-off for the Challenged Payments is December 12, 2011, because of the statute of limitations. To settle this case, Chase will pay a total of $1,500,000. The total Settlement Fund pays for administrative and attorneys fees and costs, with the remainder to be distributed to Settlement Class Members pro rata based on what they paid Chase over the Class Period. 8. WHEN WILL PAYMENTS BE ISSUED? Your Payment will be sent within 30 days after the Effective Date of the Settlement. The Effective Date of the Settlement is the date upon which all decisions in the case are final, including any appeals by any objectors. If there are objectors who appeal, the Effective Date may be more than a year away. 9. HOW WILL MY PAYMENT BE SENT? Your payment will be sent to you via First Class mail to the best address the Settlement Administrator can find for you based on Chase s records. You may update your address using the Address Verification Form included with this notice. You also must submit the Address Verification form if you believe you are a member of the Settlement Class and did not receive the Mail Notice. 10. WHAT AM I GIVING UP TO GET A PAYMENT OR STAY IN THE SETTLEMENT? Unless you exclude yourself from the Settlement (see Question 11), you will be in the Settlement Class. This means that all of the Court s orders will apply to you and legally bind you, and that you cannot sue or be part of any other lawsuit against the Settling Defendant (or any of the other related entities listed as Released Parties in the Settlement Agreement) about the legal claims resolved in the Settlement. The Release provides, in pertinent part: Plaintiff and each and all Settlement Class Members (defined as California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the settlement class in the action entitled Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.) and related actions subject to the separate prior class action settlement in that case), on behalf of themselves and their respective heirs, executors, administrators, representatives, agents, attorneys, partners, successors, predecessors-in-interest, assigns and any other holders of their Settlement Class Loan (together, the Releasing Parties ), will be deemed to have fully released and forever discharged Chase and each and all of its present, former and future direct and indirect parent companies, affiliates, subsidiaries, agents, successors, and/or predecessors in interest and all of the aforementioneds respective officers, directors, employees, attorneys, shareholders, agents, assigns and vendors (together, the Released Parties ) from any and all rights, duties, obligations, claims, actions, causes of action or liabilities, including but not limited to claims for violations of the California Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq. ( Rosenthal Act ), the - 4 -

12 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 12 of 29 federal Fair Debt Collection Practices Act, 15 U.S.C et seq., the California Unfair Competition Law, Cal. Bus. & Prof. Code et seq. ( UCL ), and Cal. Civ. Proc. Code 580b and 580d, whether arising under local, state or federal law, whether by Constitution, statute, contract, rule, regulation, any regulatory promulgation (including, but not limited to, any opinion or declaratory ruling), common law or equity, whether known or unknown, suspected or unsuspected, asserted or unasserted, foreseen or unforeseen, actual or contingent, liquidated or unliquidated, punitive or compensatory as of the date of the Final Approval Order, that were alleged or could have been alleged in the Action, whether the claims are brought directly by or on behalf of any Settlement Class Member in an individual or class action, representative action or in any other capacity, with respect to any form of relief, including, without limitation, damages, restitution, disgorgement, penalties and injunctive or declaratory relief (the Released Claims ). Talk to Class Counsel (see Question 12) or your own lawyer if you have questions about what the release means and what it covers. EXCLUDING YOURSELF FROM THE SETTLEMENT ( OPTING OUT ) 11. HOW DO I GET OUT OF THE SETTLEMENT? If you ask to be excluded from the Settlement (also called opting out of the Settlement), you will not get any money or other benefits from the Settlement. If you exclude yourself, you will not be legally bound by the Settlement. Unless you exclude yourself from the Settlement, you give up any right to sue (or continue to sue) the Released Parties for the claims that are resolved by the Settlement. To exclude yourself from the Settlement, you must send an exclusion request to the Settlement Administrator. To be valid, an exclusion request must: (1) be signed by the Settlement Class Member who is requesting exclusion; (2) include the full name, address and applicable Chase account number(s) of the Settlement Class Member requesting exclusion; and (3) include the following statement: I/we request to be excluded from the settlement in the Pacheco action, or materially similar language. No request for exclusion will be valid unless all of the information described above is included. Except in cases of legal incapacity as to which legally binding evidence must be provided to the Settlement Administrator no Settlement Class Member, or any person acting on behalf of or in concert or participation with that Settlement Class Member, may exclude any other Settlement Class Member from the Settlement Class. To be valid, you must mail your exclusion request postmarked no later than July 17, 2017 to the Settlement Administrator at: Pacheco v. JP Morgan Chase Bank c/o GCG P.O. Box 9349 Dublin, OH DO I HAVE A LAWYER IN THIS CASE? THE LAWYERS REPRESENTING YOU Yes. The Court has appointed the law firms listed below to represent you and other Settlement Class Members in the Settlement. These lawyers are called Class Counsel. You will not be charged for services performed by Class Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense. If you want to contact Class Counsel about the Settlement, they can be reached at: LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman peter@peterfredmanlaw.com HAGENS BERMAN SOBOL SHAPIRO LLP Thomas E. Loeser (Seattle, WA) toml@hbsslaw.com TRN LAW ASSOCIATES Tiffany R. Norman tiffany@trnlaw.com 13. HOW WILL THE LAWYERS BE PAID? ARE THE CLASS REPRESENTATIVES BEING PAID? Attorneys Fees. Class Counsel will ask the Court to for an award (a) of twenty-five percent (25%) of the Settlement Fund to them for attorneys fees and (b) for reimbursement of their litigation expenses. Any award of attorneys fees and expenses will be paid through the Settlement Fund. Class Counsel also will ask the Court to approve a cash payment of up to $5,000 to Plaintiff, which will be paid through the Settlement Fund, for his services as Class Representative. The Court may award less than these amounts

13 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 13 of 29 OBJECTING TO THE SETTLEMENT 14. HOW DO I TELL THE COURT THAT I DON T LIKE THE SETTLEMENT? If you re a Settlement Class Member, you can object to the proposed Settlement if you don t like it. You cannot object if you have excluded yourself from the Settlement (see Question 11). You can object if you don t like any part of the proposed Settlement, including the way payments were calculated, or the request for attorneys fees and expenses. You can give reasons why you think the Court should not approve any or all of these items, and the Court will consider your views. You CANNOT object in order to ask the Court for a higher payment for yourself personally. The Court can only approve or disapprove the Settlement, but cannot change how much money you are personally eligible to receive from the Settlement. This means that if the Court agrees with your objection, the case won t be settled unless the parties agree to change the terms and the Court approves those changes. To object, you must (a) mail your objection to Class Counsel and Chase s counsel and (b) file it with the Court. To be timely, your objection must be mailed to Class Counsel and Chase s counsel so that it is postmarked by August 24, 2017, and must be filed with the Court by no later than August 24, 2017, at the following addresses: Class Counsel LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman 125 University Ave., Suite 102 Berkeley, CA Chase s Counsel STROOCK & STROOCK & LAVAN LLP Julia B. Strickland Benjamin G. Diehl 2029 Century Park East Los Angeles, CA The Court Clerk of the Court/Judge Donato Phillip Burton Federal Building & United States Courthouse 450 Golden Gate Avenue San Francisco, CA Note: You may mail your objection to the Court, but it must be received by the Court and filed by August 24, See for more information on how to object to the Settlement. You must include the following information in your objection: Your full name, address, telephone number, and signature. The specific reasons why you object to the Settlement. The name, address, bar number, and telephone number of your counsel, if you re represented by an attorney. If you are represented by an attorney, he/she or it must comply with all applicable laws and rules for filing pleadings and documents in the Northern District of California. State whether you intend to appear at the Fairness Hearing, either in person or through counsel. Unless you submit a proper and timely written objection, according to the above requirements, you will not be allowed to object to the Settlement or appear at the Final Approval Hearing. (See Questions 16 18). 15. WHAT S THE DIFFERENCE BETWEEN OBJECTING AND EXCLUDING YOURSELF ( OPTING-OUT )? Objecting is simply telling the Court that you don t like something about the Settlement. Excluding yourself or opting-out is telling the Court that you don t want to be part of the Settlement. If you exclude yourself then you cannot object to the Settlement because you are not a part of it. If you object, and the Court approves the Settlement anyway, you will still get your benefits under the Settlement and be legally bound by the Settlement. THE COURT S SETTLEMENT HEARING 16. WHEN AND WHERE WILL THE COURT DECIDE WHETHER TO APPROVE THE SETTLEMENT? The Court will hold a Settlement Hearing (also known as a Final Approval Hearing or Fairness Hearing ) to decide whether to finally approve the proposed Settlement. The Settlement Hearing will be on September 14, 2017, at 10:00 am, before Judge James Donato, United States District Court for the Northern District of California, 450 Golden Gate Avenue, San Francisco, CA If you want to attend the Settlement Hearing, keep in mind that the date and/or time may be changed after the time of this Notice, so you should check the Settlement website before making travel plans. At the Settlement Hearing, the Court will consider whether the Settlement and all of its terms are adequate, fair, and reasonable. If there are objections, the Court will consider them. The Court may also decide how much to award Class Counsel for fees and expenses

14 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 14 of 29 At or after the Settlement Hearing, the Court will decide whether to finally approve the proposed Settlement. There may be appeals after that. There is no set timeline for either the Court s final approval decision, or for any appeals that may be brought from that decision, so it is impossible to know exactly when the Settlement will become final. The Court may change deadlines listed in this Notice without further notice to the Class. To keep up on any changes in the deadlines, please contact Class Counsel or review the website. 17. DO I HAVE TO COME TO THE SETTLEMENT HEARING? No. Class Counsel will answer any questions asked by the Court. If you send an objection, you don t have to come to Court to talk about it. So long as you mailed your written objection on time and complied with the other requirements for a proper objection, the Court will consider it. You may also pay another lawyer to attend, but it s not required. 18. MAY I SPEAK AT THE SETTLEMENT HEARING? Yes. If you submitted a proper written objection to the Settlement, you or your lawyer may, at your own expense, speak at the Settlement Hearing. To do so, you must follow the procedures set out in Question 14. You must also file a Notice of Intent to Appear, which must be mailed to Class Counsel and Chase s counsel and postmarked no later than August 24, It must be filed with the Clerk of the Court by that same date. If you intend to have a lawyer appear on your behalf, your lawyer must enter a written notice of appearance of counsel with the Clerk of the Court no later than August 24, GETTING MORE INFORMATION 19. HOW DO I GET MORE INFORMATION ABOUT THE SETTLEMENT? This Notice summarizes the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement, available at YOU MAY OBTAIN ADDITIONAL INFORMATION BY: CALLING. Call Class Counsel at (510) to ask questions and receive copies of documents. ING. Class Counsel at peter@peterfredmanlaw.com. WRITING. Send your questions by mail to Class Counsel LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman 125 University Ave., Suite 102 Berkeley, CA HAGENS BERMAN SOBOL SHAPIRO LLP Thomas E. Loeser 1918 Eighth Avenue, Suite 3300 Seattle, WA TRN LAW ASSOCIATES Tiffany R. Norman 654 Sacramento St., Second Floor San Francisco, CA VISITING THE SETTLEMENT WEBSITE. where you will find answers to common questions about the Settlement, plus other information to help you. REVIEWING LEGAL DOCUMENTS. You can review the legal documents that have been filed with the Clerk of Court in this case at: Phillip Burton Federal Building & United States Courthouse 450 Golden Gate Avenue San Francisco, CA Some of the legal documents are also located on the Settlement Website. ACCESSING PACER. You can access the Court dockets in this case through the Court s Public Access to Court Electronic Records (PACER) system at An access charge may apply. PLEASE DO NOT CALL THE JUDGE OR THE COURT CLERK TO ASK QUESTIONS ABOUT THE LAWSUIT, THE SETTLEMENT, OR THIS NOTICE. The Court will not respond to letters or telephone calls. If you wish to address the Court, you must file an appropriate pleading or motion with the clerk of the court in accordance with the Court s usual procedures. DATED: May 26, 2017 BY ORDER OF THE COURT - 7 -

15 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 15 of 29 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA NOTICE REGARDING POTENTIAL TAX CONSEQUENCES The benefits provided to Settlement Class Members may have adverse tax consequences, which may vary based on the individual circumstances of the particular Settlement Class Member and other factors. Settlement Class Members may have in the past, or might in the future, receive a Form 1099 from Chase relating to the cancellation of debt associated with a Settlement Class Loan. The issuance of a Form 1099 does not reflect a determination that a taxable event occurred or that taxes are due as a result of this Settlement or any other event. If you receive a Form 1099, you should consult a tax professional for advice regarding the significance of the Form. Plaintiff, Chase and their attorneys cannot provide tax advice to Settlement Class Members, who should seek advice from tax professionals based on their individualized circumstances. As a general matter the position of Plaintiff and Class Counsel is: (1) this Settlement does not result in income to a taxpayer because it does not require cancellation of debt; (2) cancellation of debt resulting from the Settlement would not create taxable income because enforceability of the debt was disputed prior to this Settlement (see Zarin v. C.I.R., 916 F.2d 110, 116 (3d Cir. 1990); J.H. McKnight Ranch, Inc. v. Franchise Tax Bd., 110 Cal. App. 4th 978, (2003)); and (3) any cancellation of debt income accrued upon the foreclosure of the property to which the Settlement Class Member s mortgage was attached. Chase takes no position on this matter. PLAINTIFF, CHASE AND THEIR ATTORNEYS CANNOT PROVIDE TAX ADVICE TO SETTLEMENT CLASS MEMBERS. SETTLEMENT CLASS MEMBERS SEEKING ADVICE REGARDING POTENTIAL TAX CONSEQUENCES OF THE SETTLEMENT SHOULD CONSULT THEIR OWN TAX PROFESSIONAL

16 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 16 of 29 EXHIBIT B

17 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 17 of 29 JCB ADDRESS VERIFICATION FORM *P-JCB-POC/1* If you believe you are a part of the Settlement Class and are concerned that Chase may not have your current address, please use the following form to update your address. When submitting your address update, please include as much information as possible to help Class Counsel and Chase locate your records. You also must submit this form if you believe you are a member of the Settlement Class and did not receive the Mail Notice. IF THE CLASS NOTICE WAS SENT TO YOUR CORRECT ADDRESS, YOU DO NOT NEED TO SUBMIT THIS FORM Your Current Full Name: bbbbbbbbbbbbbbbbbbbbbbbbbbbb Your Current Mailing Address: bbbbbbbbbbbbbbbbbbbbbbbbbbbb bbbbbbbbbbbbbbbbbbbbbbbbbbbb City: State: ZIP: bbbbbbbbbbbbbbbbbbbbbbbbbbbb Your Current Address: bbbbbbbbbbbbbbbbbbbbbbbbbbbb Your Chase Account Number: wwwwwwwwwwwwwww Any other name that could have been associated with your junior mortgage: bbbbbbbbbbbbbbbbbbbbbbbbbbbb If mailing this form, please send it by mail to the Settlement Administrator at: Pacheco v. JP Morgan Chase Bank c/o GCG PO Box 9349 Dublin, OH AFFIRMATION: By signing below, I affirm that I am a California borrower who: (1) on after December 12, 2011, made payments to JPMorgan Chase Bank, N.A. on a junior mortgage following JPMorgan Chase Bank, N.A. s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) is not a member of the settlement class in the action entitled Banks et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.). I understand that the accuracy of my affirmation and the Address Verification Form may be researched and verified by JPMorgan Chase Bank, N.A. and/or the Settlement Administrator. I understand that the only Settlement Class Members entitled to a recovery in this action are the certain persons whom Chase has identified on a Class List as the borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same California property; and (2) are not members of the Banks settlement class. I understand that if I am not on that Class List, then I will not be eligible to participate in this Settlement. Signature: If you need to submit an Address Verification Form, you are encouraged to do so online at (click on Update My Address ). Date: ww / ww / wwww qq1 Name (Please Print): bbbbbbbbbbbbbbbbbbbbbbbbbbbb QUESTIONS? VISIT To view GCG's Privacy Notice, please visit

18 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 18 of 29 EXHIBIT C

19 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 19 of 29 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA If you made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage on the same property, and you were not a member of the settlement class in Banks, et al. v. JP Morgan Chase Bank, N.A., your rights could be affected and you could receive payment from a class-action settlement. A federal court authorized this Notice. This is not a solicitation from a lawyer. If you are a Settlement Class Member, there are deadlines for you to object to the settlement or exclude yourself from the settlement, and your legal rights are affected whether you act or don t act. This Amended Notice Extends the Deadlines. Please Read This Notice Carefully. This Amended Notice provides information about a proposed class action settlement (the Settlement ) concerning allegations that JPMorgan Chase Bank, N.A. d/b/a Chase ( Chase ) violated the California Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq., and the California Unfair Competition Law, Cal. Bus. & Prof. Code et seq., by collecting and accepting payments on junior mortgages after foreclosing nonjudicially on a first mortgage secured by the same property. Chase denies the allegations and denies any wrongdoing whatsoever. The Court has not ruled on the merits of Plaintiff s claims or Chase s defenses and by entering into the Settlement, Chase has not conceded the truth or validity of any of the claims against it. The Settlement is with JPMORGAN CHASE BANK, N.A. See Question 3 for more detail. The Settlement covers borrowers on 309 loans that were not included in a prior settlement of claims in Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.). See Question 5 for more detail. The Court in charge of this case still has to decide whether to approve the Settlement. SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT NO CLAIM FORM REQUIRED EXCLUDE YOURSELF FROM THE SETTLEMENT OBJECT TO THE SETTLEMENT GO TO A HEARING TAX CONSEQUENCES This Settlement does not require a Settlement Class Member to make a claim in order to recover a payment under the Settlement. The amount you will receive, provided you do not opt out of the Settlement, will be based on the amount you paid to Chase on your junior mortgage following the foreclosure since December See Questions Excluding yourself means you get no payment. Excluding yourself is the only way you can ever be a part of any other case against JPMorgan Chase Bank, N.A., or its respective parents and affiliates, about the claims being resolved by this Settlement. See Question 11. Write to the Court about why you don t like the Settlement. You cannot object in order to ask the Court for a higher payment for yourself personally, although you can object to any other terms that apply generally to the Settlement Class. See Questions The Court will hold a hearing for the Settlement to decide whether to approve it. You may ask to speak in Court about the fairness of the Settlement. See Question 16. Cancellation of debt may have tax consequences. See Page

20 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 20 of 29 WHAT THIS NOTICE CONTAINS BASIC INFORMATION Why did I get this Notice? What is this lawsuit about? What is a class action and who are the Parties? Why is there a Settlement?... 3 WHO IS IN THE SETTLEMENT? How do I know if I am part of the Settlement? What is the Class definition?... 3 THE SETTLEMENT BENEFITS WHAT YOU GET What does the proposed Settlement provide? How will payments be calculated? When will payments be issued? How will my payment be sent? What am I giving up to get a payment or stay in the Settlement?... 4 EXCLUDING YOURSELF FROM THE SETTLEMENT ( OPTING OUT ) How do I get out of the Settlement?... 5 THE LAWYERS REPRESENTING YOU Do I have a lawyer in this case? How will the lawyers be paid? Are the Class Representatives being paid?... 5 OBJECTING TO THE SETTLEMENT How do I tell the Court that I don t like the Settlement? What s the difference between objecting and excluding yourself ( opting-out )?... 6 THE COURT S SETTLEMENT HEARING When and where will the Court decide whether to approve the Settlement? Do I have to come to the Settlement Hearing? May I speak at the Settlement Hearing?... 7 GETTING MORE INFORMATION How do I get more information about the Settlement?... 7 NOTICE REGARDING POTENTIAL TAX CONSEQUENCES

21 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 21 of WHY DID I GET THIS NOTICE? BASIC INFORMATION You were sent this Notice because you are a Settlement Class Member. Settlement Class Members are California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the settlement class in the action entitled Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.) and related actions subject to the separate prior class action settlement in that case ( Banks ). As a Settlement Class Member, you have a right to know about the proposed class action Settlement, and about all your options, before the Court decides whether to give final approval to the Settlement. See Question 5 for more details about who is in the Settlement Class. 2. WHAT IS THIS LAWSUIT ABOUT? Plaintiff claims that Chase violated California law by collecting and accepting payments on junior mortgages after it nonjudicially foreclosed on a first mortgage secured by the same property. Specifically, Plaintiff alleges that Chase violated the Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq., and the Unfair Competition Law, Cal. Bus. & Prof. Code et seq. Chase denies the allegations and denies any wrongdoing whatsoever. The Court has not ruled on the merits of Plaintiff s claims or Chase s defenses. 3. WHAT IS A CLASS ACTION AND WHO ARE THE PARTIES? In a class action lawsuit, one or more people, called class representatives, sue on behalf of people who have similar claims. All these people together are a class or class members. One court resolves the issues for all class members, except for those who choose to exclude themselves from the Class (see Question 11). The Settlement Class Representative involved in this Settlement is a Chase borrower who, like you, made payments to Chase on a junior mortgage after Chase nonjudicially foreclosed on a senior mortgage secured by the same property. The Settlement Class Representative is Glenn Pacheco. The Settling Defendant is JPMorgan Chase Bank, N.A. Together, the Settlement Class Representative and the Settling Defendant are called the Parties. 4. WHY IS THERE A SETTLEMENT? Chase denies all liability in the lawsuit. The Court did not decide in favor of any party on the legal claims being resolved here. Instead, all sides agreed to a Settlement, which avoids the risk and cost of a trial, but still provides compensation to the people affected. The Settlement Class Representative and Class Counsel think that the Settlement is in the best interests of the Settlement Class Members and that the proposed Settlement is fair, adequate, and reasonable. WHO IS IN THE SETTLEMENT? 5. HOW DO I KNOW IF I AM PART OF THE SETTLEMENT? WHAT IS THE CLASS DEFINITION? Chase has identified 309 junior mortgage loans on which payments were made to Chase since December 2011 following its nonjudicial foreclosure of a senior mortgage secured by the same California property ( Challenged Payments ) where the borrower was not a settlement class member in Banks. If you received this notice, you are the borrower for one of those 309 loans and eligible for a cash payment and the other benefits of the Settlement, if you do not opt out. See Question 7 for more details about how payment amounts will be calculated. Settlement Class Definition: The class is defined in the Settlement Agreement as California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the Banks settlement class. Excluded from the Settlement Class are (a) the Judge to whom the Action is assigned and any member of the Judge s staff and immediate family members, (b) any person who is not a borrower on any of the 309 loans that Chase identified in connection with discovery in this case, and (c) all persons who validly request exclusion from the Settlement Class

22 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 22 of 29 THE SETTLEMENT BENEFITS WHAT YOU GET 6. WHAT DOES THE PROPOSED SETTLEMENT PROVIDE? Settlement Fund. Chase will pay $1,500,000 to cover all costs of settlement including: (1) cash payments to Settlement Class Members; (2) an award of attorneys fees and costs to Class Counsel, in an amount not to exceed twenty-five percent (25%) of the Settlement Fund, as approved by the Court; (3) a service award to Plaintiff in an amount not to exceed a cash payment of $5,000, as approved by the Court; (4) the costs of notice and administration of the Settlement; and (5) under certain circumstances as described below, a charitable contribution. Settlement Awards. Settlement Class Members will receive cash awards calculated as set forth below. See Question 7. This amount is subject to pro rata adjustment depending on the final amount of costs of the Settlement and the number of Settlement Class Members who exclude themselves from the Settlement. Chase will also permanently forego collection of any remaining balances on the junior mortgages described above. No Portion of the Settlement Fund Will Return to Chase. Any money remaining in the Settlement Fund after paying cash awards to Settlement Class Members, attorneys fees and costs to Class Counsel, any service award to Plaintiff and the costs of notice and administration of the Settlement, or money that the Settlement Administrator is unable to distribute for lack of a current and valid mailing address, will be paid either: (1) in a second distribution, on a pro-rata basis, to those Settlement Class Members who have cashed their settlement checks; or (2) if there are not enough funds to justify a second distribution, or if there are funds remaining after a second distribution, the remaining funds will be donated to a charitable organization proposed by Plaintiff and approved by the Court. No portion of the Settlement Fund will be returned to Chase. 7. HOW WILL PAYMENTS BE CALCULATED? According to Chase s records, Settlement Class Members paid a total of $1,344,191 in Challenged Payments. The cut-off for the Challenged Payments is December 12, 2011, because of the statute of limitations. To settle this case, Chase will pay a total of $1,500,000. The total Settlement Fund pays for administrative and attorneys fees and costs, with the remainder to be distributed to Settlement Class Members pro rata based on what they paid Chase over the Class Period. 8. WHEN WILL PAYMENTS BE ISSUED? Your Payment will be sent within 30 days after the Effective Date of the Settlement. The Effective Date of the Settlement is the date upon which all decisions in the case are final, including any appeals by any objectors. If there are objectors who appeal, the Effective Date may be more than a year away. 9. HOW WILL MY PAYMENT BE SENT? Your payment will be sent to you via First Class mail to the best address the Settlement Administrator can find for you based on Chase s records. You may update your address using the Address Verification Form included with this notice. You also must submit the Address Verification form if you believe you are a member of the Settlement Class and did not receive the Mail Notice. 10. WHAT AM I GIVING UP TO GET A PAYMENT OR STAY IN THE SETTLEMENT? Unless you exclude yourself from the Settlement (see Question 11), you will be in the Settlement Class. This means that all of the Court s orders will apply to you and legally bind you, and that you cannot sue or be part of any other lawsuit against the Settling Defendant (or any of the other related entities listed as Released Parties in the Settlement Agreement) about the legal claims resolved in the Settlement. The Release provides, in pertinent part: Plaintiff and each and all Settlement Class Members (defined as California borrowers who: (1) on or after December 12, 2011, made payments to Chase on a junior mortgage following Chase s nonjudicial foreclosure of a senior mortgage secured by the same property; and (2) are not members of the settlement class in the action entitled Banks, et al. v. JP Morgan Chase Bank, N.A., Case No. RG (Cal. Super. Ct.) and related actions subject to the separate prior class action settlement in that case), on behalf of themselves and their respective heirs, executors, administrators, representatives, agents, attorneys, partners, successors, predecessors-in-interest, assigns and any other holders of their Settlement Class Loan (together, the Releasing Parties ), will be deemed to have fully released and forever discharged Chase and each and all of its present, former and future direct and indirect parent companies, affiliates, subsidiaries, agents, successors, and/or predecessors in interest and all of the aforementioneds respective officers, directors, employees, attorneys, shareholders, agents, assigns and vendors (together, the Released Parties ) from any and all rights, duties, obligations, claims, actions, causes of action or liabilities, including but not limited to claims for violations of the California Rosenthal Fair Debt Collection Practices Act, Cal. Civ. Code 1788 et seq. ( Rosenthal Act ), the federal Fair Debt Collection Practices Act, 15 U.S.C et seq., the California Unfair Competition Law, Cal. Bus. & Prof

23 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 23 of 29 Code et seq. ( UCL ), and Cal. Civ. Proc. Code 580b and 580d, whether arising under local, state or federal law, whether by Constitution, statute, contract, rule, regulation, any regulatory promulgation (including, but not limited to, any opinion or declaratory ruling), common law or equity, whether known or unknown, suspected or unsuspected, asserted or unasserted, foreseen or unforeseen, actual or contingent, liquidated or unliquidated, punitive or compensatory as of the date of the Final Approval Order, that were alleged or could have been alleged in the Action, whether the claims are brought directly by or on behalf of any Settlement Class Member in an individual or class action, representative action or in any other capacity, with respect to any form of relief, including, without limitation, damages, restitution, disgorgement, penalties and injunctive or declaratory relief (the Released Claims ). Talk to Class Counsel (see Question 12) or your own lawyer if you have questions about what the release means and what it covers. EXCLUDING YOURSELF FROM THE SETTLEMENT ( OPTING OUT ) 11. HOW DO I GET OUT OF THE SETTLEMENT? If you ask to be excluded from the Settlement (also called opting out of the Settlement), you will not get any money or other benefits from the Settlement. If you exclude yourself, you will not be legally bound by the Settlement. Unless you exclude yourself from the Settlement, you give up any right to sue (or continue to sue) the Released Parties for the claims that are resolved by the Settlement. To exclude yourself from the Settlement, you must send an exclusion request to the Settlement Administrator. To be valid, an exclusion request must: (1) be signed by the Settlement Class Member who is requesting exclusion; (2) include the full name, address and applicable Chase account number(s) of the Settlement Class Member requesting exclusion; and (3) include the following statement: I/we request to be excluded from the settlement in the Pacheco action, or materially similar language. No request for exclusion will be valid unless all of the information described above is included. Except in cases of legal incapacity as to which legally binding evidence must be provided to the Settlement Administrator no Settlement Class Member, or any person acting on behalf of or in concert or participation with that Settlement Class Member, may exclude any other Settlement Class Member from the Settlement Class. To be valid, you must mail your exclusion request postmarked no later than October 20, 2017 to the Settlement Administrator at: Pacheco v. JP Morgan Chase Bank c/o GCG P.O. Box 9349 Dublin, OH DO I HAVE A LAWYER IN THIS CASE? THE LAWYERS REPRESENTING YOU Yes. The Court has appointed the law firms listed below to represent you and other Settlement Class Members in the Settlement. These lawyers are called Class Counsel. You will not be charged for services performed by Class Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense. If you want to contact Class Counsel about the Settlement, they can be reached at: LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman peter@peterfredmanlaw.com HAGENS BERMAN SOBOL SHAPIRO LLP Thomas E. Loeser (Seattle, WA) toml@hbsslaw.com TRN LAW ASSOCIATES Tiffany R. Norman tiffany@trnlaw.com 13. HOW WILL THE LAWYERS BE PAID? ARE THE CLASS REPRESENTATIVES BEING PAID? Attorneys Fees. Class Counsel will ask the Court to for an award (a) of twenty-five percent (25%) of the Settlement Fund to them for attorneys fees and (b) for reimbursement of their litigation expenses. Any award of attorneys fees and expenses will be paid through the Settlement Fund. Class Counsel also will ask the Court to approve a cash payment of up to $5,000 to Plaintiff, which will be paid through the Settlement Fund, for his services as Class Representative. The Court may award less than these amounts

24 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 24 of 29 OBJECTING TO THE SETTLEMENT 14. HOW DO I TELL THE COURT THAT I DON T LIKE THE SETTLEMENT? If you re a Settlement Class Member, you can object to the proposed Settlement if you don t like it. You cannot object if you have excluded yourself from the Settlement (see Question 11). You can object if you don t like any part of the proposed Settlement, including the way payments were calculated, or the request for attorneys fees and expenses. You can give reasons why you think the Court should not approve any or all of these items, and the Court will consider your views. You CANNOT object in order to ask the Court for a higher payment for yourself personally. The Court can only approve or disapprove the Settlement, but cannot change how much money you are personally eligible to receive from the Settlement. This means that if the Court agrees with your objection, the case won t be settled unless the parties agree to change the terms and the Court approves those changes. To object, you must (a) mail your objection to Class Counsel and Chase s counsel and (b) file it with the Court. To be timely, your objection must be mailed to Class Counsel and Chase s counsel so that it is postmarked by January 26, 2018, and must be filed with the Court by no later than January 26, 2018, at the following addresses: Class Counsel LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman 125 University Ave., Suite 102 Berkeley, CA Chase s Counsel STROOCK & STROOCK & LAVAN LLP Julia B. Strickland Benjamin G. Diehl 2029 Century Park East Los Angeles, CA The Court Clerk of the Court/Judge Donato Phillip Burton Federal Building & United States Courthouse 450 Golden Gate Avenue San Francisco, CA Note: You may mail your objection to the Court, but it must be received by the Court and filed by January 26, See for more information on how to object to the Settlement. You must include the following information in your objection: Your full name, address, telephone number, and signature. The specific reasons why you object to the Settlement. The name, address, bar number, and telephone number of your counsel, if you re represented by an attorney. If you are represented by an attorney, he/she or it must comply with all applicable laws and rules for filing pleadings and documents in the Northern District of California. State whether you intend to appear at the Fairness Hearing, either in person or through counsel. Unless you submit a proper and timely written objection, according to the above requirements, you will not be allowed to object to the Settlement or appear at the Final Approval Hearing. (See Questions 16 18). 15. WHAT S THE DIFFERENCE BETWEEN OBJECTING AND EXCLUDING YOURSELF ( OPTING-OUT )? Objecting is simply telling the Court that you don t like something about the Settlement. Excluding yourself or opting-out is telling the Court that you don t want to be part of the Settlement. If you exclude yourself then you cannot object to the Settlement because you are not a part of it. If you object, and the Court approves the Settlement anyway, you will still get your benefits under the Settlement and be legally bound by the Settlement. THE COURT S SETTLEMENT HEARING 16. WHEN AND WHERE WILL THE COURT DECIDE WHETHER TO APPROVE THE SETTLEMENT? The Court will hold a Settlement Hearing (also known as a Final Approval Hearing or Fairness Hearing ) to decide whether to finally approve the proposed Settlement. The Settlement Hearing will be on February 8, 2018 before Judge James Donato, United States District Court for the Northern District of California, 450 Golden Gate Avenue, San Francisco, CA If you want to attend the Settlement Hearing, keep in mind that the date and/or time may be changed after the time of this Notice, so you should check the Settlement website before making travel plans. At the Settlement Hearing, the Court will consider whether the Settlement and all of its terms are adequate, fair, and reasonable. If there are objections, the Court will consider them. The Court may also decide how much to award Class Counsel for fees and expenses

25 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 25 of 29 At or after the Settlement Hearing, the Court will decide whether to finally approve the proposed Settlement. There may be appeals after that. There is no set timeline for either the Court s final approval decision, or for any appeals that may be brought from that decision, so it is impossible to know exactly when the Settlement will become final. The Court may change deadlines listed in this Notice without further notice to the Class. To keep up on any changes in the deadlines, please contact Class Counsel or review the website. 17. DO I HAVE TO COME TO THE SETTLEMENT HEARING? No. Class Counsel will answer any questions asked by the Court. If you send an objection, you don t have to come to Court to talk about it. So long as you mailed your written objection on time and complied with the other requirements for a proper objection, the Court will consider it. You may also pay another lawyer to attend, but it s not required. 18. MAY I SPEAK AT THE SETTLEMENT HEARING? Yes. If you submitted a proper written objection to the Settlement, you or your lawyer may, at your own expense, speak at the Settlement Hearing. To do so, you must follow the procedures set out in Question 14. You must also file a Notice of Intent to Appear, which must be mailed to Class Counsel and Chase s counsel and postmarked no later than January 26, It must be filed with the Clerk of the Court by that same date. If you intend to have a lawyer appear on your behalf, your lawyer must enter a written notice of appearance of counsel with the Clerk of the Court no later than January 26, GETTING MORE INFORMATION 19. HOW DO I GET MORE INFORMATION ABOUT THE SETTLEMENT? This Notice summarizes the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement, available at YOU MAY OBTAIN ADDITIONAL INFORMATION BY: CALLING. Call Class Counsel at (510) to ask questions and receive copies of documents. ING. Class Counsel at peter@peterfredmanlaw.com. WRITING. Send your questions by mail to Class Counsel LAW OFFICE OF PETER FREDMAN PC Peter B. Fredman 125 University Ave., Suite 102 Berkeley, CA HAGENS BERMAN SOBOL SHAPIRO LLP Thomas E. Loeser 1918 Eighth Avenue, Suite 3300 Seattle, WA TRN LAW ASSOCIATES Tiffany R. Norman 654 Sacramento St., Second Floor San Francisco, CA VISITING THE SETTLEMENT WEBSITE. where you will find answers to common questions about the Settlement, plus other information to help you. REVIEWING LEGAL DOCUMENTS. You can review the legal documents that have been filed with the Clerk of Court in this case at: Phillip Burton Federal Building & United States Courthouse 450 Golden Gate Avenue San Francisco, CA Some of the legal documents are also located on the Settlement Website. ACCESSING PACER. You can access the Court dockets in this case through the Court s Public Access to Court Electronic Records (PACER) system at An access charge may apply. PLEASE DO NOT CALL THE JUDGE OR THE COURT CLERK TO ASK QUESTIONS ABOUT THE LAWSUIT, THE SETTLEMENT, OR THIS NOTICE. The Court will not respond to letters or telephone calls. If you wish to address the Court, you must file an appropriate pleading or motion with the clerk of the court in accordance with the Court s usual procedures. DATED: September 8, 2017 BY ORDER OF THE COURT - 7 -

26 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 26 of 29 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA NOTICE REGARDING POTENTIAL TAX CONSEQUENCES The benefits provided to Settlement Class Members may have adverse tax consequences, which may vary based on the individual circumstances of the particular Settlement Class Member and other factors. Settlement Class Members may have in the past, or might in the future, receive a Form 1099 from Chase relating to the cancellation of debt associated with a Settlement Class Loan. The issuance of a Form 1099 does not reflect a determination that a taxable event occurred or that taxes are due as a result of this Settlement or any other event. If you receive a Form 1099, you should consult a tax professional for advice regarding the significance of the Form. Plaintiff, Chase and their attorneys cannot provide tax advice to Settlement Class Members, who should seek advice from tax professionals based on their individualized circumstances. As a general matter the position of Plaintiff and Class Counsel is: (1) this Settlement does not result in income to a taxpayer because it does not require cancellation of debt; (2) cancellation of debt resulting from the Settlement would not create taxable income because enforceability of the debt was disputed prior to this Settlement (see Zarin v. C.I.R., 916 F.2d 110, 116 (3d Cir. 1990); J.H. McKnight Ranch, Inc. v. Franchise Tax Bd., 110 Cal. App. 4th 978, (2003)); and (3) any cancellation of debt income accrued upon the foreclosure of the property to which the Settlement Class Member s mortgage was attached. Chase takes no position on this matter. PLAINTIFF, CHASE AND THEIR ATTORNEYS CANNOT PROVIDE TAX ADVICE TO SETTLEMENT CLASS MEMBERS. SETTLEMENT CLASS MEMBERS SEEKING ADVICE REGARDING POTENTIAL TAX CONSEQUENCES OF THE SETTLEMENT SHOULD CONSULT THEIR OWN TAX PROFESSIONAL

27 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 27 of 29 EXHIBIT D

28 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 28 of 29 INVOICE INVOICE DATE 12/15/2017 PERIOD START 3/9/2017 INVOICE NUMBER THROUGH DATE 6/30/2017 Project Name: Pacheco v. JP Morgan Chase Bank Description Quantity Rate Amount Fees Notice Dissemination Printing of 20 pg. Notice 616 $1.03 $ Advanced address searches 32 $0.35 $11.20 Enter name and address records into database (hard copy) 27 $0.45 $12.15 R s 36 $1.03 $37.08 Imaging, Document Management & Storage Prep, Sort, and Scan Mail 1.2 Hrs. $69.00 Process undeliverables 47 $0.25 $11.75 Document Storage - Paper (per box/per month) 1 $1.50 $1.50 Contact Services Management of call center 2 Hrs. $ Handling of class member communications 0.9 Hrs. $51.30 Project Management 44.8 Hrs. $5, Systems Support 22.5 Hrs. $2, Quality Assurance 1.7 Hrs. $ Total Fees $9, Total Project Expenses (See Exhibit A) $ Sub Total $10, Less Reduction of Fees ($1,001.28) Grand Total $9,400.00

29 Case 3:15-cv JD Document 67-1 Filed 12/20/17 Page 29 of 29 EXHIBIT A Project Name: Pacheco v. JP Morgan Chase Bank ` Description Amount Project Expenses For the period: Mar 09, 2017 through Jun 30, 2017 Postage $ Stationery & Supplies $14.07 PACER Charges $6.70 Domain Registration $ Total $ Please Remit To : Garden City Group, LLC 1985 Marcus Avenue, Suite 200 Lake Success, NY Or- Garden City Group, LLC Operating A/C Signature Bank 900 Stewart Ave., 3rd Floor Garden City, NY ABA # A /C # Tax ID # Swift Code - SIGNUS33