The Complaint alleges that the Defendants conspired to manipulate the prices of currency trades for at least a 10 year period, resulting in billions of dollars in illegal gains. The Complaint further alleges that, through the daily use of chat rooms with revealing names such as “The Cartel,” “The Bandits’ Club,” and “The Mafia,” the Defendants communicated directly with each other to coordinate their actions in order to move the foreign exchange benchmark rates, including U.S. and Canadian dollar. This affected not only those investors who directly purchased foreign exchange instruments, but those whose investments were in funds (including mutual funds and pension funds) that dealt in foreign currency.

In Canada outside of Quebec, you are included in the Settlement Class if:

• You are a person in Canada who, between January 1, 2003 and December 31, 2013, entered into an FX Instrument either directly or indirectly through an intermediary, and/or purchased or otherwise participated in an investment or equity fund, mutual fund, hedge fund, pension fund or any other investment vehicle that entered into an FX Instrument and you did not opt-out of the lawsuit on or before December 5, 2016.

In Quebec, you are included in the Settlement Class if:

• You are a person in Quebec who, between January 1, 2003 and December 31, 2013, entered into an FX Instrument either directly or indirectly through an intermediary, and/or purchased or otherwise participated in an investment or equity fund, mutual fund, hedge fund, pension fund or any other investment vehicle that entered into an FX Instrument and you did not opt-out of the lawsuit on or before December 5, 2016.

FX Spot Transactions, Outright Forwards, FX Swaps, FX Options, FX Futures Contracts, Options on FX Futures Contracts, and other instruments traded in the FX Market.