X0405 TA-1/A 0000735286 XXXXXXXX 084-00772 true LIVE SEC VANGUARD GROUP INC 385385 100 Vanguard Boulevard M39 Malvern PA 19355-2900 N 610-669-1000 Y 2525 Water Ridge Parkway 1 North Falls Plaza Charlotte NC 28217 14321 North Northsight Blvd Scottsdale AZ 85260 7900 Windrose Avenue Plano TX 75024 Y Y Bank of New York Mellon /TA 085-05006 101 BARCLAY ST NEW YORK NY 10286 JP Morgan Chase Bank NA 085-11399 4 NEW YORK PLAZA NEW YORK TX 10004 State Street Bank & Trust Co /TA 085-05003 1776 HERITAGE DRIVE JOHN ADAMS BUILDING NORTH QUINCY MA 02171 N Corporation Amy NMN Gutmann 06/30/2006 Director NA true 02/22/2022 Andre Francois Perold 12/31/2004 Director NA true Francis Joseph Loughrey 10/01/2009 Director NA true Michael Thomas Rollings 06/06/2006 Managing Director NA true Mark NMN Loughridge 03/22/2012 Director NA true Scott Charles Malpass 03/22/2012 Director NA true Peter Frederick Volanakis 12/01/2008 Director NA true Mortimer Joseph Buckley 01/31/2003 Chief Executive Officer, Director NA true Chris Davis McIsaac 01/07/2012 Managing Director NA true John Thomas Marcante 03/21/2013 Managing Director NA true 11/18/2022 Anne Elizabeth Robinson 09/22/2016 General Counsel NA true John Edward Schadl 03/18/2019 Chief Compliance Officer NA true 11/30/2022 Karin Ann Risi 05/28/2015 Managing Director NA true Thomas Mark Rampulla 05/28/2015 Managing Director NA true 12/29/2023 John Mark James 01/01/2017 Managing Director NA true Gregory NMN Davis 07/31/2017 Managing Director NA true Sarah Bloom Raskin 07/31/2017 Director NA true Deanna Marie Mulligan 07/31/2017 Director NA true Joseph Patrick Brennan 09/27/2018 Chief Risk Officer NA true Lauren Marie Valente 07/25/2020 Managing Director NA true Matthew John Benchener 12/04/2020 Managing Director NA true David Anthony Thomas 07/22/2021 Director NA true Nitin NMN Tandon 09/01/2021 Managing Director NA true Tara Lynn Bunch 11/18/2021 Director NA true Emerson U. Fullwood 01/01/2008 Director NA true Jacqueline Mary Angell 11/30/2022 Chief Compliance Officer NA true Grant Fergus Reid 07/20/2023 Director NA true Amma Acheampomaa Boateng 12/30/2023 Managing Director NA true Lubos NMN Pastor 01/01/2024 Director NA true N N N N N N N N N N N Y Vanguard Advisors, Inc Comm. of Pennsylvania, Dept. of Banking and Securities v. Vanguard Advisors, Inc 12/20/2017 Commonwealth of Pennsylvania Department of Banking and Securities; Pennsylvania As a result of an administrative error, Vanguard Advisors, Inc. did not immediately update an investment advisor representative's registration to reflect Pennsylvania as the representative's new place of employment following the representative's move from Arizona to Pennsylvania. Vanguard Advisors, Inc. self-identified the issue. Entry of Consent Order and Agreement to pay an administrative assessment in the amount of $23,480.00. Vanguard Marketing Corporation (VMC) ACCEPTANCE, WAIVER, AND CONSENT (AWC) NO. 2020066956001 11/04/2022 Financial Industry Regulatory Authority (FINRA) FINRA alleges that Vanguard Marketing Corporation violated FINRA Rules 2360(b)(23)(A) and 2010 by accepting a client' options exercise instructions on May 22, 2020, after the 5:30 pm cutoff time, and FINRA Rules 3110 and 2010 by failing to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with the requirements for handling option exercise instructions after the exercise cut-off time. Without admitting or denying FINRA's allegations, Vanguard Marketing Corporation agreed to the imposition of a censure fine in the amount of $50,000.00. Vanguard Marketing Corporation (VMC) ACCEPTANCE, WAIVER, AND CONSENT (AWC) No. 2020068469601 05/25/2023 Financial Industry Regulatory Authority (FINRA) FINRA found that from Nov. 2019 to Sept. 2020, VMC overstated projected yield and projected annual income for nine money market funds on certain brokerage account statements. FINRA also found that from at least Oct. 2019 to June 2021, certain account statements inaccurately presented market appreciation/depreciation and investment returns. The aforementioned errors did not affect the actual market yield paid to customers or holdings information displayed on customer statements a have been resolved. FINRA also found that the firm failed to reasonably supervise its account statements by failing to time address customer reports of inaccuracies. FINRA found that VMC violated FINRA rules 2210, 3110, 4511 and 2010. Without admitting or denying the allegations or findings, VMC agreed to the imposition of a censure and a fine in the amount of $800,000, VMC's Letter of Acceptance, Waiver, and Consent was accepted by FINRA on May 25, 2023. N N N N N Y Vanguard Marketing Corporation (VMC) ACCEPTANCE, WAIVER, AND CONSENT (AWC) No. C05040058 07/20/2004 National Association of Securities Dealers (NASD) NASD alleges in two instances, prices paid to customers to liquidate municipal securities positions were below fair market value. By relying on broker's bids to determine FMV, VMC failed to ensure transactions were executed at fair and reasonable prices. NASD accepted VMC's Letter of Acceptance, Waiver and Consent. Firm agreed to imposition of censure and fine in the amount of $10,000, and restitution to two customers in the amount of $9443, plus interest. Vanguard Marketing Corporation (VMC) ACCEPTANCE, WAIVER, AND CONSENT (AWC) No. 2013038325801 03/06/2015 Financial Industry Regulatory Authority (FINRA) FINRA alleges that VMC violated article V, section 2(c) of the FINRA by-laws, FINRA rule 2010 and NASD rule 3010(a) by failing to file form U4 amendments for 60 reportable events, and by failing to timely file form U4 amendments for 20 report events. FINRA accepted VMC's AWC. VMC agreed to the imposition of a censure, a $350,000 fine, production of a VMC retained independent consultant's report, and certification of VMC's implementation of improvements outlined in the independent consultant's report. N N Y N/A Capital Market Investigation Department, Investigation Team 3-1076 09/24/2020 South Korean Financial Services Commission, South Korea The South Korean Financial Supervisory Service claimed that on three occasions from 2018 to 2019 The Vanguard Group Inc. (VGI), engaged in the sale of two Korean listed securities without corresponding ownership of the positions, a practice which is prohibited under South Korean law. On September 24, 2020, the South Korean Financial Services Commission imposed an administrative fine in the amount $104,575 (KRW 120 Million) on VGI, related to the above. Vanguard Investments Australia Ltd (VIA) ASIC Infringement Notices Section 12GX 11/11/2022 Australian Securities and Investments Commission (ASIC) Act 2001 VIA self-identified an error in the product disclosure statements (PDS) to the Australian Securities and Investments Commission for the Vanguard International Shares Select Exclusions Index Funds and issued a supplementary PDS for e of the affected funds, correcting the error, and communicating the update to investors. The notices resulted in a total fine of $27,116 USD ($39,960 AUD). The notices were paid in full on 12/1/2022. Vanguard Investments Australia Ltd (VIA) Financial Markets Authority (FMA), New Zealand, Formal Warning 03/27/2023 FMA, New Zealand The FMA issued a formal warning to VIA for failing to lodge the required notice on the New Zealand Companies Office Disclose Register within the required five-day timeframe regarding the three infringement notices issued by Australian Securities and Investments Commission (ASIC). A formal warning was issued by FMA. N N N Jacqueline Angell 610-503-3877 Chief Compliance Officer 01/05/2024