NOTICE OF THE CLASS DISTRIBUTION PLAN. A court has authorized this notice. This is not a solicitation from a lawyer.

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1 NOTICE OF THE CLASS DISTRIBUTION PLAN A court has authorized this notice. This is not a solicitation from a lawyer. THIS NOTICE MAY AFFECT YOUR RIGHTS. PLEASE READ THIS ENTIRE NOTICE CAREFULLY. TO THE FOLLOWING CLASS: All borrowers who: (1) obtained a first trust deed-secured home loan ( loan ) from Wells Fargo Bank and/or Wells Fargo Home Mortgage (collectively, Wells Fargo ) in an amount in excess of one hundred fifty thousand dollars ($150,000); and (2) who applied for his or her loan through a Wells Fargo branch and/or office which is and/or was located within the following area: (a) within Thomas Swanson s area as that area was defined by Wells Fargo in January, 2002; and (b) either within, or within one mile (1 mile) from, an area comprised of fifty percent (50%) or more minority population, where minority population is defined as the total population of that geographic area less the population of non-hispanic whites of that geographic area, as established by the 2000 Census data; and, (3) whose loan was funded between the time period May 1, 2002 and December, On March 23, 2011, the jury returned a verdict in favor of the Class described above and against Wells Fargo in the lawsuit entitled Jones v. Wells Fargo Bank, N.A., Superior Court of the State of California, County of Los Angeles, Case No. BC The jury found that Wells Fargo had violated the Unruh Civil Rights Act by discriminating in its lending practices, in the total amount of $3,520,000. The Court entered a judgment based on the jury verdict on September 12, WHY ARE YOU RECEIVING THIS NOTICE? The purpose of this notice is to advise you of the terms of the distribution of the $3,520,000 judgment that was entered by the court in favor of the Plaintiff Class. If you are receiving this notice by mail, then you are already determined to be a borrower who fits within the class description. If you are reading this notice on the Class website, or in published print media, you may be a member of the Class if you fit within the Class description as established at trial. Read this entire notice to find out more about the suit and the cash payments that will be made from the judgment funds. If you are a member of the Plaintiff Class, this notice will affect your legal rights. WHAT IS A CLASS ACTION? Class actions are lawsuits in which the claims and rights of many people are decided in a single court proceeding, based on court findings that proceeding as a class action is a fair and efficient way to resolve similar claims of many people. Representative plaintiffs ( Class Plaintiffs or Class Representatives ) are named in the lawsuit to assert the claims of the entire Page 1 of 5

2 class. This avoids the necessity for a large number of people to file similar individual lawsuits and enables the court system to resolve similar claims in an efficient and economical way. Class actions ensure that people with similar claims are treated alike. In a class action, the court is guardian of class interests and supervises the prosecution of the class claims by class counsel to assure that the representation is adequate. Class members are not individually responsible for the costs or fees of class counsel, which are subject to court approval. DESCRIPTION OF THE LITIGATION The named plaintiffs, Opal Jones, Claudia A. Caldwell, Kalina Thomas, Vincent Jones, and C. Renae Walker Jones, filed this class action lawsuit in August, 2005, against defendants Wells Fargo Bank, N.A., and Wells Fargo Home Mortgage, Inc. (collectively, Wells Fargo ). The court certified the case as appropriate to proceed as a class action on the Plaintiffs Class claims for violation of the Unruh Civil Rights Act (Civil Code 51), but limited the case to claims for statutory damages, only. The class was certified under the class definition listed above, and class members received notice by mail or by publication, with the opportunity to opt out at that time. A jury trial began in December, 2010, to resolve the Class Plaintiffs claim against Wells Fargo. Class Plaintiffs alleged that Wells Fargo had discriminated against borrowers who applied for home loans through minority branch locations. The Class Plaintiffs alleged that the discrimination occurred by Wells Fargo precluding loan officers working at certain minority locations from using a computer program called Loan Economics, which could discount a loan. The jury was presented with a list of class loans and found in favor of the Plaintiff Class on that claim, and awarded damages in the verdict in the amount of $3,520,000. The Court entered judgment in the case on September 12, 2011, awarding the amount of the jury verdict, and postverdict interest to the date of judgment in the amount of $165,873.97, plus interest at 10% per annum from the date of the judgment. Wells Fargo filed an appeal of the judgment. The Court of Appeal affirmed the judgment on February 17, 2015, and the case was then sent back to the trial court. The Plan of Distribution had been stayed during the appeal. That stay has now been lifted, and this Notice is sent in accordance with the Plan of Distribution and the timeline it sets forth. DESCRIPTION OF THE CLASS You are a member of the Plaintiff Class in this lawsuit if you fit within the Class definition stated above at the top of this Notice and the trial list of Class loans. The geographic area referred to in the Class definition is roughly described as follows: (1) having its northern boundary defined by the I-10 freeway from the Pacific Ocean to its juncture with California Highway 60, and from there eastward by California Highway 60; (2) having its east and southeast boundary defined by the Los Angeles County line where it meets with San Bernardino and Orange Counties; and (3) having its western and southern boundary being bordered by the Pacific Ocean. The branch locations within that geographic area would include the following addresses: Page 2 of 5

3 6510 Atlantic Avenue, Bell, CA; S Bellflower Blvd., Bellflower, CA; South Avalon Blvd., Carson, CA; 506 West Torrance Blvd., Carson, CA; Gridley Road, Cerritos, CA; South Street, Cerritos, CA; 1600 S Azusa Ave., City of Industry, CA; E Colima Rd., City of Industry, CA; 5801 East Slauson Avenue, Commerce, CA; 5675 E. Telegraph Road, Commerce, CA; 5701 S. Eastern Avenue, Commerce, CA; 111 E. Compton Blvd., Compton, CA; 1902 W. Rosecrans Avenue, Compton, CA; 5899 Green Valley Circle, Culver City, CA; Jefferson Blvd., Culver City, CA; Washington Blvd., Culver City, CA; Jefferson Blvd., Culver City, CA; 9323 East Firestone Blvd., Downey, CA; 8626 Firestone Blvd., Downey, CA; 9027 Gallatin Rd., Downey, CA; 2120 E. Park Place, 1st Floor, El Segundo, CA; 1221 West Redondo Beach Blvd., Gardena, CA; 6115 Pacific Blvd., Huntington Park, CA; S Hawthorn Blvd., Hawthorne, CA; 400 South Market Street, Inglewood, CA; South Crenshaw Blvd., Inglewood, CA; Rosecrans Avenue, La Mirada, CA; 2096 North Bellflower Blvd., Long Beach, CA; 4540 Atlantic Avenue, Long Beach, CA; 4550 Atlantic Blvd., Long Beach, CA; 3950 Atlantic Ave., Long Beach, CA; 111 W Ocean Blvd., Long Beach, CA; 5030 E 2 nd St., Long Beach, CA; 4601 E 2 nd St., Long Beach, CA; 141 West Adams Blvd., Los Angeles, CA; 1968 W. Adams Blvd., Los Angeles, CA; 3800 Whittier Blvd., Los Angeles, CA; Crenshaw and Slauson, Los Angeles, CA; 3649 Stocker Street, Los Angeles, CA; 1144 E. Florence Avenue, Los Angeles, CA; 5458 E. Whittier Blvd., Los Angeles, CA; Wilshire Blvd., Los Angeles, CA; W Pico Blvd., Los Angeles, CA; W Pico Blvd., Los Angeles, CA; Palms Blvd., Los Angeles, CA; 8814 S Sepulveda Blvd., Los Angeles, CA; 1500 Rosecrans Ave., Manhattan Beach, CA; 3110 Sepulveda Blvd., Manhattan Beach, CA; W Washington Blvd., Marina Del Rey, CA; 480 Washington St., Marina Del Rey, CA; 777 West Whittier Blvd., Montebello, CA; 2101 S. Atlantic Blvd., Monterey Park, CA; 8737 E. Washington Blvd., Pico Rivera, CA; S Western Ave., Rancho Palos Verdes, CA; 301 S Pacific Coast HWY., Redondo Beach, CA; Hawthorne Blvd., Rolling Hills Estates, CA; Telegraph Road, Santa Fe Springs, CA; 2598 Cherry Ave., Signal Hill, CA; 4300 Tweedy Blvd., South Gate, CA; Hawthorne Blvd., Torrance, CA; Crenshaw Blvd., Torrance, CA; 3868 Carson St., Torrance, CA;1403 Sartoti Ave., Torrance, CA; Crenshaw Blvd., Torrance, CA; Hawthorne Blvd., Torrance, CA; 100 N Barranca St., West Covina, CA; 7202 South Greenleaf Avenue, Whittier, CA; East Whittier Blvd., Whittier, CA; East Whittier Blvd., Whittier, CA; E. Whittier Blvd., Whittier, CA; 1234 North Avalon Blvd., Wilmington, CA; Sherman Way, Van Nuys, CA. The Class does not include borrowers of home equity loans. DESCRIPTION OF THE AWARD AMOUNT AND DISTRIBUTION PLAN The total award amount is $3,520,000 plus interest. The distribution plan allows for a simple, easy to administer allocation to the Class of the total award, plus interest, after deducting service awards to the Class Representatives, and after deducting expert fees/reimbursement of costs awarded by the Court. Plaintiffs were awarded service awards in the amount of $10,000 each, plus interest, for their work on behalf of the Class. Lead Class Counsel was awarded reimbursement for experts fees and other litigations costs in the amount of $880,000, plus interest. The total net common pot would be distributed equally among all Class loans as to which either: (1) this notice is delivered by mail to a deliverable address; or (2) the borrower on a Class Loan submits a Claim Form on or before the Claim Deadline, or December 26, Page 3 of 5

4 The Class loans will be determined on the basis of Wells Fargo data. For any Class loan with co-borrowers, the co-borrowers would share jointly in the distribution amount allocated to that Class loan. Under the distribution plan, the Claims Administrator will calculate the amount of each class borrower s award, and distribute the fund by mailing checks directly to your or your coborrower s address. Your award will depend on the number of deliverable addresses for borrowers of Class loans, the number of valid Claims submitted, and whether or not you are an individual or co-borrower on a Class loan. The plan of distribution has been approved by the Court. WHO REPRESENTS THE CLASS? Lead Counsel for the Plaintiff Class is the law firm of Cappello & Noël LLP, 831 State Street, Santa Barbara, CA 93101, Tel: , Fax: OPTIONS AVAILABLE TO MEMBERS OF THE CLASS IF YOU ARE A MEMBER OF THE CLASS, YOU HAVE THE FOLLOWING OPTIONS: Option 1: You may obtain benefits. A. If you wish to obtain benefits under the Class distribution, and you have received this notice through the mail, you do not need to do anything. You are already considered to be a member of the Class. However, if you should change your address prior to distribution, you should contact the Claims Administrator at or write to the Claims Administrator at: If you change your address after receipt of this notice, you may have to submit additional forms to ensure the distribution is made to you. B. If you wish to obtain benefits under the Class distribution, and you are reading this notice on the Class website or in print media, then on or before December 26, 2015, you must submit your Claim form on-line at or complete and mail a Claim form to the following: Page 4 of 5

5 Obtain a Claim form on-line at or request a Claim form by calling the Claims Administrator at If your Claim form is not submitted on-line or postmarked by December 26, 2015, your claim will not be considered and you will not recover under the Class judgment. After the proposed distribution is final, the Claims Administrator will send each Class member who has filed a valid Claim [or who has received the notice at a deliverable address] their share of the judgment. Option 2: You may choose not to claim benefits. If you do not wish to obtain benefits under the Class distribution, and you receive this notice through the mail, you can choose not to participate in the distribution by sending written notice of your request to the Claims Administrator at the following address: Your request to be excluded from participation must be postmarked on or before December 26, The written request must include: (i) your name and address; (ii) the statement: I request not to participate in the Class distribution. I understand that I will be bound by the judgment in this litigation even though I have chosen not to participate in the distribution; (iii) the address of the property which secured your loan from Wells Fargo, if different than your address; (iv) if known, the loan number of your loan from Wells Fargo; and (v) the amount of your loan. If you do not wish to obtain benefits under the Class distribution, and you are reading this notice on the Class website or in print media, then you do not need to do anything. If you choose not to participate in the distribution, you will still be bound by the Court s final judgment and orders, and you will not be able to sue Wells Fargo on this claim. ADDITIONAL INFORMATION This notice is only a summary. If you would like more details, you may inspect the papers filed in this lawsuit during regular hours at the office of the Clerk of the Court, located at 600 S. Commonwealth Ave., Los Angeles, CA 90005, under Jones v. Wells Fargo Bank, N.A., Case No. BC If you have any questions regarding this notice, you may call the Claims Administrator at PLEASE DO NOT CONTACT THE COURT FOR INFORMATION. Page 5 of 5

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