i wanted to forward this analysis by our capital markets

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FW: BlackRock Analysis - US ETP Performance ; Week of 2/24 From: To: Date : " Fulton , Kathryn"(b )( 6 ) (b)(6) - Chair Powell's Email Address Tue, 03 Mar 2020 17:42:24 -0500 NONCONFIDENTIAL EXTERNAL Hi Jay , I wanted to forward this analysis by our capital markets team of ETP trading performance last week hope it's helpful to you and your team . All the best Kate Kathryn Managing Director Global Public Policy Group BlackRock 1401 New York Avenue, NW Washington , DC 20005 ( b )( 6 A message from BlackRock's Global Public Policy Group The week of February 24, 2020 was tumultuous for global markets . The Cboe Volatility Index ( VIX) reached 49 the highest since February 2018 while the S & P 500 had itslargest weekly decline since the 2008 global financial crisis . Despite heightenedmarket volatility and increased trading activity, exchange- traded products ( ETPs) traded with generally tight bid ask spreads, heavy volumes, and high liquidity To explore this further , we have published a new paper , entitled " High velocity markets: A case study on U.S. exchange- traded productperformance during theweek of February 24 , 2020" that looks at how U.S. exchange - traded products performed during this period of market stress . We hope you find this piece informative as you think about the role of exchange - traded products in global markets . We look forward to maintaining an active dialogue on these and other asset management - related topics . This message maycontain informationthat is confidential or privileged . If you are not the intended recipient , please advise the sender immediately and delete this message . See http://www.blackrock.com/corporate/compliance/email-disclaimers for further information . Please refer to http://www.blackrock.com/corporate/compliance/privacy-policy for more informationabout BlackRock's Privacy Policy For a list of BlackRock's office addresses worldwide , see http://www.blackrock.com/corporate/about us/ contacts- locations . © 2020 BlackRock , Inc. All rights reserved .

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Page 1: I wanted to forward this analysis by our capital markets

FW: BlackRock Analysis - US ETP Performance; Week of2/24

From:

To:

Date:

"Fulton, Kathryn" (b ) (6 )

(b) (6) - Chair Powell's EmailAddress

Tue, 03 Mar 2020 17:42:24 -0500

NONCONFIDENTIAL EXTERNAL

Hi Jay,

I wanted to forward this analysis by our capital markets team of ETP trading performance last weekhope it's helpful to you and your team .

All the bestKate

KathrynManagingDirectorGlobal Public Policy GroupBlackRock1401New York Avenue, NWWashington, DC 20005

( b ) (6

A message from BlackRock's Global Public Policy Group

Theweek of February 24, 2020 was tumultuous for global markets. The Cboe Volatility Index (VIX)reached 49 — the highestsince February 2018 whilethe S & P 500had itslargest weekly decline since the2008 global financial crisis. Despite heightenedmarket volatility and increased trading activity,exchange- traded products ( ETPs) traded with generally tight bid ask spreads, heavy volumes,and high liquidity

To explore this further, wehave published a new paper, entitled" High velocitymarkets: A case study onU.S.exchange-traded productperformance during theweek ofFebruary 24, 2020" that looks at how U.S.exchange- traded products performedduring this period ofmarket stress.

We hope you find this piece informative as you think about the role of exchange-traded products in globalmarkets. We look forward to maintaining an active dialogue on these and other asset management- relatedtopics.

This messagemaycontain informationthat is confidential or privileged. If you are not the intendedrecipient, pleaseadvisethe sender immediatelyand deletethis message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimersfor further information. Pleaserefertohttp://www.blackrock.com/corporate/compliance/privacy-policyfor more informationaboutBlackRock'sPrivacy PolicyFor a list of BlackRock'soffice addressesworldwide, see http://www.blackrock.com/corporate/aboutus/contacts- locations.

© 2020 BlackRock, Inc.All rights reserved.

Page 2: I wanted to forward this analysis by our capital markets

Quick call?

From:

To :

Date:

" Novick , Barbara" (b ) (6)(b)(6) - Chair Powell's Email Address

Mon, 16 Mar 2020 19:08:23 -0400

NONCONFIDENTIAL EXTERNAL

If you can, I'd like to speak with you briefly.

I'mavailableat;( ) (6)

Barbara

Sent from my iPhone

This message maycontain information that is confidential or privileged . If you are not the intendedrecipient, please advise the sender immediately and delete this message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimers for further information . Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy Policy

For a list of office addresses worldwide, see http://www.blackrock.com/corporate/aboutus/ contacts - locations .

© 2020 BlackRock Inc. All rights reserved .

Page 3: I wanted to forward this analysis by our capital markets

Call Tonight

Callahan, Thomas" (b ) ( 6 )From: "Novick, Barbara" ) (6 )To : Quarles (b) 6 )

"Novick , Barbara" (b ) (6)Date: Mon, 16 Mar 2020 21:27:32 -0400

NONCONFIDENTIAL EXTERNAL

Randy,

Tom and I are both available tonight at any time. Please let us know what time works best for you.

am reachable on (b ) (6) and I can conference in Tom.

BestBarbara

Barbara NovickVice Chairman BlackRockPhone: +

Follow us on Twitter: @BLKPublic Policy

This message may contain information that is confidential or privileged. If you are not the intendedrecipient, please advise the sender immediately and deletethis message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimers for further information . Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy PolicyFor a list of BlackRock's office addresses worldwide, see http://www.blackrock.com/corporate/aboutus/ contacts -locations.

© 2020 BlackRock, Inc. All rights reserved .

Page 4: I wanted to forward this analysis by our capital markets

RE: Tues morning

From: "Callahan, Thomas " (b ) (6 )To: [email protected]: ( ) 6 ) Quarles' [email protected] , [email protected] ,

( b )(6 ) - [email protected]: Tue, 17 Mar2020 08:33:59 -0400

NONCONFIDENTIAL EXTERNAL

We're on the call, let me know if there are issues with the dial in number

From : Callahan ThomasSent: Monday, March 16, 2020 11:08 PM

To: ' Justin [email protected]' < [email protected] >Cc : (b ) (6) - VC Quarles' [email protected] ; [email protected] ;( b)( 6) - [email protected]: RE : Tues morning

Many thanks Justin . Might be best to use a dial in, mine is

as a backupif there areany issues.

If possible l'd liketo invite my head of PortfolioManagement Rich Mejzakas well, please let me know ifthat's ok.

Lookingforward to our conversation,

Tom

My cellis b) 6 )

From: [email protected]< [email protected]>Sent: Monday, March 16, 2020 10:43PMTo: Callahan, Thomas( ) (6 )

Cc( - Quarles' [email protected]; [email protected];(b )(6) - [email protected]: Tues morning

External Email: Usecaution with links and attachments

Tom thanks for speakingthis evening. The Treasury team will call you at 8:30am tmrw morning.Please send best number.BestJustin

Thismessagemay contain informationthatisconfidentialor privileged. Ifyouare not the intendedrecipient, pleaseadvisethesenderimmediatelyanddeletethismessage. See

http://www.blackrock.com/corporate/compliance/email-disclaimersforfurtherinformation. Pleaserefertohttp://www.blackrock.com/corporate/compliance/privacy-policyfor moreinformationaboutBlackRock'sPrivacyPolicyAssociateof BlackRockInvestments, LLC( " ) and/orBlackRockExecutionServices, bothmembersFINRA SIPC. The iSharesFundsandBlackRockMutualFundsaredistributedby BRIL. Forcurrent

Page 5: I wanted to forward this analysis by our capital markets

prospectuses for iShares products, go to www.ishares.com/prospectus .For a list of BlackRock's office addresses worldwide , see http://www.blackrock.com/corporate/aboutus/contacts -locations.

© 2020 BlackRock, Inc. All rights reserved .

Page 6: I wanted to forward this analysis by our capital markets

[No Subject]

From : "Novick, Barbara " (b) (6)

To "Randal (Randy) K. Quarles (b ) (6 )Date: Tue , 17 Mar 2020 11:36:14 -0400

NONCONFIDENTIAL EXTERNAL

Randy, We would welcome the opportunity to speak about the markets and additional measuresthat maybe warranted. Barbara

Mobile: (b ) 6

Thismessagemaycontain informationthat is confidentialorprivileged. Ifyou are notthe intendedrecipient, pleaseadvise the sender immediatelyand deletethis message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimersfor further information. Pleaserefertohttp://www.blackrock.com/corporate/compliance/privacy-policyfor moreinformationaboutBlackRock'sPrivacyPolicy.For a listof BlackRock'soffice addressesworldwide, see http://www.blackrock.com/corporate/aboutus /contacts-locations.

© 2020 BlackRock, Inc.All rights reserved.

Page 7: I wanted to forward this analysis by our capital markets

Can we try to have a call at 12:45?

"Callahan ,

From: "Novick, Barbara " (b ) (6 )To "Randal ( ) K. Quarles ( b) (6)

Thomas" (b) (6 )Date: Tue, 17 Mar 2020 12:41:49 -0400

NONCONFIDENTIAL EXTERNAL

Randy, tried the ( number, but the call did not go through. Pleasetry my celland will dial in Tom.Thanks, Barbara

This messagemaycontain informationthat isconfidentialorprivileged. If you are not the intendedrecipient, pleaseadvise the sender immediatelyand delete this message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimersfor furtherinformation. Please refertohttp://www.blackrock.com/corporate/compliance/privacy-policyfor more informationaboutBlackRock'sPrivacyPolicy.Fora list of BlackRock'soffice addressesworldwide, seehttp://www.blackrock.com/corporate/aboutus /contacts-locations.

© 2020 BlackRock, Inc.All rights reserved.

Page 8: I wanted to forward this analysis by our capital markets

Fwd: BofA Asset Strategy -- Regulatory mountainsmay need to be moved.pdf

From: "Novick , Barbara " (b ) (6 )To : Quarles (b)(6) - VC Quarles' EmailAddress

Date: Wed, 18 Mar2020 10:10:22-0400

Attachments: Asset Strategy -- Regulatorymountainsmay need to be moved.pdf (276.01); ATT00001.htm 207 bytes)

NONCONFIDENTIAL EXTERNAL

Barbara NovickVice Chairman BlackRockPhone: +1

Follow us on Twitter: @BLKPublic Policy

Begin forwarded message:

From : "Fulton, Kathryn " ( b ) ( 6 )Date : March 18, 2020 at 9:58:07 AM EDTTo: "Novick, Barbara" b) (6 )Subject : BofA Asset Strategy -- Regulatory mountains may need to be moved.pdf

This message may contain information that is confidential or privileged . If you are not the intendedrecipient, please advise the sender immediately and delete this message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimers for further information . Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy Policy .For a list of BlackRock's office addresses worldwide , see http://www.blackrock.com/corporate/aboutus/ contacts -locations .

© 2020 BlackRock, Inc. All rights reserved .

Page 9: I wanted to forward this analysis by our capital markets

GLOBAL RESEARCH A SECURITIES

Cross Asset Strategy

Regulatory mountains may need to bemovedGovernment Regulations

16 March2020

EquityUnitedStatesUSBanks

( b ) (6 )

RalphAxelRatesStrategist

(b ) (6 )

) ( 6)

MarkCabana, CFARatesStrategistBofAS( b ) ( 6)

@ bofa.com

ErikaNajarian

ResearchAnalystRofAS( b) (6 )

( b ) ( 6)

MichaelCarrier, CFAResearchAnalyst

( 6

( b ) ( 6 ) @

Regulatoryeasing, evenif temporary, wouldhelpmarketsDealercapital andliquidityconstraints, combinedwithpro -cyclical tighteningof lendingstandardsascredit risksrise, havecombinedto increasefundingpressuresinrepomarketsandcreditmarketsmoregenerally(Chart 1 Chart 2 ). We think regulators, andpotentiallyCongress, needto addressthisissueto preventan economiccrisis frombecominga financialcrisis. The policyresponselikelyrequirescoordinatedandforcefulactionfrom allaspectsof government, includingonthe regulatoryside.

Unlike2008, bankshaveplentyof capitalandliquidity, andthelargestbanksare stresstestedeveryyear to test the durabilityof their balancesheetsunderbotheconomicandmarketsdistress. That said, prudentialregulationand legislationhavehandcuffedthesector'sability to deployliquidityorcapital. The Fedhasalreadyincreasedthe availabilityof fundingto primarydealersvia the overnightand termrepooperations, andhasalso increasedtheiroutrightpurchasesof Treasuriesandmortgage-backedsecurities(MBS) tohelpbothmarketliquidityand reducethe supplyof securitiesthatrequirefunding. Yet fundingpressurescontinueto increase, withCPmarketsshowingextremestress, aswellas inter-dealerrepomarkets. Wethink a temporaryemergencyeasingofvariousregulationswouldbe necessaryto ease the flow ofcreditandavoidunnecessaryfinancialstressinthecontextof theongoingpandemic. We do not thinksucheasingwouldconstituteany threattobank balance

sheetstrengthor in anyway reducetheirdefensiveness.

The EuropeanBankingAuthorityhasalready issuedguidanceon relaxingEU bankregulationsto addressthe impacton the EU bankingsector. The EBArecommendsauthoritiesmakefull useof the flexibilityembeddedin the regulatoryframeworktosupportthe bankingsector. The ECBisrelaxingsomecapitalandliquidityrequirementsandaspectsofsupervision.

Wediscuss capital andbroader bank regulatoryadjustmentsbelow . Our regulatory

handbookgoes intomoredetailon the regulationsdiscussedbelow, see here.

Capital regulations: easeGSIBsurchargecalculations

Underthe newstressedcapitalbuffer(SCB) framework, no BHC (bank holdingcompany)will be boundby leveragerequirementsleveragerequirementslikethe SLR( supplementaryleverageratio) would act as a backstop. As such, we thinka recalibrationof the US G -SIB ( global systemicallyimportantbank) frameworkwouldbe helpful. Underthe USrule, exposuresare multipliedby coefficients(e.g. tradingandAFS securitieshavea 30 % coefficientvs. 0.16 % fornotionalOTCderivativesexposure, see Exhibit1).Theseexposuresaddup to a scorethat correspondswitha G - SIB'ssurcharge, as ofyear endexposures. Asa result, manyG - are constrainedby the calculation, andhavenotwantedto incurshareholderwrathby voluntarilyincreasingexposuresto thenextsurchargebucker( additional incapitalrequirements). Basedonconversationswith the banks, we think G -SIB recalibrationhasbeenentertainedas apossibilityby regulators. Therefore, we think easingG - SIB restrictionscouldbe

somethingregulatorscoulddo to easecredit flow withoutimpactingcapitalstrength.

Continuedon page2...Unauthored

ofthisreport

Thisreportis

for

Securities does and seeks to do business with issuers covered in its research reports. Asa result investors should be aware that the firm may have a conflict of interest that couldaffect the objectivity of this report Investors should consider this report as only a singlefactor in making their investment decision .Refer to important disclosures on page 5 to 7 .

Timestamp: 16 March 2020 PM EDT

12111072

Page 10: I wanted to forward this analysis by our capital markets

BofAGLOBALRESEARCH

Exhibit 1:USGISIB surcharge calculation ( )Systemic indicator Coefficient

Totalexposures 442- 12015

Intra -

InterconnectednessOTC 0.16 %

30.17 %Level 3

Complexity%

Cross 993

Cross jurisdictionalactivity

ST Wholesale Funding

Total G - SIB Score ( bp

4932

116,141

65,97121

61028

121,516

23,715

30,768

107,61954.99431

12793

99,447

89,05492

WC

22,178

18.99838

39

96 978158719380

2525151

GS

9,193

7452

33 467

38 141

31

MS

51.53024792

119,1363097430 177

61,151

580

BK

16893

31.427

48.3651.722

11,193

1697127485

175

279

STT

11,373

22,173

33,601

11300

18,739

115191

188661 518

% 25 15 % 10G SIB Surcharge

Source Research data

SLR recalibration could also help, but not the constraintOn the capital side, we think regulators need to temporarily carve out Treasuries andcash from the supplementary leverage ratio (SLR ) This would have multiple benefits inour view . First, itwould allow dealers to tap funding through the Fed's temporary openmarket repo ops,which were extended in both overnight and 2 -week terms, but alsowere expanded with $ 500bn in 1-mo and $ 500bn in 3 -mo term availability . As primarydealers access these funds, which are collateralized by Treasuries and MBS dealerbalance sheets grow and capitalization ratios fall unless new capital is raised). If the Fedremoves cash and Treasuries from SLR dealers could tap these facilities with muchless constraint.

Dealers would be able to use the funds both for their own needs and for the needs ofclients. Outside of the Fed's repo facility , dealer desks would be able to make marketsmore easily in Treasuries and potentially warehouse large Treasury positions (optionally

funded through the Fed repo ops) that buy side investors need to offload .

Such a temporary relaxation in the leverage rules would allow funding to flowintermediated by dealers - and would allow primary dealers to participate more fully inTreasury trading without balance sheet constraints to facilitate the exchange of riskbetween investors that is crucial during times of stress . Since Treasuries do not carrydefault risk, we do not see any increase in potential bank credit losses stemming from acarve out of Treasuries and cash from the SLR. In fact , the Treasury Departmentrecommended such a carve out in 2017 for these reasons .

Volcker ruleOverall, we think there are potential tweaks that could be made to the Volcker rulearound certain trading restrictions , but anything major would likely require Congress . Ingeneral, given the areas that the Volcker rule targeted vs. where thereare current strains

in the market, we think other areas of easing regulation would likely provide morebenefit to the markets given the current liquidity issues.

Liquidity regulations: ease living will , LCROn the liquidity side, we think an easing of liquidity requirements would also be helpful.The share of banks have cited resolution planning ( living will ) requirements as thebinding constraint for liquidity. These liquidity requirements are dictated by RLAP(Resolution Liquidity Adequacy Planning) and RLEN (Resolution Liquidity ExecutionNeed). RLAP requires a BHC to project standalone liquidity needs for each majorsubsidiary over a 30 -day minimum period. It also ensures that liquidity is prepositioned in the subsidiary (which we read as a material liquidity tie-up) or otherwiseavailable at the parent as HQLA to meet potential deficits. Importantly , under RLAP

to assume that major subsidiaries will hoard the holdco's liquidity sources,and that a liquidity surplus from one sub cannot be transferred to meet a deficit atanother sub . Resolution planning information is considered confidential supervisoryinformation, and therefore it is difficult for us to make pinpoint recommendations on

2 Cross Asset Strategy March 2020

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GLOBAL RESEARCH

easing rules to improve current market functioning. That said the separate prepositioning liquidity needs for each major sub leads us to believe that this is asignificant constraint on liquidity.

RLEN requires firms to estimate post- bankruptcy liquidity to support surviving and

wound -down subsidiaries, which suggests to us even more liquidity trapped at banksubs.

On LCR ,while banks hold ample liquidity to handle outflows over a stressed 30 dayhorizon, which is the requirement of the LCR regs ( liquidity coverage ratio ) the need tomaintain an LCR ratio above 100 % could limit bank willingness to engage in lending orbalance sheet expansion more generally. Any new liability that is added to the balancesheet requires some amount of cash or Treasuries or other level 1 high quality liquidassets to be held against it. This can restrict the banks' ability to expand, and as we sawin September, may also limit banks' ability to reduce HQLA holding and direct neededresources in other assets such as repo or there forms of credit.

Coordinated action neededWe would expect the Fed , and the Treasury to work together, and to work with

Congress, on temporarily freeing up the flow of credit to avoid a financial crisis on topof a public health crisis. Congress likely will need to act in conjunction with regulatorsbecause it is the Dodd-Frank Act that ultimately governs the regulators' ability to changecapital and liquidity requirements . Having Congress amend portions of Dodd-Frank tohandle crisis environments such as today would be in line with the promotion of safety

and soundness of financial systems, which is the ultimate goal of Dodd-Frank and theBasel frameworks.

While not directly a Dodd- Frank issue, Congress may also consider setting up a dealerof -last -resort which would allow risk exchange intimes of market breakdown. Whilemarkets are accustomed to the Fed as lender of last resort, we do not have in place anypublic utility that allows markets to operate in case the typical risk intermediationchannel of dealers is not available. Whether this is because markets becomedysfunctional due to lack of dealer ability to absorb large positions, or a more generalproblem that leads to a lack of personnel on hand to execute trades such as an extremehealth threat, we think it is important to have a government -run dealer of last resort tooperate across all markets including stocks, bonds, currency and commodities andderivatives. Such a dealer of last resort could stand ready to make markets ina way that

benefits the public and limits total public losses. This would be something that Congresscould implement with the aid of the Fed and the Treasury .

Broader reg changes : temp ease or waive of RegulationTemporarily easing regulations that restrict lending between banks and their dealersubsidiaries would also increase the flow of credit. Regulation W restricts transactionsbetween a depository institution and its affiliates. Themain purpose of Reg to

reduce risk to depository institutions generated by affiliates such as dealer subsidiariesand to limit the use of deposit insurance to cover such losses. The total lending amountis highly restricted and secured lending in particular . Carving out more allowance forlending collateralized by Treasuries we think would additionally help the flow of creditbetween banks and dealers and buy -side investors.

The Fed's discount window actions last night do not address current clogged dealerbalance sheet issues as a result of Reg Dealers cannot post collateral to thedepository to then be funded at the Fed. If the Fed did not want to ease Reg W couldre - establish the Primary Dealer Credit Facility (PDCD) which was used in 2008 under theFed's 13-3 authority.

Cross Asset Strategy 2020 3

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GLOBAL RESEARCH

AppendixA few other notes on the discount window per recent client questions:

Who can access the discount window ? The discount window provides loans todepository institutions in sound financial condition. US branches and agencies of foreignbanksthat hold reserves are also eligible to borrow .

Can CP be pledgedto thediscount window ? USD denominated, investment gradecommercial paper (CP) can be pledged to the discount window. The margin for CP issimilar to that for US Treasuries (Table 1).

When is data released ? Discount window usage is releasedweekly as a part of the Fed'sH.4.1 release (Chart 3).

Chart 1: CP ratesincreasing vs ) Chart 2: GC repo vs ON RRP (bps)

90 March 16 GC repo is avg rate for

80 50

7060

45

40

35

30

50

4030

2010

-10

Jun - 19

25

20

15

Mar -20 10Sep- 19 Dec -19

3m Fin CP vs ( MA)

-Fed 3m NonFin CP OIS ( MA

5

0

2/212/232/252/272/29

3/2 3/8

3/103/12 3/14 3/161

Source. BloombergSource:Bloomberg

Chart 3 Discount window usage( )

120Table 1: Marginsfor Securities of marketvalue

Duration 0-1 > 1-3 > 3-599 % 99 % 98 %98 % 98 % 97 %

CDs 98 % 98 % 97 %

CP % 98 % 97Acceptance, ABCP

Source Reserve

> 5-10

97 %

96 %

96 %

> 10

95 %

94

94 %100

80

60

40

20

2002 2004 2006 2008 2010 2012 2014 2016 2018

Source FederalReserve

4 Cross Asset Strategy March2020

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GLOBALRESEARCH

Disclosures

ImportantDisclosures

Buy

FUNDAMENTALEQUITYOPINIONKEY: Opinionsincludea VolatilityRiskRating, an InvestmentRatingandanIncomeRating. VOLATILITYRISKRATINGSindicatorsof potentialpricefluctuation are: A Mediumand INVESTMENTRATINGSreflectthe analyst'sassessmentof astock's: ( i) absolute totalreturnpotentialand( ii)

attractivenessfor investmentrelativeto otherstockswithinitsCoverageCluster(definedbelow). Therearethree investmentratings: 1 stocksareexpectedto havea totalreturnof at least 10 % andare the most attractivestocks inthe coveragecluster Neutralstocksareexpectedto remain flat or increaseinvalueand are less attractivethanBuyratedstocksand3 Underperformstocksare the leastattractivestocksin a coveragecluster assigninvestmentratingsconsidering, amongother things, the0-12monthtotal returnexpectationfora stockandthe firm's guidelinesfor ratingsdispersions( showninthe tablebelow ) The currentpriceobjectivefora stock should bereferencedto better understandthe totalreturn expectationat any giventime. The priceobjectivereflectsthe analyst'sview of the potentialpriceappreciation( depreciation)

Investmentrating Totalreturn expectation(within 12-month period of dateofinitialrating) Ratingsdispersionguidelinesfor coverage cluster

Neutral 20 %

Underperform NA 2 20* Ratingsdispersionsmayvary from timeto timewhere Researchbelievesit better reflects the investmentprospectsof stocksinaCoverageCluster.

INCOMERATINGS,indicatorsof potentialcash dividends, are: higher dividendconsideredto be secure), 8 - same lower ( dividendnot consideredto besecure)and9 -nocashdividend. Coverage is comprised of stocks coveredby single analyst ortwoormoreanalystssharinga commonindustry sector regionor other classification(s) A stock'scoveragecluster is includedinthe most recentBofA Research reportreferencingthe stock

BofA Research personnel includingtheanalyst (s) responsibleforthisreport) receive compensationbasedupon ,amongotherfactors theoverallprofitabilityof BankofAmericaCorporation, including profitsderived from investmentbanking The analyst s) responsibleforthis reportmay also receive compensation based upon amongother factors,the

profitabilityofthe Bank's sales and trading businessesrelatingto the class ofsecuritiesorfinancial instrumentsforwhich such analyst is responsible.

OtherImportantDisclosures

From timeto timeresearchanalystsconductsitevisitsofcoveredissuers. GlobalResearchpoliciesprohibitresearchanalystsfrom acceptingpaymentor reimbursementfor travelexpensesfromtheissuerfor suchvisits.Pricesareindicativeandfor informationpurposesonly. Exceptasotherwisestatedinthereportfor thepurposeofany recommendationinrelationto: ) equitysecurity, thepricereferencedis thepubliclytradedprice ofthesecurityasof closeofbusinesson theday priortothedate ofthe reportor if thereportis publishedduringintradaytradingthepricereferencedisindicative

of thetradedprice as of date and timeof thereport ) debtsecurity( includingequitypreferredand CDS) pricesare indicativeasofthedate and timeofthereportandare from varioussourcesincluding tradingdesks.Thedateandtimeof completionof theproductionofanyrecommendationinthisreportshallbethedateandtimeofdisseminationofthisreportas recordedinthereporttimestamp

Recipientswhoare notinstitutionalinvestorsormarketprofessionalsshouldseektheadviceof theirindependentfinancialadvisorbeforeconsideringinformationin thisreportinconnectionwithanyinvestmentdecision fora necessaryexplanationofitscontents.Officersof oneor moreofits (otherthanresearchanalysts) mayhavea financialinterestinsecuritiesof theissuer(s) or inrelatedinvestments.BofA Researchpoliciesrelating to conflictsof interestare describedathttps: //" Securitiesincludes Securities, Inc. ( andits affiliates. Investorsshouldcontacttheir representativeor MerrillGlobalWealthManagement

advisoriftheyhavequestionsconcerningthisreportor concerningtheappropriatenessof any investmentideadescribedhereinfor such Securities aglobalbrandfor Research.InformationrelatingtoNon-USaffiliatesof andDistributionofAffiliateResearchReportsBofAS or MerrillLynch, & Smith("MLPF& S") mayin thefuturedistribute, informationof thefollowingnon-USaffiliatesintheUS( shortnamelegalname, regulator):Lynch(SouthAfrica): MerrillLynchSouthAfrica( Pty) Ltd regulatedby TheFinancialServiceBoard; ) MerrillLynchInternational, regulatedbytheFinancialConductAuthority( FCA) andthe PrudentialRegulationAuthority(PRA) ( France) SecuritiesEuropeSA isauthorizedby the AutoritédeContrôlePrudentieletde (ACPR ) and regulatedbythe ACPR

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Cross Asset Strategy March2020 5

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GLOBALRESEARCH

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6 Cross Asset Strategy 16 March 2020

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BofAGLOBALRESEARCH

Insome cases,an issuer may beclassifiedas Restrictedor may be Under Reviewor ExtendedReview. Ineach case, investors shouldconsider anyinvestmentopinionrelatingto such issuerits security and or financial instruments) to besuspendedorwithdrawnand shouldnot rely on the analysesand investmentopinion( s)pertainingto such issuer or itssecuritiesand / or financialinstruments) nor should the analysesoropinion(s) beconsidereda solicitationofany kind Sales personsand financialadvisorsaffiliatedwith of itsaffiliatesmay notpurchasesofsecuritiesorfinancialinstrumentsthat are Restrictedor Under Reviewand may only solicit securitiesunder ExtendedReviewinaccordancewithfirmpolicies.

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Cross AssetStrategy 16March2020 7

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Important to talk when you have a minute .

From:

To:Date:

"Novick, Barbara"

Quarles (b) ( 6 )

Thu, 19 Mar2020 16:57:11-0400

NONCONFIDENTIAL // EXTERNAL

BarbaraNovickVice Chairman BlackRockPhone: +1

Follow us on Twitter: @BLKPublic Policy

This message maycontain information that is confidential orprivileged. If you are not the intendedrecipient, please advise the sender immediatelyanddeletethismessage. Seehttp://www.blackrock.com/corporate/compliancelemail-disclaimers for further information. Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy Policy.For a list ofBlackRock's office addresses worldwide, see http://www.blackrock.com/corporate/aboutus/ contacts -locations.

© 2020 BlackRock , Inc. All rights reserved.

Page 17: I wanted to forward this analysis by our capital markets

Best number for me: )

From:To :

Date:

"Novick, Barbara " (b) (6)Quarles ( b ) ( 6 )Thu, 19 Mar 2020 18:07:24 -0400

NONCONFIDENTIAL// EXTERNAL

RandySorry missed you I'mworking remotely. Best to call my mobile which is direct .I hope we can connect this evening.BestBarbara

Barbara NovickVice Chairman BlackRockPhone: +1Mobile: (b) (6 )

Follow us on Twitter: @BLKPublicPolicy

This message maycontain information that is confidential or privileged. If you are not the intendedrecipient, pleaseadvisethe sender immediatelyanddelete this message. Seehttp://www.blackrock.com/corporate/compliancelemail-disclaimers for further information. Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy PolicyFor a listof BlackRock's office addresses worldwide, see http://www.blackrock.com/corporate/aboutus /contacts locations.

2020 BlackRock, Inc. All rights reserved .

Page 18: I wanted to forward this analysis by our capital markets

RE: Call With Larry Fink

From: Jerome Powell ( b ) (6 )To : "Chaffin, Rachel" (b) (6 )Cc: Ingrid NaylorDate: Mon, 23 Mar 2020 11:18:33 -0400

" Peter, Catherine " ( b) (6 )

NONCONFIDENTIAL EXTERNAL

Now is good (b) (6 )

From : Chaffin , Rachel( ) ( 6 )Sent : Monday, March 23, 2020 10:36 AMTo: Jerome Powell ) )Cc : Ingrid Naylor < PeterCatherine(b) (6 )Subject: With Larry Fink

NONCONFIDENTIAL// EXTERNAL

Chairman Powell

Larry Fink is available to speak today regardingthe projectyou will beworkingon together. Please let usknow if there is a convenient time for you.

Very bestRachel

RachelChaffin

Assistant

55 East52nd Street, NY, NY 10055Phone:(b ) ( 6 )

This messagemay contain informationthat isconfidentialorprivileged. Ifyou are not the intendedrecipient, please advisethe sender immediatelyand deletethismessage. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimersfor further information. Pleaserefertohttp://www.blackrock.com/corporate/compliance/privacy-policyfor moreinformationaboutBlackRock'sPrivacyPolicy.For a list of BlackRock'sofficeaddressesworldwide, seehttp://www.blackrock.com/corporate/aboutus/contacts-locations.

2020BlackRock, Inc.All rights reserved.

Page 19: I wanted to forward this analysis by our capital markets

Call With Larry Fink Today

From:To:

Cc:

Date:

" Chaffin, Rachel" b ) ( 6 )(b ) 6 ) Chair Powell'sEmailAddress

Ingrid Naylor < ic

Wed , 01 Apr 2020 14:27:08 -0400

NONCONFIDENTIAL // EXTERNAL

Chairman Powell

Fink would love to catch up today if you have some time. You may call Larry direct on his cell at(b ) (6 )

Very bestRachel

Rachel ChaffinExecutive Assistant

55 East 52nd Street,NY, NY 10055Phone:

(b ) (6)

This message may contain information that is confidential or privileged. If you are not the intendedrecipient, please advise the sender immediately and delete this message. Seehttp://www.blackrock.com/corporate/compliance/email-disclaimers for further information . Please refer tohttp://www.blackrock.com/corporate/compliance/privacy-policy for more information about BlackRock'sPrivacy PolicyFor a list of BlackRock's office addresses worldwide , see http://www.blackrock.com/corporate/aboutus contacts-locations.

© 2020 BlackRock , Inc. All rights reserved .