In re R & L Investments, Inc.

June 11, 2021 SEC-MSRD CASE NO. MSRD-MID-2020-2 IN THE MATTER OF: R & L INVESTMENTS, INC. VENTURE SECURITIES, INC., WILFRED RACADIO (President), ADORA AGUILAR (Associated Person), LORETO BALABIS (Salesman), TERESITA MOSENABRE (Settlement Head) , respondents . DECISION Before the Special Hearing Panel ("SHP") is a Formal Charge dated September 2020 of the Investigation and Review Committee ("IRC") composed of officers and personnel of the Markets and Securities Regulation Department ("MSRD") of the Securities and Exchange Commission (the "Commission") charging Venture Securities, Inc. ("VSI" or "Venture Securities") a corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines with office address at 8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City and its officers and employees, namely, Wilfredo Racadio, Adora Aguilar, Loreto Balabis and Teresita Mosenabre for violations of the Securities Regulation Code ("SRC") and its 2015 Implementing Rules and Regulations ("2015 SRC Rules" or "SRC-IRR"), as follows: Charges against Venture Securities 1) Rule 30.2.1. Ethical Standards Rules 2) Rule 30.2.1.2.3. Capabilities 3) Rule 30.2.1.2.4. Information About Clients 4) Rule 48.2. Prohibitions on Extension of Credit in relation to Rule 48.1 Margin 5) Rule 50. Purchases and Sales in Cash Account 6) Rule 52.1.1. Books and Records Rule 7) Rule 52.1.6. Customer Account Information Rule Charges against Mr. Wilfredo Racadio (VSI President) 1) Section 51 in relation to Section 26 of the SRC 2) Rule 30.2.1. Ethical Standards Rules 3) Rule 30.2.1.2.3. Capabilities 4) Rule 30.2.1.2.4. Information About Clients 5) Rule 30.2.6. Supervision 6) Rule 48.2. Prohibitions on Extension of Credit in relation to Rule 48.1 Margin 7) Rule 50. Purchases and Sales in Cash Account 8) Rule 52.1.1. Books and Records Rule 9) Rule 52.1.6. Customer Account Information Rule Charges against Ms. Adora Aguilar (VSI Associated Person) 1) Section 26 in relation to Section 54 of the SRC 2) Rule 30.2.1. Ethical Standards Rules 3) Rule 30.2.1.2.3. Capabilities 4) Rule 30.2.1.2.4. Information About Clients 5) Rule 30.2.6. Supervision 6) Rule 34. Segregation and Limitation of Functions of Members, Brokers and Dealers 7) Rule 52.1.1. Books and Records Rule 8) Rule 52.1.6. Customer Account Information Rule Charges against Mr. Loreto Balabis (VSI Salesman) 1) Section 26 in relation to Section 54 of the SRC 2) Rule 30.2.1. Ethical Standards Rules 3) Rule 30.2.1.2.3. Capabilities 4) Rule 30.2.1.2.4. Information About Clients 5) Rule 52.1.6. Customer Account Information Rule Charges against Ms. Teresita Mosenabre (VSI Settlement Head) 1) Section 26 in relation to Section 54 of the SRC 2) Rule 52.1.1. Books and Records Rule ANTECEDENT FACTS AND PROCEEDINGS On 14 November 2019, the Securities and Exchange Commission in SEC En Banc Case No. MP-2019-001 ordered the Capital Markets Integrity Corporation ("CMIC") to take over the operations of R&L Investments, Inc. ("R&L"), pursuant to Section 33.1 (d) of the SRC and Rule 33.1.1.26.3 of the SRC-IRR. The Take Over Order was issued due to the deterioration of the financial condition of R&L rendering it incapable of meeting the demands of its client security holders and the payment of their share proceeds. Consequently, the Commission directed the MSRD to conduct a thorough investigation of the incident to determine the various violations of the securities laws possibly committed and to institute, among others, the appropriate administrative charges against all the responsible persons, including VSI, its officers and employees. Pursuant to the direction, MSRD created the IRC. Hence, subpoenas were issued by IRC separately to VSI, R&L, Marlo Moron and Julieto Sulapas, and the investigative proceedings were conducted on 9 December to 12 December 2019. The IRC conducted a conference with VSI, Wilfredo Racadio, Adora Aguilar, Loreto Balabis and Teresita Mosenabre on December 9 and 12, 2019. On 5 February 2020, the SHP composed of the undersigned was created to hear, resolved and decide matters relative to the case. After conducting the investigation, the IRC formally instituted the Formal Charge dated September 2020 against the Respondents. The Formal Charge was received by the respondents on 7 September 2020. Briefly, the Formal Charge alleges that: 1. The deterioration of the financial condition of R&L was brought about by the fraudulent schemes allegedly committed by one Marlo Moron that resulted in the loss of allegedly Php700 million worth of client shares of R&L due to the unauthorized transfers through EQ Trades 1 from R&L to the Julieto Sulapas account in VSI. 2. The CMIC report regarding VSI reveal that the transaction volume amounted to roughly 14% (buying) and 20% (selling) of all transactions of VSI clients for the period of 2012 to 2019, and even reaching to as high as 27% buying (2016) and 35% selling transactions (2017). As to value, the Julieto Sulapas accounts (Customer Account SU026 and SU027) amounted to approximately 15% (buying) and 13% (selling) transaction of VSI for 2012 to 2019, with peak transactions of 25% buying (2016) and 21% selling (2016-2017). 3. The transactions of Julieto Sulapas in his VSI account amounting to Php9,905,454,333.20 (which can be broken down into Buy Transactions worth Php4,602,939,508.50 and Sell Transactions worth Php5,302,514,824.70) per account ledger of Julieto Sulapas were grossly disproportionate to his declared total net worth, liquid net worth and annual income of less than Php 1 Million as reflected in his Customer Account Information Form ("CAIF") as of October 2017. 4. The account ledger of Julieto Sulapas reveals that Julieto Sulapas approximately had 2,800 buy transactions from 2012 to 2019 but Julieto Sulapas only made cash payments five times during the same period. 5. Respondent Balabis did not personally meet Julieto Sulapas at the time the latter opened an account with VSI and did not see Julieto Sulapas fill out the CAIF himself but simply gave Marlo Moron a blank CAIF (without verification of the contents of the Julieto Sulapas CAIF). 6. Respondent Balabis did not make any inquiry or verification as to the transactions of Julieto Sulapas, despite the large amounts involved (roughly PhP10 billion in total from 2012 to 2019, per CMIC Report) in relation to the total net worth, liquid net worth and annual income declared in the CAIF amounting to PhP1,000,000.00. 7. The Associated Person Adora Aguilar likewise did not conduct any inquiry, verification and review of the Julieto Sulapas account transactions. 8. Respondent Mosenabre, as the settlement officer of VSI, did not make any inquiry into the Julieto Sulapas EQ trade transactions knowing that Marlo Moron who is the authorized person of Sulapas is at the same time the settlement officer of R&L. 9. There are EQ Trades involving the Julieto Sulapas account without written request and/or with unsigned requests. 10. Julieto Sulapas indicated in his CAIF that he does not have any other account with other broker dealers notwithstanding his existing account with R&L. 11. Respondent Aguilar did not require Julieto Sulapas to correct his answers in the CAIF as to the existence of an account with other brokers even if she knew that Julieto Sulapas has an account with R&L. 12. Marlo Moron was allowed by Respondents as authorized person of Julieto Sulapas to transact relating to the latter's account with VSI despite knowledge that Moron is a trading floor assistant/settlement clerk in R&L where the subject EQ Trades originated. 13. VSI officers relied on the confirmation of Marlo Moron as the alleged settlement officer of R&L for transactions that Marlo Moron himself instructed on behalf of Julieto Sulapas. 14. Certain "transfer in" requests in the account of Julieto Sulapas lack the signature of Sulapas. 15. The lack of action in the part of VSI, including its Associated Person Adora Aguilar and Salesman Loreto Balabis, revealed the lack of satisfactory internal control procedures in the "transfer in" transactions that ultimately led to the successful execution of the fraudulent schemes of Marlo Moron to the detriment of the clients of R&L Investments, Inc. 16. VSI failed on its duty to be duly informed about the identity of Sulapas, including the client's financial situation, investment experience and objectives. 17. The annual income of Julieto Sulapas is only Php1 million but he was allowed to transact beyond his financial capability. 18. There were lapses in employing effective compliance functions in VSI by the Associated Person Adora Aguilar. 19. Respondent Aguilar was remiss on her duty to check all executed trades and other transactions of the company for her failure to properly identify the account of Julieto Sulapas as a margin account and comply with all the requirements of the SRC and SRC-IRR. 20. The Julieto Sulapas account does not comply with the Rules and Regulations of the Commission on margin accounts as enumerated under Rules 48.1 and 48.2 of the 2015 SRC-IRR. Despite such non-compliance, the credit line agreement was still signed by Wilfred Racadio as the representative of VSI. 21. Assuming arguendo that the account is indeed a cash account, the account ledger of Julieto Sulapas submitted by VSI however shows that Julieto Sulapas did not settle his purchases within T+3. 22. Certain "transfer out" in the account of Julieto Sulapas lacks written request. 23. There are discrepancies on the number of shares between the Stock (In) CM, the Julieto Sulapas ledgers and the EQ Trade Form in the Julieto Sulapas account ledgers with VSI. 24. VSI failed to maintain and keep current complete set of its books and records in violation of the SRC and its IRR. 25. VSI does not have a clear customer acceptance policies and procedures that were applied to Julieto Sulapas. 26. Respondent Wilfredo Racadio, as President, has failed to perform his duty to oversee the day-to-day operations of VSI. 27. Section 51 of the SRC makes Wilfredo Racadio jointly and severally liable with VSI officers and employees. The Respondents filed their Answer to the Formal Charge denying the material allegations of the charge, except those admitted and alleged the facts common to all Special and Affirmative Defenses, that: (i) the creation of the Julieto Sulapas account followed the requirements under the relevant laws and rules; (ii) VSI found nothing suspicious or irregular in the transactions of Mr. Sulapas in his account; (iii) Mr. Sulapas maintained a Cash Account with VSI; (iv) VSI maintains proper customer acceptance and KYC procedures, internal control procedures, record-keeping, and anti-money laundering procedures; and, (v) Respondents did not commit the alleged violations of the SRC and the SRC-IRR as indicated in the Formal Charge. A clarificatory conference was held on February 24, 2021. Both parties appeared during the conference by themselves and/or as represented by counsel. During the conference, the parties were directed to submit their respective position papers within ten (10) days from February 24, 2021 and to furnish each other with copies thereof. Both were likewise given a period of five (5) days from receipt of the respective position paper of the other party to file their comments/replies thereto. After the lapse of said date, with or without the position paper or comments/replies, the case was deemed submitted for resolution. Complainant and Respondents in compliance with the aforementioned order, submitted their respective position papers both substantially reiterating their arguments in their previous submissions and submitted additional documents to support their allegations. Both parties also filed their comments/reply against each other's position paper. In its Position Paper, Complainants alleged and maintained the following: 1. The Respondents failed to specifically deny the material allegations in the Formal Charge required under Section 10 of the Rules of Court. 2. Mr. Racadio is liable under Section 52 of the SRC since he has the duty to oversee the day to day operations of the Company. 3. The claim of Mr. Racadio that he cannot be held liable under SRC Rules 30.2.1.1, 30.2.1.2.4,1, 30.2.1.2.4.3 and 30.2.1.2.4.6 is untenable. As President of the Company, he is an agent of the broker dealer (VSI) with the duty to oversee the day-to-day operations of the Company. In addition, the Take Over Order dated 14 November 2019 issued by the Commission effectively assigned to MSRD the authority to file administrative cases against responsible officers and employees of VSI, including Mr. Racadio. 4. The creation of the Julieto Sulapas account did not follow the requirements under the relevant laws and rules. 5. Julieto Sulapas is not an active day trader. 6. The Julieto Sulapas Accounts in VSI are not Cash Accounts. 7. VSI did not maintain proper customer acceptance and KYC procedures, internal control procedures, record-keeping, and anti-money laundering procedures on Julieto Sulapas accounts, and; 8. Respondents committed violations of the SRC and the SRC-IRR in the Formal Charge. On the other hand, Respondents in their Position Paper insisted and alleged, that: 1. The Formal Charge failed to allege the ultimate facts showing any culpability of the respondents from the alleged violations of the SRC and its IRR. 2. The Creation of the Julieto Sulapas account followed the requirements under the relevant laws and rules. 3. VSI found nothing suspicious or irregular in the transactions of Mr. Sulapas in his account. 4. Mr. Sulapas maintained a cash account with VSI. 5. VSI maintains proper customer acceptance and know-your-client procedures, internal control procedures, record-keeping, and anti-money laundering procedures. 6. Respondents did not commit the alleged violations of the SRC and the SRC-IRR as indicated in the Formal Charge. In its comments, Complainant alleged that: 1. The cases cited ( Ramitere v. Montinola and Zuniga-Santos v. Santos-Gran ) by the Respondents in their position paper pertaining to allegation of ultimate facts relates to civil cases and not applicable in administrative cases. 2. Even if granting arguendo that the Formal Charge omitted to state the full ultimate facts, the same have already been cured by the position paper of Complainant which includes all the evidence and thorough explanations of the findings of the IRC. 3. The Makati Stock Exchange v. Campos case is likewise not applicable in this extant case since it involved an adjudicative action wherein the Commission was tasked to determine the rights and obligations of the opposing parties. The instant proceeding, however, involves an administrative action from the determination of violations of laws, rule, regulations, circulars and orders that may have been violated by the Respondents. 4. With regard to the other allegations of Respondents in their Position Paper, Complainant countered that the allegations are untenable and without merit since the same were already found and discussed in its Formal Charge and Position Paper. In their reply, Respondents countered and argued that: 1. Respondents sufficiently denied the allegations of fact in the Formal Charge and already submitted in their Position Paper the documents and affidavits that would support their factual allegation in their answer. 2. Complainant has failed to specify and establish the basis for the liability of Mr. Racadio under the SRC and its IRR. 3. The creation of the Julieto Sulapas account followed the requirements under the relevant laws and rules. 4. Complainant failed to provide any basis for VSI to find the transactions of Mr. Sulapas in his account to be suspicious or irregular. 5. Certain actions have already been barred by prescription. 6. Complainant has failed to demonstrate the absence of proper customer acceptance and know-your-client procedures, internal control procedures, record-keeping, and Anti-Money Laundering Procedures on the part of VSI. 7. Complainant's presentation of Mr. Sulapas affidavits violates the rights of Respondents to due process. 8. The statements of Mr. Sulapas in his Sinumpaang Salaysay and Supplemental Affidavit cannot be used against Respondents in this case under the doctrine of res inter alios acta as embodied under Section 31, Rule 130 of the Rules of Court; and, 9. Complainant has failed to show that Respondents committed the alleged violations of the SRC and the SRC-IRR as indicated in the Formal Charge. THE ISSUES Based on the pleadings submitted, the issues presented are summarized as follows: I. Whether or not certain actions have already been barred by prescription. 2 II. Whether or not Mr. Racadio is a control person within the purview of Section 51 of the SRC. 3 III. Whether or not the Respondents violated the following provisions of the Securities Regulation Code and its 2015 Implementing Rules and Regulations: A. Sec. 30.2.1.2.4. Information About Clients B. Sec. 52.1.6. Customer Account Information Rule C. Rule 48.2. Prohibitions on Extension of Credit in relation to Rule 8.1 Margin D. Rule 50. Purchases and Sales in Cash Account E. Rule 34. Segregation and Limitation of Functions of Members, Brokers and Dealers F. Sec. 30.2.1.2.3. Capabilities G. Sec. 52.1.1. Books and Records Rule H. Sec. 26 in relation to Sec. 54 of the Securities Regulation Code I. Sec. 51 in relation to Sec. 26 of the Securities Regulation Code J. 30.2.6. Supervision Rule K. 30.2.1. Ethical Standards Rules IV. Whether or not the Formal Charge failed to allege the ultimate facts showing any culpability of the Respondents for the alleged violations of the Securities Regulation Code and its Implementing Rules and Regulations. 4 V. Whether or not the Respondent sufficiently denied the allegations of facts in the Formal Charge. 5 THE RULING Before resolving the main issue, it is important to determine at the outset the issue on prescription raised by the Respondents and the issue on whether Mr. Racadio is covered by the definition of Control Person under Section 51 of the SRC, especially that this has been raised by Respondent Racadio. I. Whether or not certain actions have already been barred by prescription Respondents argued that prescription bars the Commission from imposing penalties on actions that have already been barred by prescription. To support their arguments, they cited Article 945 of the Code of Commerce which provides that the liability of exchange brokers in the obligation in which they take part by reason of their office shall prescribe after three years while Article 1149 of the Civil Code states that all other actions whose period are not fixed in this Code or in other laws must be brought within five years from the time the right of action accrues. Thus, the Commission's authority to impose penalties would he limited on actions that have yet to prescribe. 6 The argument of Respondents is misplaced. It appears that the cited provisions of law pertain to the prescriptive period for the enforcement of civil liabilities and not on administrative liabilities. The Supreme Court in the case of Citibank N.A. and the Citigroup Private Bank v. Tanco-Gabaldon, et al. , 7 has pointed out that the SRC does not provide for a prescriptive period for the filing of administrative complaints for violations of the law and that an administrative complaint shall only be barred if it is clear that there is laches on the part of the complainant. Thus: "Section 54 of the SRC provides for the administrative sanctions to be imposed against persons or entities violating the Code, its rules or SEC orders. Just as the SRC did not provide a prescriptive period for the filing of criminal actions, it likewise omitted to provide for the period until when complaints for administrative liability under the law should be initiated. On this score, it is a well-settled principle of law that laches is a recourse in equity, which is, applied only in the absence of statutory law. And though laches applies even to imprescriptible actions, its elements must be proved positively. Ultimately, the question of laches is addressed to the sound discretion of the court and, being an equitable doctrine, its application is controlled by equitable considerations." In this case, laches was not established. In this case, the Commission through the IRC immediately conducted an investigation after knowing about the deterioration of the financial condition of R&L and discovered that the circumstances surrounding the incident is associated with the transactions pertaining to Julieto Sulapas account with VSI. Subsequently, the IRC filed on September 2020 a Formal Charge against the Respondents. Hence, the filing of this action is not barred by prescription nor laches. II. Whether or not Mr. Racadio is a control person within the purview of Section 51 of the SRC Complainant asserted that Mr. Racadio being the President of VSI failed to perform his duty to oversee the day to day operation of the company. This involves, among others, the supervision and evaluation of the acts of other officers and employees of VSI. Applying Section 51 of the SRC, he is jointly and severally liable with VSI officers and employees. 8 On the other hand, Respondent Racadio contends that he is not covered by Section 51.1 of the SRC because he does not control Ms. Aguilar, Mr. Balabis, and/or Ms. Mosenabre "by or through stock ownership, agency or otherwise or in connection with an agreement or understanding." 9 Mr. Racadio also claims that his primary duty to manage the business and operation of VSI as its President does not include controlling all the actions of the registered persons. 10 Respondent Racadio's argument is wrong. Section 51 of the SRC provides the joint and several liability of control persons, thus: Section 51. Liabilities of Controlling Persons, Aider and Abettor and Other Secondary Liability . 51.1. Every person who, by or through stock ownership, agency, or otherwise, or in connection with an agreement or understanding with one or more other persons, controls any person liable under this Code or the rules or regulations of the Commission thereunder, shall also be liable jointly and severally with and to the same extent as such controlled persons to any person to whom such controlled person is liable, unless the controlling person proves that, despite the exercise of due diligence on his part, he has no knowledge of the existence of the facts by reason of which the liability of the controlled person is alleged to exist. Section 51 describes a controlling person as " every person who, by or through stock ownership, agency or otherwise , or in connection with an agreement or understanding with one or more other persons controls any person liable under this Code or the rules or regulations of the Commission thereunder." From the foregoing, it appears that there is no fix and exclusive criteria in the determination of a controlling person. Control is rather an indefinable concept that has been variously defined. However, the 2015 SRC Rules defined control as follows: 3.1.8. Control is the power to determine the financial and operating policies of an entity in order to benefit from its activities. It is presumed to exist when the parent entity owns, directly or through subsidiaries and/or associates, more than fifty percent (50%) of the voting power of an entity. It also exists when the parent entity owns fifty percent (50%) or less of the voting power of an entity, but has any of the following powers: 3.1.8.1. Over more than fifty percent (50%) of the voting rights by virtue of an agreement with other investors; 3.1.8.2. To govern the financial and operating policies of the entity under a statute or agreement; 3.1.8.3. To appoint or remove the majority of the members of the board of directors or equivalent governing body; or 3.1.8.4. To cast the majority of votes at meetings of the board of directors or equivalent governing body. (Emphasis ours) In other words, the term "control" means the possession of the power to determine the financial and operating policies of an entity whether through the ownership of voting securities, by agency, by statute or agreement or otherwise . In Section 51, when reference is made to 'control,' it is understood that the term is intended to include actual control. Hence, persons with authority to control the corporation's financial and operating policies would be considered as controlling persons thereof. Therefore, a person should be presumed to be a controlling person under Section 51 if he occupies a status or position that ordinarily bestows authority to control any person liable/violator or with respect to the matter or affairs that produced violation of the SRC and its IRR. They should be presumed to be controlling persons if they are corporations, majority shareholders, directors, or officers or all such persons who have the authority to control the organizational affairs, employees or personnel as well as to certain duties and responsibilities. In addition, in the case of Carolina Industries, Inc. v. CMS Stock Brokerage, Inc. , 11 the Honorable Supreme Court had the occasion to explain the construction of a law patterned or adopted from another state, thus: "We have previously stated that in case of laws patterned after or adopted from those of the United States, decisions of United States courts construing similar laws are entitled to great weight. Generally speaking, when a statute has been adopted from another State and such statute has previously been construed by the courts of such State or country, this statute is deemed to have been adopted with the construction so given it." On the basis of the foregoing, since the SRC is patterned from the United States, American law and jurisprudence are highly persuasive in construing the coverage of a control person under Section 51. Based on the following American jurisprudence, the courts have upheld the claims for control person liability against individuals associated with brokerage firms, including the individual owners, directors, officers, and supervisors, 12 thus: S. E.C. v. First Jersey Securities, Inc. , 101 F.3d 1450 (2d Cir. 1996) (court upheld a finding of control person liability against the owner of a brokerage firm based on his stake and active role in the firm); San Mateo County Transit Dist. v. Dearman, Fitzgerald and Roberts, Inc. , 979 F.2d 1356 (9th Cir. 1992) (plaintiff made a colorable showing that the individual serving as vice president and treasurer of a brokerage firm was potentially liable as a controlling person for a salesperson's securities fraud); In re J.P. Jeanneret Associates, Inc. , 769 F. Supp. 2d 340 (S.D.N.Y. 2011) (claim stated for control person liability against executives at investment advising firm who exercised discretion over investment advice, oversight, and administrative services that firm provided to clients); S.E.C. v. Fitzgerald , 135 F. Supp. 2d 992 (N.D. Cal. 2001) (claim stated for control person liability against firm's individual majority owner, who also served as chairman of its board of directors and chief executive officer); Piper Jaffray Companies, Inc. v. National Union Fire Ins. Co. of Pittsburgh , 38 F. Supp. 2d 771 (D. Minn. 1999) (officers and directors of an investment firm could be held liable as control persons); Pollack v. Laidlaw Holdings, Inc. , 1995 WL 261518 (S.D.N.Y. 1995) (plaintiffs sufficiently alleged that individual officers and directors of a broker-dealer were control persons of the primary violator, who was the president, chief executive officer, and a director of the firm, as well as the broker for the plaintiffs' accounts); Padgett v. Dapelo , 791 F. Supp. 438 (S.D.N.Y. 1992), aff'd. without opinion, 992 F.2d 320 (2d Cir. 1993) (court upheld an arbitration award imposing joint and several liability on a corporate broker-dealer and its individual directors based on allegations that a broker associated with the firm had engaged in various violations of the Securities Exchange Act, and stated that the arbitrators could have concluded, based on their activities as directors of the broker-dealer, that the individual directors controlled the broker charged with the violations and managed the broker-dealer corporation in such a manner as to be culpable participants in the fraud perpetrated by the broker); Epstein v. Haas Securities Corp. , 731 F. Supp. 1166 (S.D.N.Y. 1990) (court found that the plaintiffs had stated a sufficient claim of control person status against a member of the executive committee for a firm serving as clearing broker for a securities corporation alleged to have manipulated securities in its role as market maker); Binder v. Gordian Securities, Inc. , 742 F. Supp. 663 (N.D. Ga. 1990) (action upheld against individual officer/director alleged to be a controlling person of a securities underwriter and broker-dealer); Metzner v. D.H. Blair & Co. , 689 F. Supp. 262 (S.D.N.Y. 1988) (court found that a complaint sufficiently alleged that the president of a brokerage firm was liable as control person based on his failure to supervise the firm's registered representative); Lazzaro v. Manber , 701 F. Supp. 353 (E.D.N.Y. 1988) (private businessman who allegedly created broker/dealer could have controlled its brokers even though other defendants technically owned corporation); Savino v. E. F. Hutton & Co., Inc , 507 F. Supp. 1225 (S.D.N.Y. 1981) (held that plaintiffs had sufficiently pled causes of action under Section 20(a) against three individuals who occupied positions within the brokerage firm's corporate structure "that gave them the responsibility, and hence the means, of supervising" two account executives); Leavey v. Blinder, Robinson & Co., Inc. , 1986 WL 10556 (E.D. Penn. 1986); In Margaret Hall Foundation, Inc. v. Atlantic Financial Management, Inc. , 572 F. Supp. 1475 (D. Mass. 1983) (an officer, director, and 20% shareholder of investment advisor and a broker-dealer properly alleged to be control person). The United States, no doubt, shares the same interest as the Philippine Government that is to afford the public protection from their investments and to protect the integrity of the capital market. Moreover, Mr. Racadio as the President of VSI, exercised supervision, direction and control over the Corporation and its employees. His authority over them is evident in Article III, Section 3 of VSI Amended By-Laws approved by the Commission on October 15, 2014, which provides: Section 3. The president shall be elected by the Board of Directors from their own number. He shall have the following powers and duties: xxx xxx xxx (b) Have direct and active management of the business and operations of the Corporation , conducting the same according to the orders resolutions and instructions of the Board of Directors, and according to his own discretion whenever and wherever the same is not expressly limited by such orders, resolutions and instructions, and exercise general supervision over all the other officers of the Corporation ; xxx xxx xxx (d) To appoint and at his discretion remove or suspend any or all of the agents, employees and other subordinate personnel of the Corporation , prescribe their duties and fix or change from time to time their respective salaries or wages, and require certain guarantees or bonds in such amount as he may determine to secure the faithful discharge by certain employees or agents of their official trust, and to exercise general superintendence and direction over all the agents, employees and other subordinate personnel of the Corporation, and see to it that their respective duties are properly performed . (Emphasis Supplied) Accordingly, Mr. Racadio has the power of supervision, direction and control over all the officers, agents, employees and other subordinates including the registered persons of VSI which involve oversight of a subordinate with a power to hire and fire them in order to ensure that their respective duties are properly performed and the rules are appropriately followed. Finally, the case of Immaculada L. Garcia vs. Social Security Commission Legal and Collection, Social Security System , 13 had the occasion to explain the liability of directors, trustees or officers of a corporation. The Court held: "Section 31 of the Corporation Code, stipulating on the liability of directors, trustees, or officers, provides: "SEC. 31. Liability of directors, trustees or officers . Directors or trustees who willfully and knowingly vote for or assent to patently unlawful acts of the corporation or who are guilty of gross negligence or bad faith in directing the affairs of the corporation or acquire any personal or pecuniary interest in conflict with their duty as such directors, or trustees shall be liable jointly and severally for all damages resulting therefrom suffered by the corporation, its stockholders or members and other persons. Basic is the rule that a corporation is invested by law with a personality separate and distinct from that of the persons composing it as well as from that of any other legal entity to which it may be related. A corporation is a juridical entity with legal personality separate and distinct from those acting for and in its behalf and, in general, from the people comprising it. Following this, the general rule applied is that obligations incurred by the corporation, acting through its directors, officers and employees, are its sole liabilities. A director, officer, and employee of a corporation are generally not held personally liable for obligations incurred by the corporation. Being a mere fiction of law, however, there are peculiar situations or valid grounds that can exist to warrant the disregard of its independent being and the lifting of the corporate veil. This situation might arise when a corporation is used to evade a just and due obligation or to justify a wrong, to shield or perpetrate fraud, to carry out other similar unjustifiable aims or intentions, or as a subterfuge to commit injustice and so circumvent the law. Thus, Section 31 of the Corporation Law provides: Taking a cue from the above provision, a corporate director, a trustee or an officer, may be held solidarily liable with the corporation in the following instances: 1. When directors and trustees or, in appropriate cases, the officers of a corporation (a) vote for or assent to patently unlawful acts of the corporation; (b) act in bad faith or with gross negligence in directing the corporate affairs; (c) are guilty of conflict of interest to the prejudice of the corporation, its stockholders or members, and other persons. 2. When a director or officer has consented to the issuance of watered stocks or who, having knowledge thereof, did not forthwith file with the corporate secretary his written objection thereto. 3. When a director, trustee or officer has contractually agreed or stipulated to hold himself personally and solidarily liable with the Corporation. 4. When a director , trustee or officer is made, by specific provision of law, personally liable for his corporate action. (Emphasis ours) In this case, the situation of Mr. Racadio, as a director and President of VSI when he failed to perform his duties and responsibilities mandated by the SRC and its IRR as will be discussed in the ruling below, falls exactly under the fourth situation. In this case, Section 51.1 of the SRC imposes a joint and several liabilities of a control person for any act or omission pertaining to the violation of the SRC and its IRR to the same extent as such controlled persons to any person to whom such controlled person is liable. Taken altogether, Mr. Racadio's claim that he is not covered by Section 51.1 of the SRC because he does not control Ms. Aguilar, Mr. Balabis, and/or Ms. Mosenabre does not have a legal leg to stand on. Digressing now from the prescription and controlling person aspect of this case, we now consider the clashing assertions regarding the main issue. The following are the discussions on the second and main issue in the order they are presented: III. Whether or not the respondents violated the following provisions of the Securities Regulation Code and its 2015 Implementing Rules and Regulations: A. On the Charge for violation of Rules 30.2.1.2.4.1, 30.2.1.2.4.3 and 30.2.1.2.4.6 of the 2015 SRC Rules (Venture Securities, Wilfred Racadio, Adora Aguilar and Loreto Balabis) In the Formal Charge, Complainant alleged that VSI failed on its duty to be informed regarding its client Julieto Sulapas, which includes the client's financial situation, investment experience and objectives as exemplified by the acts of its officers and employees, as follows: 14 1. Ms. Aguilar appears not to have knowledge on the background of Sulapas. 2. Mr. Balabis admission that he merely gave Marlo Moron a blank Customer Account Information Form ("CAIF") which was allegedly filled out by Sulapas without his presence. 3. Julieto Sulapas indicated in his CAIF that he does not have any other account with other broker dealers notwithstanding his existing account with another broker, R&L Securities. Ms. Aguilar admitted during the investigative proceedings that she knew that Julieto Sulapas has an account with R & L, but she did not require him to correct this fact in the CAIF. 4. Admission of Ms. Aguilar that there was no verification made for the disclosed source of income of Julieto Sulapas in his declared business, (JS Lumber). 5. The annual income of Julieto Sulapas based on his CAIFs and account ledgers is only Php1 million but he was allowed to transact beyond his financial capability. 6. Mr. Racadio duty to oversee the day to day operations of Venture Securities include the duty to put in place reasonable procedures in identifying the true and full identity of its clients and to ensure that such procedures are being implemented. The commission of foregoing acts of the officers and employees show the failure of Wilfred Racadio to implement the necessary procedures for KYC. For their part, Respondents argued that VSI, Mr. Racadio, Ms. Aguilar, and Mr. Balabis cannot be found liable for the SRC-IRR rules cited relating to the information about clients on the following reasons: 15 1. VSI and its employees were able to determine the trading pattern of Mr. Sulapas based on his numerous buy and sell transactions from 2012 to 2019. It was Mr. Sulapas who primarily gave instructions for his account. During this period, VSI never encountered any issues with Mr. Sulapas on settling his account. This gave VSI the confidence to consider Mr. Sulapas as a knowledgeable and responsible trader who is fully aware of his transactions in the market; 2. Based on his trading pattern, VSI was able to gauge more accurately his financial situation, investment experience, and investment objectives. More importantly, VSI found that Mr. Sulapas can sustain funding for his transactions almost entirely from his trading activities. This can be seen from the fact that he only made a few deposits into his account from 2012-2019. Mr. Sulapas' EQ Trade transactions into his account also form a small portion of his buying and selling transactions with VSI; 3. The trading pattern established by Mr. Sulapas as well as his dealings with VSI from 2012-2019 gave VSI a better idea of his financial situation, investment background, and investment objectives compared to what he initially provided upon account opening and to what he indicates in the CAIF. Based on this information, VSI determined that he has the financial capacity for his numerous buy and sell transactions given that he can sustain funding for his transactions almost entirely from his trading activities; 4. VSI was also able to satisfactorily determine the identity of Mr. Sulapas when he went to the office of VSI to open his account, accomplished his CAIF, interviewed on his financial situation, investment background, and investment objective, and provided his government issued identifications; 5. Ms. Aguilar repeatedly required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead, VSI had duly noted that Mr. Sulapas maintained an account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as fraudulent; 6. As the president of VSI, Mr. Racadio placed reasonable procedures in identifying the true and full identity of clients and to ensure that such procedures are implemented. He ensured that VSI obtain as much information about Mr. Sulapas and his trading activities. He ensured that the determination of his financial capacity is not merely limited to what is stated in the CAIF, but also based on his trading pattern, and on his dealings with VSI. He also made sure that the Company is aware whether it was Mr. Sulapas who was personally executing his numerous buy and sell transactions. In addition, since Mr. Racadio is not a registered person, he cannot be made liable under Rule 30.2.1.2.4.1, Rule 30.2.1.2.4.3, and Rule 30.2.1.2.4.6 of the SRC-IRR; and, 7. The foregoing discussion shows that VSI, Mr. Racadio, Ms. Aguilar, and Mr. Balabis had taken more than reasonable steps to determine the identity, financial situation, investment experience and investment objective of Mr. Sulapas. We reject the Respondents arguments. In the context, the particular SRC Rules violated pertaining to "Information About Clients" or the Know Your Client Rule (KYC) read as follows: Sec. 30.2.1.2.4. Information About Clients . 30.2.1.2.4.1. A registered person should seek from his clients, information about their financial situation, investment experience and investment objectives regarding the services to be provided pursuant to SRC Rule 52.1.6 and other applicable laws. If a client refuses to disclose reasonable information about his financial situation, the registered person shall make the necessary estimate based on his initial evaluation of the information given by the client. xxx xxx xxx Sec. 30.2.1.2.4.3. A registered person shall take all reasonable steps to establish the true and full identity of each of his clients, their financial situation, investment experience, and investment objectives. 30.2.1.2.4.4. Having regard to information disclosed by a client and other circumstances relating to the client which the registered person is or should be aware of through the exercise of due diligence, the registered person shall ensure that such recommendation or solicitation for that client is reasonable and suitable in all circumstances pursuant to Suitability Rule under SRC Rule 30.2.4. xxx xxx xxx Sec. 30.2.1.2.4.6. A registered person should be reasonably satisfied about the identity, address and contact details of the person ultimately responsible for originating the instruction in relation to a transaction, the person who stands to gain the commercial or economic benefit of the transaction and/or bears the commercial or economic risk; Provided, however, that in relation to an investment company, or discretionary account, the person referred to above is the investment company or account, not those who hold a beneficial interest therein. xxx xxx xxx In this case, we noted that proper KYC measures were not implemented on Julieto Sulapas Account on the following reasons: First, Mr. Balabis did not dispute the Complainant allegation that he merely gave blank CAIF to Marlo Moron which was filled out by Mr. Sulapas without his presence. His absence during the opening of account is further bolstered by his statement in his Affidavit 16 dated March 8, 2021, and we quote in part as follows: "5. Mr. Julieto Sulapas ("Mr. Sulapas") is a client that was referred by Mr. Marlo Moron ("Mr. Moron"). I am familiar with Mr. Moron because I always see him at the trading floor of the PSE. I told Mr. Moron that in order for Mr. Sulapas to open an account with Venture Securities, Mr. Sulapas has to go to its office. 6. I know that Mr. Sulapas went to the Office of Venture Securities to open his account because the associated person, Ms. Adora M. Aguilar ("Ms. Aguilar") informed me of his successful account opening. " (Emphasis ours) This fact is also manifest in the alleged process and procedures conducted in the opening of Sulapas account stated in the Respondents answer as follows: 17 "4.4 Mr. Sulapas personally visited the offices of Venture Securities on 29 May 2012 to open his account. He was interviewed by Ms. Grace Machacon, Officer-in-charge of Venture at that time, prior to his account opening regarding his financial situation, investment experience, and investment objectives; 4.5 During his interview, Mr. Sulapas was introduced to Ms. Aguilar. For the creation of his account, Venture Securities required Mr. Sulapas to present his government issued identification cards, accomplish a CAIF, and affix his signature on the signature cards." To note, Mr. Balabis is required to conduct a face-to-face interview with a client in accordance with Item III (G) (1) (a) of VSI written Supervisory Procedures and Compliance Manual 18 which provides: "As a matter of policy, prior to effecting any transaction for or with any client, the assigned licensed salesman/agent shall have already done a face-to-face interview with the client. In this interview the license salesman/agent shall inform the client of the Company's policies regarding acceptance of new accounts, payment scheme and their rules and regulations which the client needs to know in doing business with the Company. Proper identification card shall also be presented like driver's license, SSS/GSIS Cards, Company ID's, passport, residence certificates and other ID's which would prove the identity of the new client. The client must supply the licensed salesman/agent with a complete business and home address wherein correspondences could be sent. A fax number and telephone number where the Company could get in touch with him are also necessary. xxx xxx xxx The licensed salesman/agent who solicited the account has to be sure that information contained in the CAIF is verified to be true and correct." The absence of Mr. Balabis during the account opening coupled with the process and procedures undertaken by Ms. Aguilar together with the violation of the VSI Supervisory Procedures provision, is more than substantial evidence to prove that indeed, Respondents failed to take all reasonable steps to establish the true and full identity of Mr. Sulapas, his financial situation, investment experience, and investment objectives. Second, the Financial Capacity of Mr. Sulapas indicated in his Customer Account Information Forms ("CAIF") 19 is only P1,000,000.00 and based on the documents submitted and as indicated in Ms. Aguilar Affidavit, 20 there were transactions which were evidently beyond the client's declared P1,000,000.000 financial capacity. From the entries recorded in the ledgers 21 of Mr. Sulapas pertaining to SU026 account, he was allowed to transact in numerous transactions (1,047 transactions) in an amount well above his CAIF's stated financial capacity as follows: Number Years Date TRAN REF. # ISSUE Shares Total Debit 1 2012 30-May BUY 39569 CAL 108,200 1,482,032.99 2 2012 31-May BUY 39598 CAL 100,000 1,412,073.00 3 2012 01-Jun BUY 39621 CAL 100,000 1,719,832.50 4 2012 01-Jun BUY 39623 EW 150,000 2,834,722.46 5 2012 04-Jun BUY 39648 CAL 183,700 3,618,211.78 6 2012 05-Jun BUY 39666 CAL 200,000 4,213,489.05 7 2012 06-Jun BUY 39677 CAL 121,400 1,321,100.90 8 2012 06-Jun BUY 39684 VMC 500,000 1,030,913.86 9 2012 07-Jun BUY 39690 LCB 1,000,000 1,438,222.50 10 2012 11-Jun BUY 39709 CAL 152,200 1,989,401.66 11 2012 13-Jun BUY 39724 CAL 200,000 2,679,318.00 12 2012 14-Jun BUY 39752 CAL 300,000 4,054,970.78 13 2012 19-Jun BUY 39782 CAL 200,000 2,546,559.00 14 2012 20-Jun BUY 39796 OV 50,000,000 2,464,087.51 15 2012 22-Jun BUY 39828 NI 118,800 1,050,400.29 16 2012 25-Jun BUY 39838 DIZ 100,000 3,872,137.50 17 2012 27-Jun BUY 39860 TDY 500,000 2,310,318.39 18 2012 29-Jun BUY 39879 LIHC 2,000,000 2,604,892.50 19 2012 29-Jun BUY 39883 RFM 500,000 1,759,982.05 20 2012 02-Jul BUY 39898 MEG 1,000,000 2,252,880.00 21 2012 03-Jul BUY 39917 DIZ 50,000 1,744,966.20 22 2012 04-Jul BUY 39938 GERI 1,000,000 2,045,433.99 23 2012 05-Jul BUY 39957 DIZ 50,000 1,754,279.44 24 2012 06-Jul BUY 39978 BEL 500,000 2,614,950.00 25 2012 06-Jul BUY 39992 LR 300,000 2,684,321.62 26 2012 06-Jul BUY 39993 OPMB 100,000,000 2,011,500.00 27 2012 09-Jul BUY 40007 LC 1,500,000 2,247,851.25 28 2012 09-Jul BUY 40009 LCB 2,000,000 3,097,710.00 29 2012 10-Jul BUY 40030 LC 1,000,000 1,387,935.00 30 2012 11-Jul BUY 40047 PGOLD 200,000 5,632,200.00 31 2012 12-Jul BUY 40054 GREEN 100,000,000 1,508,625.00 32 2012 12-Jul BUY 40070 PGOLD 110,000 2,987,077.50 33 2012 13-Jul BUY 40080 ABA 5,000,000 4,525,875.00 34 2012 17-Jul BUY 40117 ELI 5,000,000 4,508,928.11 35 2012 19-Jul BUY 40156 ABA 2,000,000 1,850,580.00 36 2012 19-Jul BUY 40165 GEO 2,000,000 1,206,900.00 37 2012 24-Jul BUY 40201 ABA 4,000,000 3,942,540.00 38 2012 24-Jul BUY 40202 ABA 2,000,000 2,051,730.00 39 2012 26-Jul BUY 40235 CPG 1,000,000 1,544,248.65 40 2012 31-Jul BUY 40279 PIP 700,000 2,307,924.69 41 2012 31-Jul BUY 40280 PIP 500,000 1,682,438.71 42 2012 01-Aug BUY 40302 TDY 300,000 2,202,592.50 43 2012 01-Aug BUY 40309 VMC 1,410,000 1,981,689.57 44 2012 02-Aug BUY 40311 CAL 200,000 1,110,348.00 45 2012 02-Aug BUY 40330 TDY 500,000 5,089,095.00 46 2012 03-Aug BUY 40349 MJC 500,000 1,634,042.02 47 2012 03-Aug BUY 40368 TDY 201,400 2,349,210.73 48 2012 03-Aug BUY 40369 TDY 142,100 1,839,977.38 49 2012 03-Aug BUY 40370 TDY 238,500 3,319,809.75 50 2012 03-Aug BUY 40371 TDY 261,500 3,680,753.35 51 2012 06-Aug BUY 40381 CAL 186,500 1,312,875.89 52 2012 06-Aug BUY 40390 PGOLD 150,000 4,230,109.09 53 2012 08-Aug BUY 40398 CMT 1,000,000 2,524,432.50 54 2012 08-Aug BUY 40410 TDY 610,000 7,639,375.27 55 2012 08-Aug BUY 40411 TDY 145,200 1,898,087.62 56 2012 09-Aug BUY 40423 ACE 700,000 1,233,049.50 57 2012 09-Aug BUY 40434 TDY 200,000 2,635,065.00 58 2012 10-Aug BUY 40446 CMT 600,000 1,364,802.75 59 2012 13-Aug BUY 40463 BHI 10,000,000 1,757,930.32 60 2012 13-Aug BUY 40465 CMT 500,000 1,181,756.26 61 2012 13-Aug BUY 40476 TDY 127,700 1,591,619.49 62 2012 13-Aug BUY 40477 TDY 130,300 1,636,413.60 63 2012 14-Aug BUY 40484 BHI 10,000,000 1,810,350.00 64 2012 14-Aug BUY 40496 MJC 445,000 1,454,565.94 65 2012 15-Aug BUY 40530 SGI 1,800,000 4,638,519.00 66 2012 16-Aug BUY 40551 GREEN 200,000,000 3,520,125.00 67 2012 23-Aug BUY 40623 PCOR 400,000 4,141,022.75 68 2012 24-Aug BUY 40645 MEG 3,000,000 6,849,157.50 69 2012 28-Aug BUY 40653 AGI 300,000 3,427,596.00 70 2012 28-Aug BUY 40665 MEG 1,000,000 2,293,110.00 71 2012 28-Aug BUY 40671 TDY 116,000 1,506,693.96 72 2012 28-Aug BUY 40672 TDY 184,000 2,401,710.89 73 2012 29-Aug BUY 40681 CMT 500,000 1,242,101.25 74 2012 29-Aug BUY 40686 GREEN 100,000,000 1,609,200.00 75 2012 31-Aug BUY 40705 ABA 3,000,000 2,363,512.50 76 2012 04-Sep BUY 40739 CMT 500,000 1,216,957.50 77 2012 10-Sep BUY 40799 AGI 300,000 3,777,597.00 78 2012 11-Sep BUY 40814 LC 2,000,000 2,413,800.00 79 2012 11-Sep BUY 40821 PX 200,000 3,254,500.40 80 2012 14-Sep BUY 40871 MEG 2,000,000 4,505,760.00 81 2012 14-Sep BUY 40878 PX 200,000 3,198,285.00 82 2012 17-Sep BUY 40888 CYBR 2,000,000 1,810,350.00 83 2012 20-Sep BUY 40918 CMT 1,500,000 3,922,425.00 84 2012 21-Sep BUY 40939 PX 200,000 2,989,089.00 85 2012 25-Sep BUY 40973 PHES 3,000,000 2,283,052.50 86 2012 01-Oct BUY 41038 BLOOM 600,500 6,927,404.85 87 2012 03-Oct Buy 41055 AGI 100,000 1,478,452.51 88 2012 03-Oct BUY 41059 APM 300,000,000 7,844,850.00 89 2012 04-Oct BUY 41088 CMT 1,296,000 3,150,451.52 90 2012 04-Oct BUY 41093 MA 50,000,000 2,564,662.50 91 2012 04-Oct BUY 41094 MAB 20,000,000 1,025,865.00 92 2012 05-Oct BUY 41113 APM 140,000,000 4,646,565.00 93 2012 05-Oct BUY 41118 LR 175,500 1,568,291.14 94 2012 05-Oct BUY 41130 SFI 11,070,000 2,260,423.14 95 2012 08-Oct BUY 41146 APM 100,000,000 5,292,155.93 96 2012 08-Oct BUY 41152 GREEN 200,000,000 3,419,550.00 97 2012 08-Oct BUY 41153 MEG 2,000,000 4,867,830.00 98 2012 08-Oct BUY 41158 SFI 10,000,000 1,910,925.00 99 2012 09-Oct BUY 41172 APM 71,390,000 4,114,131.01 100 2012 09-Oct BUY 41173 APM 28,610,000 1,726,470.45 101 2012 10-Oct BUY 41195 APM 100,000,000 6,436,960.93 102 2012 11-Oct BUY 41233 MA 50,000,000 2,514,375.00 103 2012 11-Oct BUY 41234 PX 200,000 2,931,517.85 104 2012 16-Oct BUY 41287 CLOUD 560,000 1,688,895.63 105 2012 16-Oct BUY 41298 EG 90,000,000 4,877,887.51 106 2012 16-Oct BUY 41300 GREEN 300,000,000 6,336,225.00 107 2012 18-Oct BUY 41349 APM 20,000,000 2,896,560.00 108 2012 19-Oct BUY 41394 APM 30,000,000 4,797,427.50 109 2012 29-Oct BUY 41542 VITA 1,000,000 1,850,580.00 110 2012 05-Nov BUY 41595 APM 49,030,000 6,176,924.26 111 2012 05-Nov BUY 41596 APM 60,970,000 8,071,274.50 112 2012 05-Nov BUY 41601 GREEN 71,000,000 1,499,573.25 113 2012 06-Nov BUY 41627 GREEN 200,000,000 4,626,450.00 114 2012 06-Nov BUY 41637 VITA 1,000,000 1,478,452.51 115 2012 07-Nov BUY 41649 VUL 1,000,000 2,091,960.00 116 2012 08-Nov BUY 41682 BHI 10,000,000 1,659,487.50 117 2012 08-Nov BUY 41710 APM 80,000,000 8,522,936.71 118 2012 09-Nov BUY 41723 APM 20,000,000 2,574,720.00 119 2012 09-Nov BUY 41727 GREEN 100,000,000 2,413,800.00 120 2012 09-Nov BUY 41753 VUL 1,000,000 2,004,228,42 121 2012 14-Nov BUY 41806 APM 30,000,000 4,103,460.00 122 2012 15-Nov BUY 41841 APM 30,000,000 3,982,770.00 123 2012 19-Nov BUY 41898 GREEN 100,000,000 2,514,375.00 124 2012 22-Nov BUY 41991 VUL 1,000,000 1,729,890.00 125 2012 23-Nov BUY 42008 WEB 100,000 1,410,061.50 126 2012 27-Nov BUY 42034 GREEN 83,000,000 1,919,976.75 127 2012 28-Nov BUY 42090 WEB 111,300 1,578,353.65 128 2012 07-Dec BUY 42193 GREEN 200,000,000 4,626,450.00 129 2012 11-Dec BUY 42241 GREEN 200,000,000 5,028,750.01 130 2012 17-Dec BUY 42359 PHES 1,500,000 1,229,740.58 131 2012 18-Dec BUY 42381 EVER 5,000,000 2,058,870.83 132 2013 08-Jan BUY 42633 CPG 777,000 1,356,796.97 133 2013 15-Jan BUY 42812 ZHI 3,000,000 2,081,902.50 134 2013 16-Jan BUY 42849 SLI 2,000,000 1,744,654.42 135 2013 17-Jan BUY 42872 ARA 1,000,000 1,284,553.96 136 2013 17-Jan BUY 42882 CYBR 2,000,000 1,693,612.59 137 2013 17-Jan BUY 42904 ZHI 2,000,000 1,408,050.00 138 2013 31-Jan BUY 43445 PRIM 730,000 1,835,493.75 139 2013 31-Jan BUY 43447 PRIM 494,000 1,233,160.14 140 2013 05-Feb BUY 43315 CHI 300,000 1,504,420.97 141 2013 05-Feb Buy 43350 TA 2,000,000 3,691,102.50 142 2013 14-Feb BUY 43572 DNL 500,000 3,117,825.00 143 2013 18-Feb BUY 43641 DNL 500,000 3,416,170.67 144 2013 18-Feb BUY 43681 TA 2,000,000 3,942,670.76 145 2013 21-Feb BUY 43800 TA 2,000,000 3,862,080.00 146 2013 28-Feb BUY 43987 BEL 700,000 4,083,345.00 147 2013 04-Mar BUY 44097 SLI 1,000,000 1,257,187.50 148 2013 04-Mar BUY 44111 TA 2,000,000 4,721,050.85 149 2013 05-Mar BUY 44139 BLOOM 300,000 4,820,805.15 150 2013 06-Mar BUY 44204 SLI 2,000,000 2,604,892.50 151 2013 08-Mar BUY 44310 TA 2,000,000 5,329,881.62 152 2013 12-Mar BUY 44403 TA 1,000,000 2,423,857.50 153 2013 19-Mar BUY 44565 TA 2,000,000 4,547,257.26 154 2013 20-Mar BUY 44593 MMI 150,000 1,156,612.51 155 2013 22-Mar BUY 44668 BLOOM 100,000 1,367,803.92 156 2013 27-Mar BUY 44812 BHI 20,000,000 2,755,755.00 157 2013 15-Apr BUY 45507 MPI 700,000 4,212,757.88 158 2013 15-Apr BUY 45508 TA 778,000 1,885,761.13 159 2013 15-Apr BUY 45509 TA 1,222,000 2,949,663.60 160 2013 16-Apr BUY 45297 MPI 500,000 2,831,186.25 161 2013 16-Apr BUY 45310 TA 2,000,000 4,666,680.00 162 2013 17-Apr BUY 45313 ABS 44,700 1,910,673.57 163 2013 17-Apr BUY 45359 VUL 916,000 1,631,648.35 164 2013 17-Apr BUY 45360 VUL 1,134,000 2,047,978.56 165 2013 18-Apr BUY 45373 ACR 2,000,000 2,935,532.82 166 2013 18-Apr BUY 45438 VUL 2,000,000 4,103,460.00 167 2013 22-Apr BUY 45526 APC 7,000,000 6,336,225.00 168 2013 22-Apr BUY 45578 PNB 50,000 5,431,050.00 169 2013 23-Apr BUY 45680 SINO 8,000,000 3,193,205.96 170 2013 24-Apr BUY 45859 TA 1,000,000 2,665,237.50 171 2013 24-Apr BUY 45861 TA 2,000,000 5,431,050.00 172 2013 25-Apr BUY 45864 SUN 2,000,000 1,890,810.00 173 2013 26-Apr BUY 45890 MCP 200,000 2,874,220.28 174 2013 29-Apr BUY 45952 TA 1,000,000 2,765,812.50 175 2013 30-Apr BUY 45999 SLI 1,342,000 1,368,051.32 176 2013 30-Apr BUY 46053 TA 2,000,000 5,732,775.01 177 2013 03-May BUY 46091 MMI 338,000 1,230,333.97 178 2013 03-May BUY 46107 TA 3,000,000 8,146,575.00 179 2013 06-May BUY 46140 H2O 121,500 1,063,128.04 180 2013 07-May BUY 46228 TA 1,971,000 5,257,920.21 181 2013 07-May BUY 46888 BHI 20,000,000 4,002,885.00 182 2013 14-May BUY 46549 TA 2,000,000 5,531,625.00 183 2013 21-May BUY 46791 VUL 1,500,000 3,240,858.41 184 2013 24-May BUY 46902 MEG 2,000,000 8,066,115.00 185 2013 29-May BUY 47128 LC 4,000,000 3,073,672.59 186 2013 29-May BUY 47131 LCB 4,000,000 3,178,170.00 187 2013 31-May BUY 47234 LCB 4,000,000 3,017,250.00 188 2013 03-Jun BUY 47269 SMDC 500,000 4,274,437.50 189 2013 04-Jun BUY 47291 COSCO 500,000 5,310,360.01 190 2013 04-Jun BUY 47298 MEG 3,000,000 11,334,802.51 191 2013 06-Jun BUY 47367 LCB 1,600,000 1,062,072.00 192 2013 10-Jun BUY 47425 DMPL 150,000 4,377,526.88 193 2013 10-Jun BUY 47437 SUN 2,000,000 1,799,739.34 194 2013 17-Jun BUY 47591 MEG 1,500,000 5,317,460.59 195 2013 18-Jun BUY 47617 TA 1,000,000 2,313,225.00 196 2013 19-Jun BUY 47637 TA 1,000,000 2,309,101.43 197 2013 24-Jun BUY 47734 MCP 300,000 2,715,525.00 198 2013 28-Jun BUY 47879 MEG 3,000,000 10,047,442.50 199 2013 03-Jul BUY 48073 MEG 3,000,000 9,685,372.50 200 2013 04-Jul BUY 48022 LC 4,000,000 2,312,520.97 201 2013 04-Jul BUY 48038 MCP 109,400 1,122,919.88 202 2013 04-Jul BUY 48076 MMI 1,000,000 1,196,842.51 203 2013 11-Jul BUY 48274 COSCO 390,500 4,023,022.10 204 2013 11-Jul BUY 48275 COSCO 609,500 6,311,489.58 205 2013 11-Jul BUY 48276 LC 5,000,000 2,609,921.25 206 2013 12-Jul BUY 48283 BLOOM 500,000 5,257,793.49 207 2013 16-Jul BUY 48484 LC 10,000,000 5,531,625.00 208 2013 18-Jul BUY 48587 TA 2,000,000 4,928,175.00 209 2013 19-Jul BUY 48636 MER 50,000 14,120,730.00 210 2013 22-Jul BUY 48680 MA 100,000,000 3,117,825.00 211 2013 23-Jul BUY 48758 SMPH 400,000 7,442,501.74 212 2013 23-Jul BUY 48776 TA 419,000 1,131,046.32 213 2013 23-Jul BUY 48844 TA 1,631,000 4,429,021.27 214 2013 24-Jul BUY 48841 TA 2,000,000 5,626,416.95 215 2013 25-Jul BUY 48848 ALPHA 29,200 1,468,395.00 216 2013 29-Jul BUY 49001 LC 10,000,000 6,637,950.00 217 2013 31-Jul BUY 49152 LC 1,703,000 1,061,931.21 218 2013 31-Jul BUY 49312 TA 500,000 1,292,006.56 219 2013 01-Aug BUY 49180 LC 10,000,000 6,436,800.01 220 2013 08-Aug BUY 49293 TSI 100,000 1,158,624.00 221 2013 14-Aug BUY 49367 SECB 50,000 6,739,530.75 222 2013 15-Aug BUY 49414 LCB 5,000,000 3,419,550.00 223 2013 22-Aug BUY 49554 IRC 600,000 1,005,448.26 224 2013 23-Aug BUY 49598 LCB 5,000,000 3,067,537.50 225 2013 30-Aug BUY 49821 SUN 777,000 1,410,413.53 226 2013 30-Aug BUY 49822 SUN 1,786,000 3,311,130.14 227 2013 02-Sep BUY 49847 SMPH 500,000 8,146,575.00 228 2013 04-Sep BUY 49917 SMPH 159,000 2,558,628.00 229 2013 09-Sep BUY 49997 SMPH 500,000 8,196,862.50 230 2013 10-Sep BUY 50039 GSMI 100,000 2,162,493.25 231 2013 16-Sep BUY 50236 GSMI 100,000 2,110,536.21 232 2013 17-Sep BUY 50317 TSI 111,600 1,351,828.58 233 2013 17-Sep BUY 50318 TSI 198,000 2,988,063.14 234 2013 17-Sep BUY 50319 TSI 500,000 8,277,322.50 235 2013 01-Oct BUY 50692 GSMI 100,000 2,673,484.65 236 2013 03-Oct BUY 50785 GSMI 86,900 2,320,114.39 237 2013 07-Oct BUY 50843 BHI 20,000,000 3,017,250.00 238 2013 09-Oct BUY 50943 EMP 220,600 2,263,058.18 239 2013 10-Oct BUY 51034 MCP 648,400 7,825,135.30 240 2013 14-Oct BUY 51125 MARC 1,000,000 2,614,950.00 241 2013 17-Oct BUY 51176 GSMI 50,000 1,282,331.25 242 2013 21-Oct BUY 51315 MARC 1,500,000 4,974,077.42 243 2013 24-Oct BUY 51468 LOTO 70,000 1,159,649,87 244 2013 24-Oct BUY 51472 MARC 1,000,000 3,253,601.25 245 2013 30-Oct BUY 51581 TUGS 1,700,000 3,382,618.86 246 2013 04-Nov BUY 51756 MARC 798,000 2,773,838.39 247 2013 06-Nov BUY 51768 MARC 1,000,000 3,505,038.75 248 2013 07-Nov BUY 51850 TA 9,000,000 16,941,687.78 249 2013 07-Nov BUY 51851 TA 4,000,000 8,609,220.00 250 2013 08-Nov BUY 51870 BKD 512,000 1,197,848.25 251 2013 08-Nov BUY 51871 BKD 1,988,000 4,997,159.40 252 2013 08-Nov BUY 51878 LTG 700,000 10,912,387.51 253 2013 13-Nov BUY 52080 LMG 265,000 1,289,371.50 254 2013 14-Nov BUY 52140 VMC 682,000 1,267,265.11 255 2013 05-Dec BUY 52551 GMA7 200,000 1,790,018.76 256 2013 16-Dec BUY 52728 SMPH 600,000 9,351,873.84 257 2013 17-Dec BUY 52793 SMPH 500,000 7,533,067.51 258 2013 20-Dec BUY 52916 BHI 12,720,000 1,952,472.54 259 2013 20-Dec BUY 52941 SMPH 100,000 1,458,337.50 260 2013 26-Dec BUY 52985 VMC 717,000 1,478,301.64 261 2014 21-Jan BUY 53608 MA 150,000,000 2,866,387.50 262 2014 22-Jan BUY 53686 MA 100,000,000 1,910,925.00 263 2014 27-Jan BUY 53808 MRC 9,000,000 1,088,945.64 264 2014 29-Jan BUY 53859 MA 150,000,000 3,017,250.00 265 2014 12-Feb BUY 54183 MA 150,000,000 3,017,250.00 266 2014 17-Feb BUY 54228 MA 150,000,000 2,866,387.50 267 2014 20-Feb BUY 54358 VMC 500,000 2,011,007.19 268 2014 21-Feb BUY 54423 VMC 500,000 1,959,522.84 269 2014 26-Feb BUY 54533 LRW 1,310,000 1,247,783.74 270 2014 03-Mar BUY 54658 VMC 326,000 1,262,316.82 271 2014 04-Mar BUY 54685 MA 100,000,000 1,810,350.00 272 2014 07-Mar BUY 54873 SCC 10,000 4,023,000.00 273 2014 10-Mar BUY 54889 BHI 15,000,000 2,358,483.76 274 2014 21-Mar BUY 55215 MARC 500,000 2,036,643.75 275 2014 26-Mar BUY 55267 CYBR 2,000,000 1,337,647.50 276 2014 01-Apr BUY 55397 LRW 1,190,000 1,615,737.38 277 2014 02-Apr BUY 55508 LRW 810,000 1,059,054.75 278 2014 03-Apr BUY 55558 VMC 500,000 2,360,374.56 279 2014 03-Apr BUY 55564 SLI 2,000,000 1,462,400.73 280 2014 08-Apr BUY 55680 DD 999,000 3,928,550.02 281 2014 08-Apr BUY 55712 DD 1,001,000 4,126,511.80 282 2014 10-Apr BUY 55732 DD 1,000,000 3,881,058.51 283 2014 11-Apr BUY 55802 MB 845,000 1,062,323.44 284 2014 14-Apr BUY 55851 MB 600,000 1,031,899.51 285 2014 30-Apr BUY 56334 MARC 516,000 2,262,696.13 286 2014 06-May BUY 56443 CNPF 500,000 7,794,562.50 287 2014 07-May BUY 56516 TA 2,000,000 4,847,151.77 288 2014 13-May BUY 56840 BKD 682,000 2,051,227.12 289 2014 13-May BUY 56843 CPM 2,000,000 1,981,327.50 290 2014 13-May BUY 56847 CYBR 5,000,000 4,805,775.23 291 2014 16-May BUY 57035 MA 100,000,000 2,112,075.00 292 2014 16-May BUY 57036 MAB 70,000,000 1,721,341.13 293 2014 21-May BUY 57238 PHA 5,354,000 2,881,795.58 294 2014 21-May BUY 57265 PHA 2,646,000 1,516,892.26 295 2014 28-May BUY 57489 DD 361,400 3,634,780.50 296 2014 29-May BUY 57579 HOUSE 500,000 4,123,575.00 297 2014 30-May BUY 57618 DD 394,700 3,731,513.54 298 2014 02-Jun BUY 57664 DD 400,000 4,012,318.94 299 2014 05-Jun BUY 57985 SUN 1,465,000 2,333,863.00 300 2014 06-Jun BUY 58064 SINO 4,130,000 6,415,156.27 301 2014 06-Jun BUY 58065 SINO 870,000 1,431,976.80 302 2014 10-Jun BUY 58225 SINO 2,000,000 2,655,180.00 303 2014 10-Jun BUY 58239 VITA 2,000,000 1,857,740.94 304 2014 17-Jun BUY 58465 IMI 198,900 1,091,133.16 305 2014 20-Jun BUY 58627 DAVIN 1,000,000 3,918,774.13 306 2014 20-Jun BUY 58676 PX 560,000 6,683,234.91 307 2014 24-Jun BUY 58776 IMI 300,000 1,810,153.88 308 2014 24-Jun BUY 58804 NOW 2,000,000 1,609,200.00 309 2014 25-Jun BUY 58824 COAL 1,100,000 1,766,469.13 310 2014 26-Jun BUY 58907 SINO 3,000,000 4,525,875.00 311 2014 30-Jun BUY 59024 OM 1,912,000 1,898,594.50 312 2014 03-Jul BUY 59134 APX 800,000 4,125,586.50 313 2014 07-Jul BUY 59209 ATN 501,000 1,189,158.57 314 2014 09-Jul BUY 59326 ION 3,313,000 2,954,410.74 315 2014 09-Jul BUY 59365 VITA 2,000,000 2,505,715.50 316 2014 21-Jul BUY 59541 PX 330,000 4,055,787.45 317 2014 22-Jul BUY 59577 PXP 136,900 1,169,776.76 318 2014 23-Jul BUY 59603 PXP 201,100 1,638,132.42 319 2014 24-Jul BUY 59621 CEI 14,210,000 1,810,812.66 320 2014 28-Jul BUY 59679 SCC 20,000 7,040,250.00 321 2014 05-Aug BUY 59858 APC 5,000,000 4,727,025.00 322 2014 11-Aug BUY 60025 COAL 969,000 1,289,019.50 323 2014 12-Aug BUY 60074 CEI 9,470,000 1,536,454.11 324 2014 12-Aug BUY 60112 VUL 1,000,000 1,910,925.00 325 2014 13-Aug BUY 60138 CEI 20,000,000 3,356,238.04 326 2014 13-Aug BUY 60164 VUL 2,000,000 4,204,035.00 327 2014 20-Aug BUY 60353 CEI 13,290,000 1,967,860.52 328 2014 20-Aug BUY 60384 VUL 569,000 1,054,901.00 329 2014 28-Aug BUY 60576 TAPET 181,000 1,420,179.35 330 2014 02-Sep BUY 60689 CEI 9,490,000 1,547,296.10 331 2014 02-Sep BUY 60690 CEI 10,510,000 1,733,550.92 332 2014 02-Sep BUY 60714 IS 18,000,000 4,495,199.62 333 2014 03-Sep BUY 60808 MRC 20,000,000 3,459,780.00 334 2014 11-Sep BUY 61128 CMT 1,000,000 2,987,077.50 335 2014 12-Sep BUY 61212 MAC 483,000 1,387,130.41 336 2014 16-Sep BUY 61317 CEI 11,150,000 1,937,406.40 337 2014 16-Sep BUY 61358 TAPET 174,000 1,030,270.18 338 2014 18-Sep BUY 61434 CPM 2,000,000 2,102,017.51 339 2014 23-Sep BUY 61540 CEI 10,000,000 1,887,651.96 340 2014 24-Sep BUY 61641 RWM 300,000 2,926,646.01 341 2014 25-Sep BUY 61679 MED 2,000,000 1,601,968.66 342 2014 25-Sep BUY 61703 IMI 254,000 2,222,858.36 343 2014 25-Sep BUY 61704 IMI 182,900 1,618,759.66 344 2014 02-Oct BUY 61904 AR 400,000,000 3,293,026.65 345 2014 07-Oct BUY 62013 IS 5,000,000 1,307,475.00 346 2014 08-Oct BUY 62120 IS 5,000,000 1,408,050.00 347 2014 14-Oct BUY 62228 AR 300,000,000 2,202,592.50 348 2014 21-Oct BUY 62430 CEI 7,500,000 1,312,503.75 349 2014 21-Oct BUY 62435 FPI 2,370,000 1,048,796.10 350 2014 21-Oct BUY 62440 IS 7,500,000 3,216,639.95 351 2014 21-Oct BUY 62450 WIN 5,000,000 1,858,374.57 352 2014 30-Oct BUY 62823 SFI 5,000,000 1,257,187.50 353 2014 31-Oct BUY 62900 SFI 20,000,000 5,833,350.00 354 2014 04-Nov BUY 62990 IS 23,200,000 18,717,007.51 355 2014 04-Nov BUY 63008 SFI 4,760,000 1,148,968.80 356 2014 05-Nov BUY 63068 IS 43,385,000 31,696,824.76 357 2014 05-Nov BUY 63082 AR 483,000,000 4,265,989.20 358 2014 05-Nov BUY 63084 BHI 29,000,000 2,597,047.65 359 2014 06-Nov BUY 63132 BHI 18,000,000 1,692,677.25 360 2014 06-Nov BUY 63154 SFI 4,800,000 1,013,735.65 361 2014 06-Nov BUY 63161 LRW 766,000 4,314,265.20 362 2014 06-Nov BUY 63162 LRW 195,000 1,096,317.79 363 2014 07-Nov BUY 63197 SSI 489,500 4,029,913.52 364 2014 07-Nov BUY 63198 SSI 1,310,500 10,807,890.08 365 2014 11-Nov BUY 63277 FPI 2,900,000 1,370,837.25 366 2014 11-Nov BUY 63282 SFI 10,180,000 2,161,759.05 367 2014 12-Nov BUY 63327 IS 25,241,000 20,020,620.43 368 2014 12-Nov BUY 63332 SUN 1,081,000 1,703,670.11 369 2014 12-Nov BUY 63333 SUN 1,869,000 3,001,902.25 370 2014 14-Nov BUY 63423 PLC 1,900,000 4,107,563.46 371 2014 17-Nov BUY 63437 FPI 4,800,000 2,100,006.00 372 2014 17-Nov BUY 63480 LRW 281,000 1,865,263.94 373 2014 18-Nov BUY 63499 FPI 5,000,000 2,187,506.25 374 2014 18-Nov BUY 63526 SUN 900,000 1,261,994.98 375 2014 19-Nov BUY 63565 IS 9,000,000 7,241,400.00 376 2014 19-Nov BUY 63569 SFI 5,900,000 1,290,528.12 377 2014 21-Nov BUY 63688 TUGS 2,649,000 4,928,667.81 378 2014 21-Nov BUY 63689 TUGS 875,000 1,653,422.85 379 2014 21-Nov BUY 63690 TUGS 1,326,000 2,543,441.17 380 2014 24-Nov BUY 63748 LRW 690,000 4,654,026.67 381 2014 25-Nov BUY 63811 LRW 198,300 1,256,473.41 382 2014 26-Nov BUY 63857 ROCK 990,000 2,186,922.92 383 2014 27-Nov BUY 63896 CHIPS 190,000 3,152,891.48 384 2014 28-Nov BUY 63959 IS 20,898,000 13,298,469.02 385 2014 01-Dec BUY 63990 IS 9,995,000 6,023,758.59 386 2014 01-Dec BUY 63992 PSPC 1,970,000 6,566,813.31 387 2014 01-Dec BUY 63993 PSPC 1,000,000 3,419,550.00 388 2014 02-Dec BUY 64023 CEI 15,920,000 2,364,819.99 389 2014 02-Dec BUY 64029 LRW 411,000 2,519,735.65 390 2014 03-Dec BUY 64085 X 1,190,000 10,456,782.75 391 2014 04-Dec BUY 64114 X 490,000 4,188,948.75 392 2014 05-Dec BUY 64143 CMT 1,073,000 3,001,489.89 393 2014 05-Dec BUY 64144 CMT 466,000 1,380,532.67 394 2014 05-Dec BUY 64148 X 500,000 3,952,597.50 395 2014 10-Dec BUY 64193 LRW 252,300 1,395,367.48 396 2014 10-Dec BUY 64195 X 522,700 4,745,469.45 397 2014 10-Dec BUY 64196 X 467,300 4,248,682.26 398 2014 11-Dec BUY 64225 IS 2,950,000 1,482,038.00 399 2014 11-Dec BUY 64230 X 391,000 3,460,454.87 400 2014 11-Dec BUY 64231 X 122,100 1,087,399.82 401 2014 11-Dec BUY 64232 X 396,900 3,552,695.20 402 2014 11-Dec BUY 64236 IS 7,900,000 4,048,445.47 403 2014 12-Dec BUY 64257 IS 10,330,000 4,765,092.64 404 2014 16-Dec BUY 64325 PRMX 355,000 1,749,492.07 405 2014 16-Dec BUY 64338 IS 19,210,000 8,091,057.59 406 2014 17-Dec BUY 64374 UPM 100,000,000 1,307,475.00 407 2014 17-Dec BUY 64375 X 495,000 4,575,758.19 408 2014 18-Dec BUY 64413 X 495,000 4,604,525.66 409 2014 19-Dec BUY 64465 PSPC 553,000 1,582,557.69 410 2014 22-Dec BUY 64504 MAXS 173,800 4,149,548.49 411 2014 22-Dec BUY 64506 PSPC 950,000 2,904,606.00 412 2014 23-Dec BUY 64544 MARC 210,900 1,479,837.43 413 2014 23-Dec BUY 64545 MARC 779,100 5,482,151.17 414 2014 29-Dec BUY 64570 MAXS 56,300 1,391,057.87 415 2014 29-Dec BUY 64571 MAXS 274,600 6,904,473.75 416 2015 05-Jan BUY 64641 MAXS 50,000 1,237,072.50 417 2015 06-Jan BUY 64638 UNI 3,000,000 1,053,673.99 418 2015 07-Jan BUY 64676 LC 9,900,000 2,688,369.75 419 2015 08-Jan BUY 64717 IS 20,140,000 8,605,800.46 420 2015 08-Jan BUY 64720 LRW 418,000 2,148,855.27 421 2015 08-Jan BUY 64721 LRW 372,000 1,944,285.72 422 2015 12-Jan BUY 64826 IS 2,580,000 1,146,756.14 423 2015 13-Jan BUY 64846 IS 19,900,000 8,389,815.65 424 2015 14-Jan BUY 64888 FNI 1,454,000 5,103,175.50 425 2015 14-Jan BUY 64889 FNI 1,446,000 5,284,673.17 426 2015 14-Jan BUY 64891 MED 1,950,000 1,104,816.38 427 2015 14-Jan BUY 64893 UNI 3,100,000 1,128,451.51 428 2015 19-Jan BUY 64931 IS 10,530,000 4,130,313.53 429 2015 20-Jan BUY 64960 ISM 721,000 1,411,278.46 430 2015 20-Jan BUY 64961 ISM 1,400,000 2,876,445.00 431 2015 22-Jan BUY 65032 UNI 5,300,000 2,130,178.50 432 2015 23-Jan BUY 65065 OV 99,000,000 2,090,954.25 433 2015 23-Jan BUY 65071 X 480,000 5,783,464.80 434 2015 27-Jan BUY 65138 CAL 300,000 1,309,486.51 435 2015 28-Jan BUY 65169 IS 20,000,000 7,844,850.01 436 2015 30-Jan BUY 65247 HOUSE 490,000 4,435,357.51 437 2015 02-Feb BUY 65303 LRI 103,700 1,220,564.11 438 2015 02-Feb BUY 65304 LRI 186,000 2,207,420.10 439 2015 03-Feb BUY 65345 CAL 390,000 1,802,947.67 440 2015 04-Feb BUY 65377 IS 35,680,000 10,215,503.32 441 2015 04-Feb BUY 65379 SFI 7,990,000 1,324,773.89 442 2015 06-Feb BUY 65440 IS 19,980,000 5,124,195.69 443 2015 09-Feb BUY 65490 OM 2,016,000 1,622,928.50 444 2015 12-Feb BUY 65643 IS 20,000,000 5,028,750.01 445 2015 13-Feb BUY 65682 CPM 1,525,000 1,712,389.95 446 2015 13-Feb BUY 65689 NI 490,000 1,621,973.03 447 2015 17-Feb BUY 65764 FNI 1,990,000 5,433,866.10 448 2015 18-Feb BUY 65800 FNI 990,000 2,628,628.20 449 2015 18-Feb BUY 65823 FPI 4,940,000 1,930,537.13 450 2015 18-Feb BUY 65825 LRW 238,000 1,096,247.38 451 2015 18-Feb BUY 65826 LRW 309,000 1,429,985.39 452 2015 18-Feb BUY 65829 LRW 268,000 1,266,641.55 453 2015 18-Feb BUY 65831 OM 1,900,000 1,566,958.50 454 2015 20-Feb BUY 65874 UNI 11,230,000 6,805,538.14 455 2015 23-Feb BUY 65926 UNI 11,379,000 7,286,809.62 456 2015 24-Feb BUY 65981 SFI 12,990,000 2,814,088.51 457 2015 24-Feb BUY 65982 SFI 13,820,000 3,235,457.51 458 2015 24-Feb BUY 65989 UNI 3,900,000 3,441,676.50 459 2015 25-Feb BUY 66021 JAS 490,000 1,999,933.87 460 2015 26-Feb BUY 66059 IS 54,410,000 17,100,163.83 461 2015 27-Feb BUY 66084 IS 44,970,000 13,934,766.83 462 2015 03-Mar BUY 66167 SFI 8,160,000 1,666,045.00 463 2015 03-Mar BUY 66168 SFI 4,940,000 1,039,663.87 464 2015 05-Mar BUY 66251 2GO 248,100 2,038,107.12 465 2015 06-Mar BUY 66298 IS 10,000,000 3,168,112.51 466 2015 09-Mar BUY 66336 IS 18,740,000 5,928,292.80 467 2015 10-Mar BUY 66391 UNI 2,490,000 1,517,576.17 468 2015 16-Mar BUY 66545 GTCAP 10,000 13,474,168.56 469 2015 16-Mar BUY 66577 NI 534,000 1,995,729.83 470 2015 16-Mar BUY 66578 NI 384,000 1,540,617.93 471 2015 16-Mar BUY 66579 NI 572,000 2,301,156.00 472 2015 17-Mar BUY 66604 IS 14,590,000 4,740,904.35 473 2015 17-Mar BUY 66615 FNI 825,000 1,930,869.02 474 2015 17-Mar BUY 66616 FNI 665,000 1,571,735.82 475 2015 19-Mar BUY 66698 2GO 300,000 2,171,780.34 476 2015 19-Mar BUY 66699 2GO 305,000 2,292,607.14 477 2015 19-Mar BUY 66707 IS 13,260,000 3,851,067.05 478 2015 20-Mar BUY 66745 IS 3,760,000 1,077,761.70 479 2015 23-Mar BUY 66754 2GO 201,900 1,469,881.48 480 2015 24-Mar BUY 66846 PPC 498,000 2,036,110.70 481 2015 27-Mar BUY 66977 ACR 1,168,000 2,660,329.45 482 2015 27-Mar BUY 66978 ACR 5,384,000 12,451,476.66 483 2015 27-Mar BUY 66980 BHI 29,000,000 3,500,010.00 484 2015 27-Mar BUY 66988 PRMX 195,000 1,568,970.00 485 2015 30-Mar BUY 67043 PPC 545,000 2,055,501.57 486 2015 01-Apr BUY 67146 UNI 7,710,000 3,325,914.70 487 2015 06-Apr BUY 67163 NIKL 282,400 6,773,967.62 488 2015 06-Apr BUY 67179 NIKL 200,000 4,792,398.75 489 2015 07-Apr BUY 67203 FNI 1,593,000 3,641,187.13 490 2015 07-Apr BUY 67205 NI 995,000 4,032,876.48 491 2015 07-Apr BUY 67207 NIKL 352,400 8,546,043.82 492 2015 07-Apr BUY 67208 NIKL 247,600 6,049,309.67 493 2015 08-Apr BUY 67228 NIKL 217,600 5,240,601.17 494 2015 08-Apr BUY 67243 FNI 1,044,000 2,333,128.80 495 2015 08-Apr BUY 67244 FNI 495,000 1,162,395.56 496 2015 08-Apr BUY 67247 NIKL 300,000 7,241,400.00 497 2015 10-Apr BUY 67276 MEG 195,000 1,151,146.25 498 2015 13-Apr BUY 67304 GERI 2,195,000 3,527,145.14 499 2015 13-Apr BUY 67306 MEG 1,000,000 5,853,465.00 500 2015 13-Apr BUY 67307 GEO 7,000,000 3,102,738.75 501 2015 13-Apr BUY 67308 GEO 2,990,000 1,383,308.55 502 2015 16-Apr BUY 67404 NIKL 232,200 4,578,668.84 503 2015 16-Apr BUY 67405 NIKL 107,500 2,156,490.93 504 2015 16-Apr BUY 67406 NIKL 305,300 6,138,890.82 505 2015 16-Apr BUY 67408 MEG 495,000 2,663,477.45 506 2015 21-Apr BUY 67476 POPI 2,000,000 1,831,571.33 507 2015 21-Apr BUY 67477 POPI 2,900,000 2,750,726.25 508 2015 27-Apr BUY 67574 IS 6,200,000 1,682,770.61 509 2015 27-Apr BUY 67603 CAL 670,000 3,219,204.60 510 2015 28-Apr BUY 67628 CROWN 990,000 2,787,939.00 511 2015 04-May BUY 67714 POPI 1,443,500 1,649,083.03 512 2015 05-May BUY 67737 POPI 1,480,000 1,741,104.11 513 2015 05-May BUY 67744 TA 1,881,000 4,714,583.88 514 2015 07-May BUY 67798 ATNB 4,920,000 1,688,905.70 515 2015 08-May BUY 67814 TAPET 195,000 1,113,968.70 516 2015 08-May BUY 67817 MAXS 398,700 11,578,400.20 517 2015 08-May BUY 67818 MAXS 91,300 2,662,069.39 518 2015 11-May BUY 67861 LRW 250,000 1,156,612.50 519 2015 14-May BUY 67863 TA 1,130,000 2,606,853.71 520 2015 12-May BUY 67890 BRN 3,000,000 2,413,800.00 521 2015 13-May BUY 67913 GTCAP 2,000 2,812,077.00 522 2015 14-May BUY 67985 POPI 1,059,000 1,251,776.56 523 2015 15-May BUY 68000 POPI 1,000,000 1,082,891.03 524 2015 18-May BUY 68003 ICT 40,620 4,568,506.73 525 2015 18-May BUY 68004 ICT 22,100 2,507,214.06 526 2015 18-May BUY 68024 LIB 676,000 1,970,988.37 527 2015 19-May BUY 68043 APC 2,990,000 2,335,975.08 528 2015 19-May BUY 68047 CAL 346,000 1,494,946.80 529 2015 22-May BUY 68126 PXP 990,000 2,156,730.29 530 2015 25-May BUY 68140 GTCAP 2,000 2,866,387.50 531 2015 29-May BUY 68228 FNI 7,262,000 12,193,783.42 532 2015 29-May BUY 68230 MHC 2,990,000 2,100,508.87 533 2015 29-May BUY 68233 PXP 990,000 2,079,780.38 534 2015 01-Jun BUY 68255 FNI 3,617,000 5,527,954.01 535 2015 03-Jun BUY 68295 CROWN 2,776,000 6,011,347.63 536 2015 04-Jun BUY 68312 PHA 5,800,000 4,339,016.72 537 2015 05-Jun BUY 68325 FNI 990,000 1,543,323.37 538 2015 05-Jun BUY 68326 LIB 500,000 1,483,481.25 539 2015 08-Jun BUY 68341 FNI 2,990,000 5,190,283.51 540 2015 17-Jun BUY 68441 POPI 3,524,000 5,204,434.41 541 2015 17-Jun BUY 68445 TAPET 90,000 1,071,053.34 542 2015 19-Jun BUY 68479 TAPET 227,600 2,698,982.43 543 2015 19-Jun BUY 68480 POPI 888,000 1,393,245.36 544 2015 23-Jun BUY 68499 ICT 15,000 1,667,030.63 545 2015 25-Jun BUY 68537 POPI 1,000,000 1,780,177.50 546 2015 29-Jun BUY 68566 ICT 15,000 1,667,030.63 547 2015 30-Jun BUY 68595 POPI 2,500,000 5,016,057.44 548 2015 02-Jul BUY 68618 ICT 15,000 1,697,203.13 549 2015 03-Jul BUY 68643 IS 11,900,000 2,661,888.35 550 2015 07-Jul BUY 68670 ATN 19,950,000 5,616,359.44 551 2015 08-Jul BUY 68689 AR 520,000,000 3,500,010.00 552 2015 08-Jul BUY 68692 POPI 590,000 1,102,483.04 553 2015 09-Jul BUY 68718 AR 298,000,000 1,828,252.35 554 2015 14-Jul BUY 68773 AR 498,000,000 3,255,612.75 555 2015 15-Jul BUY 68794 LIB 990,000 3,082,834.98 556 2015 16-Jul BUY 68807 PLC 1,990,000 3,042,192.60 557 2015 22-Jul BUY 68873 MCP 495,000 3,584,493.00 558 2015 24-Jul BUY 68908 GTCAP 2,000 2,836,215.00 559 2015 27-Jul BUY 68938 PPC 559,000 2,154,457.30 560 2015 27-Jul BUY 68939 PPC 441,000 1,764,326.90 561 2015 28-Jul BUY 68959 PPC 800,000 2,865,240.95 562 2015 29-Jul BUY 68987 TA 2,000,000 4,623,261.77 563 2015 04-Aug BUY 69070 AR 1,500,000,000 9,252,900.00 564 2015 07-Aug BUY 69107 CAL 500,000 1,867,496.72 565 2015 07-Aug BUY 69108 AR 300,000,000 1,750,005.00 566 2015 11-Aug BUY 69136 SBS 917,000 5,256,954.68 567 2015 14-Aug BUY 69210 POPI 2,305,000 5,762,323.95 568 2015 19-Aug BUY 69263 POPI 527,000 1,033,559.00 569 2015 20-Aug BUY 69290 PA 20,000,000 1,119,429.93 570 2015 24-Aug BUY 69315 PA 40,000,000 2,031,615.00 571 2015 28-Aug BUY 69379 LIB 1,000,000 2,524,211.24 572 2015 07-Sep BUY 69444 SBS 500,000 2,604,892.51 573 2015 07-Sep BUY 69446 SBS 500,000 2,675,677.21 574 2015 14-Sep BUY 69518 ION 2,000,000 2,002,548.82 575 2015 17-Sep BUY 69582 IS 10,000,000 2,103,445.67 576 2015 21-Sep BUY 69681 SGI 1,000,000 1,455,672.26 577 2015 22-Sep BUY 69730 UNI 4,000,000 1,568,970.00 578 2015 23-Sep BUY 69758 ION 1,588,000 4,884,143.27 579 2015 23-Sep BUY 69759 ION 1,212,000 3,802,740.75 580 2015 28-Sep BUY 69833 DAVIN 841,000 1,815,670.40 581 2015 28-Sep BUY 69834 DAVIN 1,310,000 2,898,269.77 582 2015 28-Sep BUY 69842 UNI 3,750,000 1,337,245.19 583 2015 29-Sep BUY 69872 MED 5,000,000 4,002,885.00 584 2015 30-Sep BUY 69898 ISM 1,000,000 1,555,573.42 585 2015 01-Oct BUY 69921 ION 1,490,000 4,743,519.30 586 2015 01-Oct BUY 69927 LIB 737,000 3,361,880.30 587 2015 01-Oct BUY 69928 LIB 563,000 2,607,879.57 588 2015 06-Oct BUY 69999 ION 750,000 2,133,155.55 589 2015 07-Oct BUY 70022 MCP 1,000,000 4,023,000.00 590 2015 09-Oct BUY 70087 GERI 1,980,000 2,560,438.35 591 2015 09-Oct BUY 70094 SPH 641,000 1,623,763.26 592 2015 09-Oct BUY 70095 SPH 777,000 2,061,546.13 593 2015 12-Oct BUY 70110 PBB 177,000 3,172,276.30 594 2015 12-Oct BUY 70127 NOW 9,000,000 7,241,922.99 595 2015 12-Oct BUY 70128 SUN 1,500,000 1,910,925.00 596 2015 13-Oct BUY 70161 ION 625,000 1,759,459.06 597 2015 13-Oct BUY 70166 NOW 5,257,000 4,253,125.67 598 2015 14-Oct BUY 70176 ION 500,000 1,377,877.50 599 2015 14-Oct BUY 70195 ION 875,000 2,524,432.51 600 2015 16-Oct BUY 70234 NOW 7,000,000 8,297,437.50 601 2015 19-Oct BUY 70253 ATN 5,000,000 1,382,906.25 602 2015 19-Oct BUY 70254 CYBR 5,000,000 3,147,997.51 603 2015 20-Oct BUY 70282 NOW 2,000,000 2,169,111.10 604 2015 21-Oct BUY 70303 SFI 17,930,000 3,447,077.39 605 2015 21-Oct BUY 70304 SFI 5,000,000 1,005,750.00 606 2015 22-Oct BUY 70319 NOW 2,300,000 2,124,194.29 607 2015 23-Oct BUY 70335 NOW 5,000,000 4,763,674.51 608 2015 26-Oct BUY 70349 NOW 1,399,000 1,387,100.22 609 2015 27-Oct BUY 70372 PPC 1,236,000 3,835,669.03 610 2015 27-Oct BUY 70373 PPC 690,000 2,260,755.02 611 2015 27-Oct BUY 70374 PPC 891,000 2,957,206.72 612 2015 28-Oct BUY 70389 PXP 1,000,000 1,807,604.30 613 2015 30-Oct BUY 70419 LIB 626,000 2,552,050.40 614 2015 04-Nov BUY 70468 BRN 2,000,000 2,252,880.00 615 2015 05-Nov BUY 70490 LIB 1,472,000 6,684,858.19 616 2015 05-Nov BUY 70491 LIB 897,000 4,322,089.92 617 2015 06-Nov BUY 70511 BRN 1,500,000 1,568,175.45 618 2015 10-Nov BUY 70546 ION 2,309,000 4,819,724.98 619 2015 11-Nov BUY 70563 LTG 500,000 7,039,926.16 620 2015 11-Nov BUY 70566 PA 100,000,000 3,993,430.95 621 2015 12-Nov BUY 70592 PA 230,500,000 9,107,569.12 622 2015 13-Nov BUY 70617 NOW 5,000,000 3,438,971.02 623 2015 16-Nov BUY 70638 ION 646,000 1,605,076.42 624 2015 17-Nov BUY 70645 ION 500,000 1,221,091.11 625 2015 23-Nov BUY 70675 FJP 300,000 2,062,793.25 626 2015 24-Nov BUY 70694 MRSGI 1,000,000 4,324,725.00 627 2015 26-Nov BUY 70723 CROWN 1,000,000 2,603,343.65 628 2015 27-Nov BUY 70742 CROWN 1,000,000 2,534,490.00 629 2015 02-Dec BUY 70773 NOW 2,000,000 1,689,660.00 630 2015 03-Dec BUY 70806 NOW 2,000,000 1,679,602.50 631 2015 04-Dec BUY 70826 DAVIN 2,000,000 3,459,780.00 632 2015 07-Dec BUY 70864 IDC 1,270,000 5,793,693.28 633 2015 08-Dec BUY 70887 IDC 700,000 2,779,842.72 634 2015 09-Dec BUY 70898 FJP 361,700 2,164,794.40 635 2015 09-Dec BUY 70904 X 200,000 3,034,750.05 636 2015 10-Dec BUY 70919 NOW 4,228,000 3,859,545.52 637 2015 11-Dec BUY 70934 NOW 1,346,000 1,197,224.68 638 2015 14-Dec BUY 70949 NOW 2,000,000 1,709,775.00 639 2015 18-Dec BUY 71007 NOW 5,300,000 4,717,741.95 640 2015 22-Dec BUY 71038 ION 1,206,000 3,418,162.05 641 2015 23-Dec BUY 71048 ION 1,000,000 2,514,375.00 642 2015 23-Dec BUY 71053 PLC 5,000,000 3,136,833.68 643 2015 28-Dec BUY 71063 IDC 300,000 1,028,067.57 644 2015 28-Dec BUY 71068 PLC 5,000,000 3,268,687.50 645 2016 05-Jan BUY 71104 EG 100,000,000 1,106,325.00 646 2016 05-Jan BUY 71105 MCP 1,532,000 3,256,266.49 647 2016 05-Jan BUY 71106 MCP 1,968,000 4,309,880.12 648 2016 12-Jan BUY 71193 LIB 374,000 1,674,553.64 649 2016 13-Jan BUY 71200 LIB 300,000 1,333,624.50 650 2016 13-Jan BUY 71202 PLC 5,000,000 2,358,383.17 651 2016 18-Jan BUY 71264 PLC 4,310,000 2,109,912.65 652 2016 20-Jan BUY 71301 DAVIN 2,500,000 6,761,154.38 653 2016 22-Jan BUY 71349 DAVIN 500,000 1,408,050.00 654 2016 25-Jan BUY 71369 PLC 5,000,000 3,153,116.76 655 2016 25-Jan BUY 71371 PLC 5,065,000 3,209,297.96 656 2016 29-Jan BUY 71465 PLC 3,000,000 2,383,627.50 657 2016 01-Feb BUY 71481 SSI 990,000 3,215,885.62 658 2016 02-Feb BUY 71503 IRC 1,000,000 1,380,824.32 659 2016 02-Feb BUY 71504 MCP 1,000,000 2,406,709.47 660 2016 02-Feb BUY 71505 SSI 500,000 1,795,263.75 661 2016 03-Feb BUY 71517 MCP 1,000,000 2,262,937.50 662 2016 09-Feb BUY 71595 MA 200,000,000 2,614,950.00 663 2016 09-Feb BUY 71597 MAB 108,700,000 1,421,225.33 664 2016 10-Feb BUY 71619 DAVIN 1,500,000 3,466,588.93 665 2016 10-Feb BUY 71628 MA 112,900,000 1,476,139.27 666 2016 12-Feb BUY 71676 PA 50,000,000 1,709,775.00 667 2016 15-Feb BUY 71699 LC 25,000,000 8,272,293.74 668 2016 15-Feb BUY 71702 LCB 4,160,000 1,421,728.20 669 2016 15-Feb BUY 71705 PLC 4,000,000 3,577,261.66 670 2016 16-Feb BUY 71733 PLC 5,000,000 4,324,725.00 671 2016 17-Feb BUY 71752 LC 15,000,000 4,701,881.25 672 2016 17-Feb BUY 71760 PLC 3,000,000 2,591,948.51 673 2016 19-Feb BUY 71797 LC 30,000,000 9,956,925.00 674 2016 19-Feb BUY 71800 LCB 11,340,000 3,951,893.49 675 2016 22-Feb BUY 71823 SSI 1,000,000 3,771,562.50 676 2016 29-Feb BUY 71874 IS 10,000,000 2,313,225.00 677 2016 02-Mar BUY 71929 PLC 5,000,000 4,626,450.00 678 2016 03-Mar BUY 71963 ION 1,500,000 4,140,944.32 679 2016 04-Mar BUY 72016 LCB 10,000,000 3,519,018.68 680 2016 08-Mar BUY 72088 DAVIN 500,000 2,832,192.00 681 2016 08-Mar BUY 72101 VITA 4,000,000 3,479,895.00 682 2016 14-Mar BUY 72220 DAVIN 300,000 1,810,350.00 683 2016 17-Mar BUY 72319 IS 5,000,000 1,433,193.75 684 2016 17-Mar BUY 72322 OV 100,000,000 1,307,475.00 685 2016 21-Mar BUY 72369 PXP 940,000 2,453,396.40 686 2016 21-Mar BUY 72370 PXP 560,000 1,520,694.00 687 2016 22-Mar BUY 72391 PXP 550,000 1,295,285.31 688 2016 28-Mar BUY 72446 BRN 2,000,000 2,151,832.29 689 2016 29-Mar BUY 72453 APC 2,214,000 1,358,305.59 690 2016 29-Mar BUY 72491 IS 23,000,000 6,664,652.66 691 2016 04-Apr BUY 72624 STI 4,362,000 2,845,488.00 692 2016 05-Apr BUY 72646 ISM 2,000,000 3,086,988.71 693 2016 05-Apr BUY 72651 NOW 5,000,000 9,271,164.40 694 2016 07-Apr BUY 72701 NOW 3,000,000 6,487,087.50 695 2016 11-Apr BUY 72740 ATN 8,480,000 2,889,771.18 696 2016 11-Apr BUY 72745 BRN 1,000,000 1,653,764.80 697 2016 11-Apr BUY 72751 VITA 2,000,000 2,413,800.00 698 2016 12-Apr BUY 72771 COAL 3,000,000 1,805,723.55 699 2016 13-Apr BUY 72786 NOW 1,000,000 2,363,512.50 700 2016 14-Apr BUY 72808 VITA 4,000,000 4,827,600.00 701 2016 22-Apr BUY 72948 NOW 2,298,000 7,968,758.42 702 2016 22-Apr BUY 72955 NOW 500,000 1,755,777.99 703 2016 25-Apr BUY 73000 ARA 1,100,000 3,384,811.40 704 2016 25-Apr BUY 73001 SLI 7,000,000 7,195,849.58 705 2016 26-Apr BUY 73032 NOW 813,000 2,779,661.67 706 2016 27-Apr BUY 73059 IS 20,000,000 7,593,412.51 707 2016 28-Apr BUY 73081 ATN 5,000,000 1,985,199.64 708 2016 28-Apr BUY 73090 IS 30,000,000 11,968,425.01 709 2016 02-May BUY 73132 LC 20,000,000 5,431,050.00 710 2016 04-May BUY 73169 ATN 12,620,000 6,317,216.32 711 2016 05-May BUY 73198 IS 3,040,000 1,131,267.60 712 2016 05-May BUY 73201 IS 6,960,000 2,590,007.40 713 2016 05-May BUY 73205 ATN 3,000,000 1,448,280.00 714 2016 10-May BUY 73234 IS 3,560,000 1,271,066.85 715 2016 11-May BUY 73253 ACR 2,000,000 3,379,320.00 716 2016 11-May BUY 73255 IS 30,000,000 11,566,125.00 717 2016 12-May BUY 73290 ATN 14,060,000 7,356,357.22 718 2016 13-May BUY 73315 ATN 3,000,000 1,538,797.50 719 2016 17-May BUY 73346 PGOLD 30,000 1,267,245.00 720 2016 17-May BUY 73377 PXP 500,000 2,459,370.54 721 2016 18-May BUY 73419 LC 30,000,000 9,328,331.25 722 2016 18-May BUY 73425 T 1,225,000 3,741,379.96 723 2016 20-May BUY 73480 ALT 1,961,400 10,284,306.70 724 2016 23-May BUY 73494 ALT 500,000 2,189,467.47 725 2016 24-May BUY 73509 ACR 2,000,000 3,967,723.98 726 2016 26-May BUY 73553 ALT 600,000 2,625,007.50 727 2016 26-May BUY 73555 ATN 4,000,000 1,543,323.37 728 2016 30-May BUY 73594 LIB 500,000 2,262,937.50 729 2016 02-Jun BUY 73643 PHA 11,000,000 5,642,659.80 730 2016 06-Jun BUY 73659 PLC 3,000,000 3,318,975.00 731 2016 08-Jun BUY 73693 DD 90,120 5,890,515.83 732 2016 09-Jun BUY 73712 DD 300,000 22,467,635.34 733 2016 10-Jun BUY 73732 DD 100,000 6,939,675.00 734 2016 13-Jun BUY 73746 DD 50,000 3,294,229.54 735 2016 13-Jun BUY 73749 NOW 565,000 1,675,318.00 736 2016 13-Jun BUY 73750 NOW 766,000 2,309,081.32 737 2016 13-Jun BUY 73751 NOW 1,000,000 3,017,250.00 738 2016 14-Jun BUY 73766 PXP 1,049,000 5,314,614.34 739 2016 14-Jun BUY 73767 PXP 300,000 1,508,625.00 740 2016 15-Jun BUY 73784 CYBR 25,000,000 16,015,261.28 741 2016 16-Jun BUY 73808 DD 100,000 6,133,689.08 742 2016 17-Jun BUY 73826 IDC 678,000 3,467,463.91 743 2016 17-Jun BUY 73827 IDC 788,000 4,328,778.17 744 2016 21-Jun BUY 73860 ALT 816,000 3,380,104.51 745 2016 23-Jun BUY 73909 ATN 11,550,000 4,594,517.44 746 2016 24-Jun BUY 73941 SBS 1,500,000 10,308,931.47 747 2016 28-Jun BUY 73982 APX 1,162,000 4,634,274.73 748 2016 28-Jun BUY 73984 T 1,507,000 3,183,701.65 749 2016 28-Jun BUY 73985 T 873,000 1,886,515.46 750 2016 30-Jun BUY 74026 HVN 286,400 6,335,420.40 751 2016 01-Jul BUY 74036 HVN 300,000 6,023,318.08 752 2016 04-Jul BUY 74063 NOW 1,500,000 5,807,944.76 753 2016 05-Jul BUY 74085 NOW 1,000,000 3,942,540.00 754 2016 07-Jul BUY 74096 NOW 1,000,000 3,781,620.00 755 2016 07-Jul BUY 74099 VITA 6,138,000 6,719,657.15 756 2016 08-Jul BUY 74115 APO 816,000 1,229,046.61 757 2016 08-Jul BUY 74121 VITA 8,000,000 8,317,552.50 758 2016 08-Jul BUY 74124 VUL 1,931,000 2,819,620.12 759 2016 08-Jul BUY 74125 VUL 1,069,000 1,607,540,52 760 2016 11-Jul BUY 74128 ALT 967,000 5,510,001.37 761 2016 11-Jul BUY 74141 ALT 411,000 2,270,098.43 762 2016 12-Jul BUY 74173 ALT 800,000 4,375,012.50 763 2016 13-Jul BUY 74197 PXP 779,000 4,377,526.90 764 2016 13-Jul BUY 74198 PXP 888,000 5,089,265.98 765 2016 14-Jul BUY 74215 ALT 1,000,000 6,135,075.00 766 2016 14-Jul BUY 74229 PXP 300,000 1,581,835.57 767 2016 15-Jul BUY 74244 BHI 50,000,000 4,948,290.02 768 2016 18-Jul BUY 74264 BHI 20,000,000 1,931,040.00 769 2016 19-Jul BUY 74278 IS 4,000,000 1,408,050.00 770 2016 20-Jul BUY 74302 ALT 910,700 7,327,492.20 771 2016 21-Jul BUY 74329 ALT 2,500,000 20,467,012.51 772 2016 26-Jul BUY 74432 VITA 18,000,000 23,534,550.01 773 2016 27-Jul BUY 74468 IDC 500,000 3,329,032.50 774 2016 28-Jul BUY 74492 IDC 700,000 4,021,042.83 775 2016 29-Jul BUY 74526 BHI 50,000,000 5,971,650.69 776 2016 02-Aug BUY 74558 BHI 20,000,000 2,359,871.67 777 2016 02-Aug BUY 74559 MRC 20,000,000 2,816,100.00 778 2016 05-Aug BUY 74611 BHI 20,000,000 2,112,075.00 779 2016 05-Aug BUY 74619 VITA 3,000,000 4,978,462.50 780 2016 15-Aug BUY 74759 VITA 3,000,000 5,943,982.50 781 2016 16-Aug BUY 74775 NOW 363,000 1,450,291.51 782 2016 16-Aug BUY 74776 NOW 637,000 2,564,883.76 783 2016 18-Aug BUY 74825 IMI 500,000 4,019,221.40 784 2016 23-Aug BUY 74904 TUGS 1,000,000 1,709,775.00 785 2016 24-Aug BUY 74926 CAL 800,000 3,186,065.15 786 2016 25-Aug BUY 74968 LR 750,000 3,899,795.62 787 2016 30-Aug BUY 75016 VITA 4,000,000 12,277,431.64 788 2016 31-Aug BUY 75040 NOW 1,000,000 3,867,108.75 789 2016 01-Sep BUY 75079 UNI 9,300,000 3,664,248.99 790 2016 02-Sep BUY 75103 MED 5,000,000 6,798,870.00 791 2016 05-Sep BUY 75130 CAL 500,000 2,110,898.28 792 2016 15-Sep BUY 75218 MRC 12,000,000 2,268,972.00 793 2016 15-Sep BUY 75220 PXP 1,096,000 3,687,954.51 794 2016 22-Sep BUY 75291 MRC 20,000,000 4,958,347.51 795 2016 23-Sep BUY 75306 MRC 15,000,000 3,590,497.33 796 2016 26-Sep BUY 75315 MRC 5,000,000 1,156,612.50 797 2016 27-Sep BUY 75333 FNI 6,000,000 5,642,257.50 798 2016 27-Sep BUY 75342 MRC 20,000,000 4,405,637.59 799 2016 30-Sep BUY 75378 MRC 20,000,000 4,716,967.50 800 2016 03-Oct BUY 75397 FNI 5,000,000 5,516,096.23 801 2016 03-Oct BUY 75399 PXP 1,000,000 3,969,675.16 802 2016 05-Oct BUY 75428 MRC 6,000,000 1,265,474.88 803 2016 06-Oct BUY 75446 LIB 2,000,000 5,232,464.67 804 2016 06-Oct BUY 75455 WEB 439,800 3,571,070.26 805 2016 06-Oct BUY 75457 WEB 520,000 4,704,837.15 806 2016 17-Oct BUY 75546 MED 8,773,000 8,245,440.24 807 2016 19-Oct BUY 75577 PXP 1,500,000 6,989,841.82 808 2016 20-Oct BUY 75587 APL 50,000,000 3,208,342.50 809 2016 25-Oct BUY 75620 TUGS 1,000,000 2,297,344.20 810 2016 27-Oct BUY 75655 LIHC 5,000,000 5,159,145.51 811 2016 08-Nov BUY 75727 FNI 12,000,000 16,806,303.78 812 2016 09-Nov BUY 75751 CPG 21,593,000 15,051,451.05 813 2016 09-Nov BUY 75754 FNI 7,000,000 9,594,855.00 814 2016 10-Nov BUY 75778 CPG 8,407,000 5,495,971.16 815 2016 15-Nov BUY 75828 LIHC 4,513,000 5,798,148.77 816 2016 17-Nov BUY 75856 LIHC 10,074,000 13,546,346.16 817 2016 18-Nov BUY 75878 ALCO 5,000,000 1,753,726.28 818 2016 22-Nov BUY 75923 LIHC 6,000,000 9,055,602.03 819 2016 24-Nov BUY 75971 LIHC 2,000,000 3,212,627.00 820 2016 28-Nov BUY 76022 LIHC 2,000,000 3,414,752.59 821 2016 28-Nov BUY 76023 WEB 300,000 4,520,836.19 822 2016 29-Nov BUY 76043 CDC 880,000 1,266,339.83 823 2016 29-Nov BUY 76044 CDC 1,890,000 2,833,901.77 824 2016 01-Dec BUY 76068 LIHC 2,194,000 3,321,288.23 825 2016 01-Dec BUY 76069 LIHC 7,039,000 11,020,445.29 826 2016 01-Dec BUY 76078 SLI 2,000,000 2,534,490.00 827 2016 02-Dec BUY 76092 LIHC 2,000,000 2,926,732.50 828 2016 02-Dec BUY 76102 WEB 444,900 6,164,931.69 829 2016 05-Dec BUY 76117 LIHC 22,000,000 33,179,058.88 830 2016 05-Dec BUY 76127 SLI 10,000,000 12,898,381.70 831 2016 06-Dec BUY 76136 EW 250,000 4,777,312.50 832 2016 07-Dec BUY 76151 ALCO 6,640,000 3,230,670.15 833 2016 07-Dec BUY 76171 ALCO 3,580,000 1,584,257.40 834 2016 08-Dec BUY 76183 ALCO 30,000,000 13,275,900.00 835 2016 12-Dec BUY 76229 APL 610,000,000 33,345,641.25 836 2016 15-Dec BUY 76293 PIZZA 1,000,000 12,267,697.97 837 2016 16-Dec BUY 76308 ALCO 2,120,000 1,023,451.20 838 2016 21-Dec BUY 76393 LIHC 2,000,000 2,398,713.75 839 2016 21-Dec BUY 76396 WEB 210,000 2,471,127.75 840 2016 23-Dec BUY 76421 DFNN 237,900 2,052,672.43 841 2016 23-Dec BUY 76422 DFNN 708,400 6,269,078.13 842 2016 27-Dec BUY 76459 TUGS 2,000,000 5,613,342.19 843 2016 28-Dec BUY 76477 LIHC 2,102,000 2,486,455.37 844 2016 29-Dec BUY 76486 LIHC 1,000,000 1,146,555.00 845 2017 03-Jan BUY 76511 ALCO 4,950,000 2,330,222.18 846 2017 05-Jan BUY 76574 NOW 2,000,000 5,723,683.04 847 2017 09-Jan BUY 76654 PA 150,000,000 8,096,287.50 848 2017 09-Jan BUY 76661 WEB 500,000 5,547,767.30 849 2017 09-Jan BUY 76662 WEB 200,000 2,309,650.56 850 2017 11-Jan BUY 76710 ALCO 5,000,000 3,369,262.50 851 2017 16-Jan BUY 76776 LIHC 2,450,000 2,730,108.38 852 2017 17-Jan BUY 76797 ALCO 10,000,000 7,844,850.01 853 2017 17-Jan BUY 76802 STI 10,000,000 10,912,387.50 854 2017 19-Jan BUY 76841 STI 5,000,000 5,530,729.89 855 2017 20-Jan BUY 76866 WEB 200,000 2,140,262.15 856 2017 23-Jan BUY 76873 ALCO 2,731,000 2,279,763.69 857 2017 25-Jan BUY 76916 ALCO 6,000,000 4,943,301.50 858 2017 26-Jan BUY 76924 MA 90,100,000 1,087,416.90 859 2017 27-Jan BUY 76968 LMG 800,000 3,620,700.00 860 2017 30-Jan BUY 76986 LMG 600,000 2,579,748.75 861 2017 31-Jan BUY 76998 LMG 300,000 1,267,245.00 862 2017 31-Jan BUY 77005 APL 50,000,000 3,117,825.00 863 2017 01-Feb BUY 77046 SBS 500,000 3,591,190.29 864 2017 02-Feb BUY 77056 DFNN 176,900 1,654,946.55 865 2017 02-Feb BUY 77057 DFNN 276,800 2,641,128.67 866 2017 02-Feb BUY 77059 FPH 20,000 1,448,280.00 867 2017 03-Feb BUY 77082 DFNN 600,000 5,642,257.50 868 2017 06-Feb BUY 77142 RLT 9,399,000 8,202,997.57 869 2017 07-Feb BUY 77158 CPG 9,900,000 5,675,447.25 870 2017 08-Feb BUY 77185 BSC 16,380,000 5,805,943.34 871 2017 08-Feb BUY 77186 BSC 13,900,000 5,583,873.72 872 2017 08-Feb BUY 77200 RLT 5,000,000 4,475,587.50 873 2017 10-Feb BUY 77245 ALCO 5,000,000 8,111,373.75 874 2017 10-Feb BUY 77252 PA 50,000,000 3,369,262.50 875 2017 14-Feb BUY 77288 APL 50,000,000 3,369,262.50 876 2017 14-Feb BUY 77297 APL 29,980,000 1,839,295.49 877 2017 16-Feb BUY 77335 LMG 300,000 2,039,661.00 878 2017 16-Feb BUY 77350 LMG 171,300 1,360,664.09 879 2017 16-Feb BUY 77351 LMG 328,700 2,643,352.37 880 2017 17-Feb BUY 77364 LMG 700,000 5,109,332.70 881 2017 20-Feb BUY 77383 PSPC 549,000 1,214,744.85 882 2017 22-Feb BUY 77416 DFNN 468,900 4,147,753.24 883 2017 22-Feb BUY 77417 DFNN 148,000 1,339,341.18 884 2017 24-Feb BUY 77460 APX 795,000 1,851,756.73 885 2017 24-Feb BUY 77469 RLT 3,000,000 2,021,557.50 886 2017 24-Feb BUY 77470 APX 2,205,000 5,040,617.83 887 2017 01-Mar BUY 77503 DFNN 343,600 3,045,489.46 888 2017 01-Mar BUY 77513 LMG 242,500 1,797,035.90 889 2017 02-Mar BUY 77525 DFNN 228,900 1,956,837.49 890 2017 02-Mar BUY 77534 APL 200,000,000 14,734,237.50 891 2017 03-Mar BUY 77550 PGOLD 30,000 1,378,883.26 892 2017 06-Mar BUY 77567 LMG 182,000 1,451,459.17 893 2017 06-Mar BUY 77568 LMG 818,000 6,581,502.30 894 2017 07-Mar BUY 77590 APL 100,000,000 5,783,062.50 895 2017 17-Mar BUY 77721 LMG 300,000 1,562,935.51 896 2017 20-Mar BUY 77728 LMG 700,000 3,787,654.51 897 2017 21-Mar BUY 77750 MRC 30,000,000 6,416,926.39 898 2017 22-Mar BUY 77758 DFNN 268,100 2,291,953.39 899 2017 22-Mar BUY 77766 MG 14,650,000 4,657,628.25 900 2017 28-Mar BUY 77815 ALCO 2,000,000 2,715,525.00 901 2017 29-Mar BUY 77827 ALCO 2,000,000 2,686,509.12 902 2017 29-Mar BUY 77832 MRC 5,000,000 1,146,555.00 903 2017 03-Apr BUY 77872 CHIB 71,200 2,917,167.82 904 2017 03-Apr BUY 77879 2GO 400,000 5,229,900.00 905 2017 04-Apr BUY 77891 CHIB 160,000 6,557,349.21 906 2017 04-Apr BUY 77899 2GO 287,000 3,624,093.42 907 2017 04-Apr BUY 77900 2GO 355,500 4,820,678.45 908 2017 05-Apr BUY 77913 CHIB 241,300 9,947,591.67 909 2017 05-Apr BUY 77914 CHIB 88,700 3,690,866.14 910 2017 07-Apr BUY 77979 CHP 1,000,000 8,025,885.00 911 2017 10-Apr BUY 77995 ATN 20,000,000 9,303,187.50 912 2017 12-Apr BUY 78025 CPM 5,871,000 4,444,550.08 913 2017 18-Apr BUY 78045 CPM 1,500,000 1,234,186.00 914 2017 19-Apr BUY 78065 LMG 1,161,000 6,984,491.23 915 2017 20-Apr BUY 78078 ATN 9,000,000 4,012,942.50 916 2017 24-Apr BUY 78118 BHI 70,000,000 6,319,781.00 917 2017 05-May BUY 78295 MRC 20,000,000 9,051,749.99 918 2017 10-May BUY 78352 RLT 15,000,000 12,257,497.68 919 2017 12-May BUY 78389 WPI 6,000,000 4,586,220.01 920 2017 17-May BUY 78433 PXP 1,800,000 6,706,914.27 921 2017 23-May BUY 78492 PNX 500,000 5,280,187.51 922 2017 30-May BUY 78581 RLT 2,000,000 1,649,430.00 923 2017 01-Jun BUY 78656 ACR 2,000,000 3,800,910.29 924 2017 02-Jun BUY 78663 PGOLD 30,000 1,369,831.50 925 2017 02-Jun BUY 78682 CLI 1,121,900 6,066,280.69 926 2017 07-Jun BUY 78759 NRCP 1,098,000 1,130,362.41 927 2017 07-Jun BUY 78760 NRCP 1,715,000 2,010,735.63 928 2017 28-Jun BUY 79003 OM 6,000,000 5,233,420.13 929 2017 22-Sep BUY 79886 BKR 3,000,000 7,337,187.62 930 2017 28-Sep BUY 79999 EDC 990,000 5,277,170.25 931 2017 04-Oct BUY 80090 PXP 551,700 4,634,618.71 932 2017 04-Oct BUY 80091 PXP 236,800 2,011,583.47 933 2017 04-Oct BUY 80092 PXP 211,500 1,807,435.35 934 2017 26-Oct BUY 80355 IDC 500,000 3,268,299.29 935 2017 06-Nov BUY 80438 GSMI 150,000 3,510,937.48 936 2017 06-Nov BUY 80456 IDC 300,000 2,712,789.37 937 2017 13-Nov BUY 80618 IDC 128,200 2,062,994.40 938 2017 15-Nov BUY 80623 IDC 300,000 4,224,150.00 939 2017 24-Nov BUY 80775 TUGS 1,990,000 7,005,048.75 940 2017 01-Dec BUY 80871 SHLPH 35,690 2,094,505.55 941 2017 05-Dec BUY 80935 MJC 554,000 3,230,469.00 942 2017 06-Dec BUY 80951 SHLPH 19,940 1,200,724.70 943 2017 14-Dec BUY 81053 CHIB 300,000 10,041,357.72 944 2017 15-Dec BUY 81072 CHIB 100,000 3,349,147.50 945 2017 15-Dec BUY 81084 TBGI 3,000,000 11,965,085.89 946 2017 18-Dec BUY 81095 CHIB 86,000 2,880,266.85 947 2017 19-Dec BUY 81153 CHIB 200,000 6,698,295.00 948 2018 09-Jan BUY 81234 MER 5,000 1,655,846.69 949 2018 09-Jan BUY 81235 PGOLD 20,000 1,072,659.55 950 2018 22-Jan BUY 81361 NOW 1,300,000 6,519,472.67 951 2018 22-Jan BUY 81362 NOW 200,000 1,064,194.12 952 2018 25-Jan BUY 81414 PGOLD 20,000 1,091,880.41 953 2018 09-Feb BUY 81673 CEI 35,000,000 9,006,491.26 954 2018 12-Feb BUY 81694 NOW 700,000 5,278,342.97 955 2018 12-Feb BUY 81698 POPI 1,500,000 5,619,034.74 956 2018 14-Feb BUY 81760 NOW 1,000,000 15,387,975.00 957 2018 14-Feb BUY 81764 SSP 688,000 1,707,240.49 958 2018 14-Feb BUY 81765 SSP 1,312,000 3,296,124.37 959 2018 15-Feb BUY 81836 PXP 625,700 7,550,780.77 960 2018 20-Feb BUY 81896 NOW 1,000,000 13,066,995.67 961 2018 21-Feb BUY 81942 PXP 840,000 14,784,525.00 962 2018 22-Feb BUY 81971 PXP 500,000 9,502,945.54 963 2018 26-Feb BUY 82068 MRC 25,000,000 17,600,625.00 964 2018 27-Feb BUY 82098 APC 15,000,000 11,616,412.51 965 2018 28-Feb BUY 82134 TBGI 22,418,000 13,314,088.32 966 2018 01-Mar BUY 82150 MRC 12,000,000 10,620,720.00 967 2018 07-Mar BUY 82253 ION 1,345,000 3,933,196.58 968 2018 07-Mar BUY 82254 ION 1,655,000 4,932,369.00 969 2018 09-Mar BUY 82330 DAVIN 300,000 2,051,488.62 970 2018 09-Mar BUY 82336 PRIM 1,178,000 1,960,548.70 971 2018 09-Mar BUY 82337 PRIM 822,000 1,388,900.53 972 2018 14-Mar BUY 82427 MBT 50,000 4,852,027.15 973 2018 20-Mar BUY 82510 MRC 11,790,000 7,351,831.35 974 2018 27-Mar BUY 82592 BPI 50,000 5,624,154.00 975 2018 04-Apr BUY 82637 MRC 15,000,000 10,107,787.50 976 2018 05-Apr BUY 82648 VUL 9,000,000 9,578,712.73 977 2018 05-Apr BUY 82649 VUL 1,000,000 1,056,037.51 978 2018 27-Apr BUY 82812 EAGLE 70,000 1,094,457.15 979 2018 03-May BUY 82829 TBGI 10,000,000 4,847,966.44 980 2018 07-May BUY 82837 CHIB 35,000 1,232,043.75 981 2018 24-May BUY 83002 NOW 594,400 5,953,442.61 982 2018 24-May BUY 83003 NOW 205,600 2,065,754.17 983 2018 29-May BUY 83051 NOW 1,000,000 11,817,562.50 984 2018 05-Jun BUY 83119 ABA 10,000,000 3,017,250.00 985 2018 05-Jun BUY 83128 NOW 500,000 5,219,023.81 986 2018 19-Jun BUY 83262 ISM 1,531,000 3,048,810.44 987 2018 20-Jun BUY 83277 ISM 600,000 1,267,245.00 988 2018 25-Jun BUY 83355 ISM 894,000 2,543,400.97 989 2018 25-Jun BUY 83356 ISM 606,000 1,767,505.06 990 2018 02-Jul BUY 83433 ISM 2,000,000 6,663,093.75 991 2018 05-Jul BUY 83474 IRC 2,000,000 3,510,308.87 992 2018 05-Jul BUY 83475 ISM 1,000,000 2,946,063.03 993 2018 10-Jul Buy 83532 MER 5,000 1,777,771.75 994 2018 13-Jul BUY 83608 TBGI 8,000,000 4,586,220.00 995 2018 01-Aug BUY 83779 PXP 500,000 6,529,526.15 996 2018 06-Aug BUY 83834 ATN 7,000,000 10,336,726.36 997 2018 08-Aug BUY 83885 PXP 600,000 9,622,448.77 998 2018 24-Aug BUY 84050 SMC 41,000 7,092,046.13 999 2018 03-Sep BUY 84111 MER 6,000 2,214,661.50 1000 2018 03-Sep BUY 84112 SMC 10,000 1,780,177.51 1001 2018 07-Nov BUY 84616 ISM 500,000 2,362,828.59 1002 2018 13-Nov BUY 84713 ISM 605,900 4,851,079.24 1003 2018 13-Nov BUY 84714 ISM 394,100 3,169,483.35 1004 2018 21-Nov BUY 84830 ISM 1,000,000 6,788,812.50 1005 2018 27-Nov BUY 84887 NOW 400,000 1,583,724.37 1006 2018 27-Nov BUY 84888 NOW 702,000 2,820,505.19 1007 2018 13-Dec BUY 85071 2GO 100,000 1,770,119.99 1008 2019 23-Jan BUY 85398 PHA 3,000,000 2,383,627.50 1009 2019 24-Jan BUY 85409 IRC 1,000,000 2,497,488.45 1010 2019 24-Jan BUY 85414 PHA 10,000,000 10,057,500.00 1011 2019 25-Jan BUY 85435 PHA 6,000,000 6,215,535.00 1012 2019 28-Jan BUY 85453 PHA 10,000,000 12,958,334.44 1013 2019 30-Jan BUY 85498 PHA 2,000,000 3,337,219.29 1014 2019 31-Jan BUY 85517 PHA 3,000,000 4,672,302.15 1015 2019 04-Feb BUY 85546 GEO 5,000,000 1,627,504.65 1016 2019 04-Feb BUY 85553 PHA 2,000,000 2,775,870.00 1017 2019 07-Feb BUY 85595 PHA 2,000,000 2,755,755.00 1018 2019 08-Feb BUY 85617 PHA 2,000,000 2,517,150.88 1019 2019 11-Feb BUY 85646 X 2,000,000 4,401,805.70 1020 2019 12-Feb BUY 85664 X 1,000,000 2,044,790.32 1021 2019 21-Feb BUY 85800 X 1,000,000 1,554,849.30 1022 2019 01-Mar BUY 85873 PHA 4,014,000 5,242,602.62 1023 2019 14-Mar BUY 85961 GREEN 2,000,000 5,218,293.65 1024 2019 26-Mar BUY 86028 SOC 2,124,000 3,195,227.54 1025 2019 26-Mar BUY 86029 SOC 779,000 1,242,785.15 1026 2019 24-Apr BUY 85995 PXP 700,000 6,329,399.98 1027 2019 14-May BUY 86218 PHA 7,000,000 6,969,847.51 1028 2019 23-May BUY 86250 T 1,500,000 1,876,065.70 1029 2019 24-May BUY 86262 T 1,000,000 1,609,200.00 1030 2019 13-Jun BUY 86333 PNB 70,000 3,881,189.25 1031 2019 19-Jun BUY 86380 MHC 2,000,000 1,508,625.00 1032 2019 26-Jun BUY 86424 BPI 20,000 1,602,411.20 1033 2019 28-Jun BUY 86441 ABA 5,000,000 5,129,325.00 1034 2019 02-Jul BUY 86468 PRIM 1,000,000 1,825,436.25 1035 2019 05-Jul BUY 86495 PRIM 1,769,000 2,888,966.59 1036 2019 06-Aug BUY 86693 ABA 1,682,000 1,421,004.07 1037 2019 19-Aug BUY 86771 ABA 6,043,000 5,149,983.10 1038 2019 19-Aug BUY 86778 KPPI 186,500 1,196,900.84 1039 2019 19-Aug BUY 86779 KPPI 181,000 1,209,622.58 1040 2019 19-Aug BUY 86781 KPPI 301,300 2,272,743.57 1041 2019 20-Aug BUY 86784 ABA 5,504,000 4,609,714.33 1042 2019 27-Aug BUY 86849 VUL 1,970,000 2,833,650.35 1043 2019 03-Sep BUY 86918 CHIB 47,000 1,228,573.92 1044 2019 04-Sep BUY 86940 ISM 400,000 2,272,995.00 1045 2019 24-Oct BUY 87189 SUN 5,005,000 6,343,104.35 1046 2019 24-Oct BUY 87190 SUN 2,995,000 4,069,908.17 1047 2019 29-Oct BUY 87231 BDO 10,000 1,531,757.24 From the above, it is inexplicable how Mr. Sulapas was allowed to transact or buy securities in numerous transactions amounting to more than P1,000,000.00 and as high as P33,000,000.00 in spite of his declared financial capacity amounting to P1,000,000.00 only. Therefore, to a reasonable mind, it would appear that there must be a suspicious securities transaction on the Sulapas account that Respondents intentionally and repeatedly ignored and did not bother to scrutinize and investigate. In addition, it is well-established that under the Suitability Rule, the broker dealers, associated persons or salesmen have an obligation to recommend to their customers only the purchase of securities that are reasonable and suitable to the customer's financial situation and needs. Not only that, despite being aware that Mr. Sulapas has only One Million Financial standing and that his account is a Cash Account, Respondents through Respondent Racadio even granted Mr. Sulapas a credit line 22 allowing Mr. Sulapas to borrow up to 40% the value of his alleged stock position amounting to Php44,639,825.00 which also served as the value of the collateral on Mr. Sulapas trading account without updating his source of funds and net income. Even though Respondents are aware of the reason of the abrupt change in Mr. Sulapas financial situation, they still actively facilitated the trades by giving credit line to the Sulapas account. Sulapas account was able to continuously conduct the illegal trades through this credit provided by VSI. It is clear from the KYC Rule that Respondents must not only be aware of their client's financial situation but they are also required to conduct ongoing diligence to update itself as to the changes in the financial situation of its clients. Despite Respondents claim to know the true financial condition of Sulapas due to his alleged trading pattern, they did not fulfill their obligation to update the CAIF. To emphasize, the main purpose of the KYC Rule is to verify the identity of the clients in compliance with legal and regulatory requirements as well as part of good business practice and to prevent the money laundering and other illegal acts as required under the SRC-IRR. In other words, it is the process of identifying and verifying the personal circumstances of the investors, their wealth status, the sources of their funds, investment experience and investment objectives. The purpose of getting the detailed information is to protect both parties in a business transaction and all stakeholders within the industry to preserve the integrity of the capital markets. It is the reason why the KYC Rules imposes a strict duty on trading participants to determine the true financial condition of their clients. If the true financial condition becomes known, then Respondents should have required the updating of the CAIF accordingly. Third, Respondents argued that the trading pattern allegedly established by Mr. Sulapas as well as his dealings with VSI from 2012-2019 determined that he has the financial capacity for his numerous buy and sell transactions given that he can sustain funding for his transactions almost entirely from his trading activities. As additional support for the argument, Respondents avers that this can be seen from the fact that he only made a few deposits into his account from 2012-2019 and Mr. Sulapas' EQ Trade transactions into his account also form a small portion of his buying and selling transactions with VSI. We find that the Respondents reliance on these justifications to be misplaced. As discussed above, Mr. Sulapas financial capacity of P1,000,000.00 is already disproportionate to his buying transaction. Further, as payment to the transactions, VSI executed the unauthorized EQ Trade transactions or by applying the prohibited credit line on the Sulapas account. Thus, as early as May 30, 2012 there was already a clear indication of Respondents knowledge that Mr. Sulapas financial capacity cannot sustain funding for his buy and sell transactions if not for the execution of the EQ Trade transactions. Based on the Ledger of Mr. Julieto Sulapas with VSI (SU026), the first transactions made dated 30 May 2012 (a day after account opening on 29 May 2012) were two (2) buy transactions of CAL shares amounting to Php2,210,759.23 (Php1,482,032.99 and Php728,726.24). This transaction was settled through an EQ Trade of 52,500 shares of PXP which was sold on the same day for Php2,242,298.33. Furthermore, as observed in the account ledger of Mr. Sulapas (SU026), he has only paid cash for all of his transactions once for the amount of Php981,612.00 dated 04 November 2019 for the transaction Buy 87228 dated 29 October 2019 for 20,000 shares of ALI at P48.80 per shares and that the Sulapas account has a total of Three Hundred Seventy Nine (379) EQ Trade transactions from R&L to VSI consisting of One Hundred Sixty Seven (167) Stock Credit Memo, to wit: DATE DATE 2 TXN REF. LEDGER REFERENCE STOCK SHARES TRANSFER 5/30/12 Wednesday, 30 May 2012 SCM 5422 CLG91619769 PXP 52,500 R&L 6/28/12 Thursday, 28 June 2012 SCM 5562 CLG91682704 OV 50,000,000 R&L 7/10/12 Tuesday, 10 July 2012 SCM 5579 CLG91708880 BLOOM 300,000 R&L 8/6/12 Monday, 6 August 2012 SCM 5654 CLG91766336 CAL 250,000 R&L 8/24/12 Friday, 24 August 2012 SCM 5677 CLG91798999 MAB 50,000,000 R&L 8/24/12 Friday, 24 August 2012 SCM 5677 CLG97644751 MA 50,000,000 R&L 10/5/12 Friday, 5 October 2012 SCM 5751 CLG97680604 MA 50,000,000 R&L 10/5/12 Friday, 5 October 2012 SCM 5751 CLG0000091887622 MAB 20,000,000 R&L 11/26/12 Monday, 26 November 2012 SCM 5959 CLG92002330 SMC 30,000 R&L 2/6/13 Wednesday, 6 February 2013 SCM 6108 CLG092194196 ICT 100,000 R&L 5/21/13 Tuesday, 21 May 2013 SCM 6396 CLG092499288 PGOLD 200,000 R&L 6/18/13 Tuesday, 18 June 2013 SCM 6421 CLG092595422 NIKL 300,000 R&L 6/18/13 Tuesday, 18 June 2013 SCM 6421 CLG092595423 FPH 50,000 R&L 7/3/13 Wednesday, 3 July 2013 SCM 6437 CLG92653691 PGOLD 200,000 R&L 7/5/13 Friday, 5 July 2013 SCM 6438 CLG92661845 PGOLD 200,000 R&L 7/24/13 Wednesday, 24 July 2013 SCM 6460 CLG0000092706183 PGOLD 100,000 R&L 9/20/13 Friday, 20 September 2013 SCM 6581 CLG92856036 PX 500,000 R&L 5/16/14 Friday, 16 May 2014 SCM 7112 CLG93537924 GTCAP 10,000 R&L 6/24/14 Tuesday, 24 June 2014 SCM 7149 CLG93656344 NIKL 300,000 R&L 6/24/14 Tuesday, 24 June 2014 SCM 7149 CLG93656343 APC 3,000,000 R&L 6/24/14 Tuesday, 24 June 2014 SCM 7149 CLG93656342 MA 100,000,000 R&L 11/7/14 Friday, 7 November 2014 SCM 7794 CLG094065164 IS 22,000,000 R&L 11/13/14 Thursday, 13 November 2014 SCM 7844 CLG094082807 IS 30,000,000 R&L 11/28/14 Friday, 28 November 2014 SCM 7879 CLG094127975 IS 40,000,000 R&L 12/19/14 Friday, 19 December 2014 SCM 7940 CLG094202353 IS 40,000,000 R&L 3/19/15 Thursday, 19 March 2015 SCM 8070 CLG094487483 NIKL 600,000 R&L 3/25/15 Wednesday, 25 March 2015 SCM 8071 CLG094512831 AGI 200,000 R&L 3/25/15 Wednesday, 25 March 2015 SCM 8071 CLG094512832 MER 20,000 R&L 4/10/15 Friday, 10 April 2015 SCM 8088 CLG094552996 GTCAP 29,000 R&L 4/14/15 Tuesday, 14 April 2015 SCM 8090 CLG0000094563963 CHIB 200,000 R&L 5/11/15 Monday, 11 May 2015 SCM 8157 CLG094654505 NIKL 600,000 R&L 5/13/15 Wednesday, 13 May 2015 SCM 8164 CLG09465655 NIKL 400,000 R&L 6/4/15 Thursday, 4 June 2015 SCM 8183 CLG094743272 NIKL 100,000 R&L 6/10/15 Wednesday, 10 June 2015 SCM 8190 CLG094761172 NIKL 200,000 R&L 7/9/15 Thursday, 9 July 2015 SCM 8221 CLG094856271 NIKL 400,000 R&L 10/15/15 Thursday, 15 October 2015 SCM 8412 CLG0000095182424 GTCAP 7,000 R&L 12/29/15 Tuesday, 29 December 2015 SCM 8583 CLG95399102 CHIB 300,000 R&L 1/13/16 Wednesday, 13 January 2016 SCM 8595 CLG095433563 MER 14,000 R&L 2/26/16 Friday, 26 February 2016 SCM 8659 CLG095570074 BLOOM 1,000,000 R&L 2/26/16 Friday, 26 February 2016 SCM 8659 CLG095570075 PX 200,000 R&L 2/26/16 Friday, 26 February 2016 SCM 8659 CLG095570081 MER 11,000 R&L 2/26/16 Friday, 26 February 2016 SCM 8659 CLG095570077 FPH 45,000 R&L 6/20/16 Monday, 20 June 2016 SCM 8843 CLG095985699 LR 1,000,000 R&L 6/22/16 Wednesday, 22 June 2016 SCM 8872 CLG95998864 CYBR 5,000,000 R&L 6/22/16 Wednesday, 22 June 2016 SCM 8872 CLG95998865 PX 200,000 R&L 6/29/16 Wednesday, 29 June 2016 SCM 8905 CLG096018307 APC 8,000,000 R&L 7/12/16 Tuesday, 12 July 2016 SCM 8927 CLG96063001 FGEN 300,000 R&L 7/22/16 Friday, 22 July 2016 SCM 9043 CLG096106357 SMC 30,000 R&L 7/22/16 Friday, 22 July 2016 SCM 9043 CLG096106284 ALI 100,000 R&L 7/22/16 Friday, 22 July 2016 SCM 9043 CLG096106283 EW 250,000 R&L 7/22/16 Friday, 22 July 2016 SCM 9043 CLG096106285 DD 100,000 R&L 7/22/16 Friday, 22 July 2016 SCM 9043 CLG096106282 NIKL 500,000 R&L 9/2/16 Tuesday, 2 September 2016 SCM 9162 CLG96265097 DDPR 100,000 R&L 9/6/16 Tuesday, 6 September 2016 SCM 9166 CLG096273897 SMC2D 130,000 R&L 10/25/16 Tuesday, 25 October 2016 SCM 9365 CLG96446490 MWIDE 300,000 R&L 11/9/16 Wednesday, 9 November 2016 SCM 9446 CLG96492824 SHLPH 500,000 R&L 11/22/16 Tuesday, 22 November 2016 SCM 9470 CLG096537748 SHLPH 200,000 R&L 11/24/16 Thursday, 24 November 2016 SCM 9475 CLG096547097 SHLPH 300,000 R&L 12/6/16 Tuesday, 6 December 2016 SCM 9492 CLG095679479 SHLPH 500,000 R&L 12/8/16 Thursday, 8 December 2016 SCM 9496 CLG096587912 SHLPH 800,000 R&L 12/13/16 Tuesday, 13 December 2016 SCM 9499 CLG096599482 SHLPH 700,000 R&L 12/29/16 Thursday, 29 December 2016 SCM 9597 CLG96653656 SHLPH 200,000 R&L 1/20/17 Friday, 20 January 2017 SCM 9630 CLG096714452 SHLPH 100,000 R&L 2/13/17 Monday, 13 February 2017 SCM 9664 CLG96783917 SHLPH 200,000 R&L 6/6/17 Tuesday, 6 June 2017 SCM 9960 CLG097180217 SHLPH 100,000 R&L 6/21/17 Wednesday, 21 June 2017 SCM 9971 CLG97232380 DD 100,000 R&L 6/21/17 Wednesday, 21 June 2017 SCM 9971 CLG97232378 AT 500,000 R&L 8/11/17 Friday, 11 August 2017 SCM 10137 CLG093794754 CHIB 100,000 R&L 8/17/17 Thursday, 17 August 2017 SCM 10141 CLG097411016 CHIB 100,000 R&L 8/23/17 Wednesday, 23 August 2017 SCM 10147 CLG097423880 CHIB 300,000 R&L 8/30/17 Wednesday, 30 August 2017 SCM 10154 CLG097442927 NIKL 1,000,000 R&L 9/13/17 Wednesday, 13 September 2017 SCM 10160 CLG097479573 PPC 500,000 R&L 9/29/17 Friday, 29 September 2017 SCM 10196 CLG97543062 DD 100,000 R&L 10/4/17 Wednesday, 4 October 2017 SCM 10202 CLG097556805 NIKL 500,000 R&L 10/11/17 Wednesday, 11 October 2017 SCM 10213 CLG097579093 CHIB 200,000 R&L 10/18/17 Wednesday, 18 October 2017 SCM 10227 CLG97598968 CHIB 300,000 R&L 11/2/17 Thursday, 2 November 2017 SCM 10232 CLG97644751 AC 7,000 R&L 11/14/17 Tuesday, 14 November 2017 SCM 10256 CLG97680604 AC 7,000 R&L 11/24/17 Friday, 24 November 2017 SCM 10262 CLG97716704 AC 2,000 R&L 11/24/17 Friday, 24 November 2017 SCM 10262 CLG97716703 CHIB 200,000 R&L 12/4/17 Monday, 4 December 2017 SCM 10265 CLG097737974 GTPPA 7,000 R&L 12/6/17 Wednesday, 6 December 2017 SCM 10266 CLG097751816 8990P 80,000 R&L 12/13/17 Wednesday, 13 December 2017 SCM 10268 CLG097776108 MPI 500,000 R&L 12/19/17 Tuesday, 19 December 2017 SCM 10277 CLG09798011 MER 30,000 R&L 12/20/17 Wednesday, 20 December 2017 SCM 10278 CLG097804305 SMC 40,000 R&L 12/20/17 Wednesday, 20 December 2017 SCM 10278 CLG097804304 DNL 400,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814364 MWIDE 200,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814363 CLC 500,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814365 DD 100,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814411 NIKL 500,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814630 TEL 4,000 R&L 12/22/17 Friday, 22 December 2017 SCM 10300 CLG097814976 PX 1,000,000 R&L 12/29/17 Friday, 29 December 2017 SCM 10308 CLG097828973 SMC 30,000 R&L 1/12/18 Friday, 12 January 2018 SCM 10320 CLG097867979 CHIB 500,000 R&L 1/26/18 Friday, 26 January 2018 SCM 10338 CLG0000097918626 CHIB 500,000 R&L 2/27/18 Tuesday, 27 February 2018 SCM 10364 CLG0000098022794 CHIB 200,000 R&L 3/7/18 Wednesday, 7 March 2018 SCM 10379 CLG098057820 EW 100,000 R&L 3/7/18 Wednesday, 7 March 2018 SCM 10379 CLG098057819 FGEN 150,000 R&L 3/7/18 Wednesday, 7 March 2018 SCM 10379 CLG098057821 MBT 50,000 R&L 3/7/18 Wednesday, 7 March 2018 SCM 10379 CLG098057818 PXP 300,000 R&L 3/20/18 Tuesday, 20 March 2018 SCM 10382 CLG098095124 APC 5,000,000 R&L 3/20/18 Tuesday, 20 March 2018 SCM 10382 CLG098095125 BLOOM 300,000 R&L 3/20/18 Tuesday, 20 March 2018 SCM 10382 CLG098095126 BPI 50,000 R&L 3/20/18 Tuesday, 20 March 2018 SCM 10382 CLG098095128 GTCAP 2,000 R&L 3/27/18 Tuesday, 27 March 2018 SCM 10393 CLG098127312 CHIB 100,000 R&L 3/27/18 Tuesday, 27 March 2018 SCM 10393 CLG098127313 MBT 60,000 R&L 4/3/18 Tuesday, 3 April 2018 SCM 10394 98139006 FROM R & L AEV 40,000 R&L 4/3/18 Tuesday, 3 April 2018 SCM 10394 98139159 FROM R & L DMC 300,000 R&L 4/3/18 Tuesday, 3 April 2018 SCM 10394 98139002 FROM R & L EAGLE 200,000 R&L 4/17/18 Tuesday, 17 April 2018 SCM 10436 CLG098181661 BPI 50,000 R&L 4/18/18 Wednesday, 18 April 2018 SCM 10438 98184504 FROM R & L CHIB 100,000 R&L 4/18/18 Wednesday, 18 April 2018 SCM 10437 CLG098184499 OPM 200,000,000 R&L 4/18/18 Wednesday, 18 April 2018 SCM 10437 CLG098184503 PCOR 300,000 R&L 4/18/18 Wednesday, 18 April 2018 SCM 10437 CLG098184507 PRF2A 3,000 R&L 4/26/18 Thursday, 26 April 2018 SCM 10445 CLG098212986 AUB 50,000 R&L 4/26/18 Thursday, 26 April 2018 SCM 10445 CLG098212988 BDO 20,000 R&L 4/26/18 Thursday, 26 April 2018 SCM 10445 CLG098211323 BEL 700,000 R&L 4/27/18 Friday, 27 April 2018 SCM 10446 CLG098215991 ALCPB 20,000 R&L 4/27/18 Friday, 27 April 2018 SCM 10446 CLG098215989 COSCO 200,000 R&L 4/27/18 Friday, 27 April 2018 SCM 10446 CLG098215990 PNX3A 25,000 R&L 4/27/18 Friday, 27 April 2018 SCM 10446 CLG098215992 PNX3B 10,000 R&L 5/8/18 Tuesday, 8 May 2018 SCM 10466 CLG098242243 PHEN 1,500,000 R&L 5/8/18 Tuesday, 8 May 2018 SCM 10466 CLG098242247 PNB 20,000 R&L 5/8/18 Tuesday, 8 May 2018 SCM 10466 CLG098242244 SHNG 1,000,000 R&L 5/8/18 Tuesday, 8 May 2018 SCM 10466 CLG098242246 URC 15,000 R&L 5/10/18 Thursday, 10 May 2018 SCM 10468 CLG098250551 BPI 30,000 R&L 5/10/18 Thursday, 10 May 2018 SCM 10468 CLG098250550 EW 100,000 R&L 5/25/18 Friday, 25 May 2018 SCM 10475 CLG098294565 CYBR 4,000,000 R&L 5/25/18 Friday, 25 May 2018 SCM 10475 CLG098294567 GTPPB 3,000 R&L 5/25/18 Friday, 25 May 2018 SCM 10475 CLG098294566 MPI 300,000 R&L 5/31/18 Thursday, 31 May 2018 SCM 10477 CLG098310878 BPI 20,000 R&L 5/31/18 Thursday, 31 May 2018 SCM 10477 CLG098310878 SM 1,800 R&L 6/4/18 Monday, 4 June 2018 SCM 10479 CLG98320988 FROM R & L INVESTMENT ALI 35,000 R&L 6/11/18 Monday, 11 June 2018 SCM 10543 CLG098348080 AC 1,500 R&L 6/11/18 Monday, 11 June 2018 SCM 10543 CLG098348079 ACPB 4,000 R&L 6/11/18 Monday, 11 June 2018 SCM 10543 CLG098348075 BSC 5,000,000 R&L 6/11/18 Monday, 11 June 2018 SCM 10543 CLG098348077 DMC 100,000 R&L 6/11/18 Monday, 11 June 2018 SCM 10543 CLG093848186 RWM 250,000 R&L 6/26/18 Tuesday, 26 June 2018 SCM 10552 CLG098392390 FBP2 2,000 R&L 7/10/18 Tuesday, 10 July 2018 SCM 10570 CLG098439045 MBT 70,000 R&L 7/27/18 Friday, 27 July 2018 SCM 10581 CLG9841878 FROM R&L OV 90,100,000 R&L 7/27/18 Friday, 27 July 2018 SCM 10581 CLG98481863 FROM R&L PPC 120,000 R&L 7/27/18 Friday, 27 July 2018 SCM 10581 CLG9841862 FROM R&L TUGS 200,000 R&L 7/27/18 Friday, 27 July 2018 SCM 10581 CLG98481879 FROM R&L WLCON 100,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498879 ACR 700,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498882 AGI 80,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498881 CLC 170,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498883 CNPF 50,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498884 MWP 10,000 R&L 8/2/18 Thursday, 2 August 2018 SCM 10587 CLG98498880 PX 200,000 R&L 8/6/18 Monday, 6 August 2018 SCM 10593 CLG98509911 TFHI 4,000 R&L 8/7/18 Tuesday, 7 August 2018 SCM 10594 CLG098511904 LTG 50,000 R&L 8/9/18 Thursday, 9 August 2018 SCM 10601 CLG098533170 MBT 17,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537816 CHP 200,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537820 GSMI 30,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537831 MAXS 100,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537815 MRSGI 300,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537817 PBB 100,000 R&L 8/16/18 Thursday, 16 August 2018 SCM 10602 CLG098537818 SCC 30,000 R&L 8/24/18 Friday, 24 August 2018 SCM 10820 CLG098556767 8990P 9,000 R&L 8/24/18 Friday, 24 August 2018 SCM 10820 CLG098556766 AP 15,000 R&L 8/24/18 Friday, 24 August 2018 SCM 10820 CLG098556765 CPM 400,000 R&L 8/30/18 Thursday, 30 August 2018 SCM 10887 CLG98568947 FROM R & L CHIB 40,000 R&L 8/30/18 Thursday, 30 August 2018 SCM 10887 CLG98569089 FROM R & L PAX 700,000 R&L 8/30/18 Thursday, 30 August 2018 SCM 10887 CLG98568986 FROM R & L PSB 14,000 R&L 8/30/18 Thursday, 30 August 2018 SCM 10887 CLG98569090 FROM R & L PXP 100,000 R&L 8/31/18 Friday, 31 August 2018 SCM 10889 CLG98572615 FROM R&L AT 300,000 R&L 8/31/18 Friday, 31 August 2018 SCM 10889 CLG98572616 FROM R&L NIKL 200,000 R&L 9/6/18 Thursday, 6 September 2018 SCM 10893 CLG098590326 BDO 100,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626811 FROM R&L FLI 400,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626809 FROM R&L FPH 10,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626807 FROM R&L MWC 25,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626806 TO R&L PCOR 50,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626808 FROM R&L PGOLD 15,000 R&L 9/19/18 Wednesday, 19 September 2018 SCM 10899 CLG98626810 FROM R&L SM 1,000 R&L 9/28/18 Friday, 28 September 2018 SCM 10910 CLG98657387 FROM R&L SHLPH 5,000 R&L 9/28/18 Friday, 28 September 2018 SCM 10910 CLG98657389 SM 2,000 R&L 10/5/18 Friday, 5 October 2018 SCM 10918 CLG98678907 FROM R&L ABA 1,500,000 R&L 10/5/18 Friday, 5 October 2018 SCM 10918 CLG98678910 FROM R&L BDO 5,000 R&L 10/5/18 Friday, 5 October 2018 SCM 10918 CLG98678911 FROM R&L BPI 5,000 R&L 10/5/18 Friday, 5 October 2018 SCM 10918 CLG98678908 FROM R&L FNI 250,000 R&L 10/5/18 Friday, 5 October 2018 SCM 10918 CLG98678909 FROM R&L MEG 100,000 R&L 10/12/18 Friday, 12 October 2018 SCM 10921 CLG98695758 FROM R&L DNL 70,000 R&L 10/12/18 Friday, 12 October 2018 SCM 10921 CLG98695760 FROM R&L FBP2 500 R&L 10/12/18 Friday, 12 October 2018 SCM 10921 CLG98695759 FROM R&L MBT 10,000 R&L 10/25/18 Thursday, 25 October 2018 SCM 10932 CLG98731026 FROM R&L COSCO 70,000 R&L 10/25/18 Thursday, 25 October 2018 SCM 10932 CLG98731025 FROM R&L MPI 100,000 R&L 10/25/18 Thursday, 25 October 2018 SCM 10932 CLG98731024 FROM R&L MRC 1,500,000 R&L 11/8/18 Thursday, 8 November 2018 SCM 10934 CLG98760856 FROM R&L MBT 20,000 R&L 11/9/18 Friday, 9 November 2018 SCM 10936 CLG98768007 FROM R&L PNB 30,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783650 EEI 60,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783653 GSMI 15,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783654 ICT 7,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783651 MWIDE 60,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783652 PBB 40,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783656 SLF 1,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783649 SSP 300,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783655 URC 4,000 R&L 11/15/18 Thursday, 15 November 2018 SCM 10939 CLG98783648 V 400,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810760 FROM R&L INVESTMENT AUB 20,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810755 FROM R&L INVESTMENT CLC 100,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810758 FROM R&L INVESTMENT CNPF 30,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810757 FROM R&L INVESTMENT EW 50,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810759 FROM R&L INVESTMENT RLC 25,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810754 FROM R&L INVESTMENT SSI 150,000 R&L 11/23/18 Friday, 23 November 2018 SCM 10970 CLG98810756 FROM R&L INVESTMENT VLL 70,000 R&L 11/29/18 Thursday, 29 November 2018 SCM 10973 CLG098826503 SMC 30,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856485 ACPB2 900 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856483 DD 40,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856481 NIKL 300,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856479 OPM 50,000,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856480 OPMB 50,000,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098857364 PAL 50,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098857365 SLF 350 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098857363 SOC 1,000,000 R&L 12/7/18 Friday, 7 December 2018 SCM 10978 CLG098856482 TUGS 120,000 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868579 AC 400 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868578 ALCPB 4,000 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868577 CEB 5,000 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868573 LC 5,020,000 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868575 MAC 30,000 R&L 12/11/18 Tuesday, 11 December 2018 SCM 10981 CLG98868576 SHLPH 10,000 R&L 12/12/18 Wednesday, 12 December 2018 SCM 10983 CLG098873690 CHIB 400,000 R&L 12/19/18 Wednesday, 19 December 2018 SCM 10994 CLG98897711 CHIB 150,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927854 PX 300,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG09827868 ALCO 500,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927850 NI 300,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927889 GEO 2,000,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927851 BLOOM 60,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927852 AGI 40,000 R&L 1/3/19 Thursday, 3 January 2019 SCM 11004 CLG098927853 PRF2A 500 R&L 1/3/19 Thursday, 3 January 2019 SCM 11006 CLG98930648 BC 1,000,000 R&L 1/7/19 Monday, 7 January 2019 SCM 11007 CLG098936703 PNB 10,000 R&L 1/7/19 Monday, 7 January 2019 SCM 11007 CLG098936704 JFC 3,000 R&L 1/10/19 Thursday, 10 January 2019 SCM 11010 CLG98949537 LC 4,000,000 R&L 1/10/19 Thursday, 10 January 2019 SCM 11010 CLG98949538 LPZ 100,000 R&L 1/10/19 Thursday, 10 January 2019 SCM 11010 CLG98949539 PXP 60,000 R&L 1/10/19 Thursday, 10 January 2019 SCM 11010 CLG98949451 SECB 3,000 R&L 1/10/19 Thursday, 10 January 2019 SCM 11010 CLG98949540 BDO 5,000 R&L 1/11/19 Friday, 11 January 2019 SCM 11012 CLG98954421 ISM 100,000 R&L 1/11/19 Friday, 11 January 2019 SCM 11012 CLG98954420 VUL 150,000 R&L 1/11/19 Friday, 11 January 2019 SCM 11012 CLG98954419 IRC 200,000 R&L 1/18/19 Friday, 18 January 2019 SCM 11014 CLG098981007 CHIB 15,000 R&L 1/18/19 Friday, 18 January 2019 SCM 11014 CLG098981006 ABS 15,000 R&L 1/18/19 Friday, 18 January 2019 SCM 11014 CLG098981003 RLT 1,000,000 R&L 1/22/19 Tuesday, 22 January 2019 SCM 11018 CLG098989857 AEV 6,000 R&L 1/29/19 Tuesday, 29 January 2019 SCM 11019 CLG99013847 LMG 100,000 R&L 1/29/19 Tuesday, 29 January 2019 SCM 11019 CLG99013849 GLO 200 R&L 1/29/19 Tuesday, 29 January 2019 SCM 11019 CLG99013845 APC 700,000 R&L 1/29/19 Tuesday, 29 January 2019 SCM 11019 CLG99013846 BRN 400,000 R&L 1/29/19 Tuesday, 29 January 2019 SCM 11019 CLG099013860 PSB 5,820 R&L 3/7/19 Thursday, 7 March 2019 SCM 11029 CGL99138274 PCOR 50,000 R&L 3/7/19 Thursday, 7 March 2019 SCM 11029 CLG99138273 SBS 60,000 R&L 3/7/19 Thursday, 7 March 2019 SCM 11029 CLG99138272 MA 100,000,000 R&L 3/7/19 Thursday, 7 March 2019 SCM 11029 CLG99138271 UPM 100,000,000 R&L 3/7/19 Thursday, 7 March 2019 SCM 11029 CLG99138270 MAB 150,000,000 R&L 3/8/19 Friday, 8 March 2019 SCM 11030 CLG99141582 GTPPB 400 R&L 3/8/19 Friday, 8 March 2019 SCM 11030 CLG99141583 SM 400 R&L 3/8/19 Friday, 8 March 2019 SCM 11030 CLG99141581 GTPPA 420 R&L 3/8/19 Friday, 8 March 2019 SCM 11030 CLG99141580 OPMB 25,000,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162384 RWM 60,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162382 PHEN 280,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162383 EEI 60,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162381 BHI 6,000,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162385 JGS 6,000 R&L 3/15/19 Friday, 15 March 2019 SCM 11033 CLG99162386 GTCAP 800 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182458 ACR 200,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG099918240 ELI 600,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG099182441 ISM 120,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182442 CLI 80,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182457 ZHI 1,500,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182459 MPI 100,000 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182460 ACPB 600 R&L 3/22/19 Friday, 22 March 2019 SCM 11040 CLG0999182443 AP 9,000 R&L 3/26/19 Tuesday, 26 March 2019 SCM 11041 CLG99190537 COL 15,000 R&L 4/4/19 Thursday, 4 April 2019 SCM 11083 CLG99219596 SMC2D 5,000 R&L 4/4/19 Thursday, 4 April 2019 SCM 11083 CLG99219592 LC 2,800,000 R&L 4/4/19 Thursday, 4 April 2019 SCM 11083 CLG99219593 PHA 500,000 R&L 4/4/19 Thursday, 4 April 2019 SCM 11083 CLG9920647 CHIB 60,000 R&L 4/4/19 Thursday, 4 April 2019 SCM 11083 CLG99219595 ANI 18,000 R&L 4/5/19 Friday, 5 April 2019 SCM 11084 CLG099222492 SMPH 7,000 R&L 4/5/19 Friday, 5 April 2019 SCM 11084 CLG099222491 CHP 130,000 R&L 4/5/19 Friday, 5 April 2019 SCM 11084 CLG099222490 MVC 150,000 R&L 4/5/19 Friday, 5 April 2019 SCM 11084 CLG099222489 APX 180,000 R&L 4/5/19 Friday, 5 April 2019 SCM 11084 CLG099222488 APO 400,000 R&L 4/15/19 Monday, 15 April 2019 SCM 11087 CLG099243699 PNB 12,000 R&L 4/15/19 Monday, 15 April 2019 SCM 11087 CLG099243697 STI 500,000 R&L 4/15/19 Monday, 15 April 2019 SCM 11087 CLG099243698 PX 150,000 R&L 4/16/19 Tuesday, 16 April 2019 SCM 11088 CLG099247884 SOC 300,000 R&L 4/16/19 Tuesday, 16 April 2019 SCM 11088 CLG099247887 GMAP 60,000 R&L 4/16/19 Tuesday, 16 April 2019 SCM 11088 CLG099247886 NIKL 100,000 R&L 4/16/19 Tuesday, 16 April 2019 SCM 11088 CLG099247885 IRC 200,000 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099250934 SHLPH 7,000 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259930 OM 450,000 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259931 PRIM 180,000 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259932 FGEN 10,000 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259935 FB 2,400 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259936 FBP2 350 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259937 TEL 300 R&L 4/23/19 Tuesday, 23 April 2019 SCM 11090 CLG099259948 SHNG 80,000 R&L 4/25/19 Thursday, 25 April 2019 SCM 11092 CLG099267890 GTPPA 350 R&L 4/25/19 Thursday, 25 April 2019 SCM 11092 CLG099267889 MAXS 20,000 R&L 4/25/19 Thursday, 25 April 2019 SCM 11092 CLG099267888 HLCM 25,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288138 MRSGI 85,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288135 CPG 450,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288140 AUB 3,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288236 PAX 250,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288141 SMC 2,500 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288237 BC 200,000 R&L 5/3/19 Friday, 3 May 2019 SCM 11100 CLG099288238 PIZZA 15,000 R&L 5/7/19 Tuesday, 7 May 2019 SCM 11101 CLG099297289 ALI 350,000 R&L 5/20/19 Monday, 20 May 2019 SCM 11107 CLG99309574 ALI 17,000 R&L 5/23/19 Thursday, 23 May 2019 SCM 11114 CLG099355765 GTCAP 500 R&L 5/23/19 Thursday, 23 May 2019 SCM 11115 CLG099355764 LTG 12,000 R&L 5/23/19 Thursday, 23 May 2019 SCM 11116 CLG099355763 WPI 300,000 R&L 5/23/19 Thursday, 23 May 2019 SCM 11117 CLG099355762 COAL 650,000 R&L 5/30/19 Thursday, 30 May 2019 SCM 11119 CLG PCOR 50,000 R&L 6/3/19 Monday, 3 June 2019 SCM 11126 CLG099391981 PSB 980 R&L 6/3/19 Monday, 3 June 2019 SCM 11126 CLG099391980 JFC 1,000 R&L 6/3/19 Monday, 3 June 2019 SCM 11126 CLG099391979 PNB 10,000 R&L 6/3/19 Monday, 3 June 2019 SCM 11126 CLG099391978 BPI 20,000 R&L 6/3/19 Monday, 3 June 2019 SCM 11126 CLG099301977 RFM 50,000 R&L 6/19/19 Wednesday, 19 June 2019 SCM 11139 CLG99442233 RCI 1,100,000 R&L 6/19/19 Wednesday, 19 June 2019 SCM 11139 CLG99442234 SMC 8,000 R&L 6/19/19 Wednesday, 19 June 2019 SCM 11139 CLG99442235 BPI 6,000 R&L 6/25/19 Tuesday, 25 June 2019 SCM 11145 CLG099457033 PNB 80,000 R&L 6/27/19 Thursday, 27 June 2019 SCM 11146 CLG099468110 GREEN 200,000 R&L 6/28/19 Friday, 28 June 2019 SCM 11147 CLG099470469 PRF3A 2,000 R&L 7/2/19 Tuesday, 2 July 2019 SCM 11149 CLG099479096 ALCPC 20,000 R&L 7/16/19 Tuesday, 16 July 2019 SCM 11151 CLG99523860 RCI 1,500,000 R&L 7/31/19 Wednesday, 31 July 2019 SCM 11160 CLG099570566 JFC 2,000 R&L 7/31/19 Wednesday, 31 July 2019 SCM 11160 CLG099570564 PNB 20,000 R&L 7/31/19 Wednesday, 31 July 2019 SCM 11160 CLG099570565 DD 15,000 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587589 SLI 100,000 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587547 JFC 2,000 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587546 CEI 1,000,000 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587590 X 150,000 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587591 STR 11,600 R&L 8/6/19 Tuesday, 6 August 2019 SCM 11175 CLG099587588 NRCP 180,000 R&L 8/7/19 Wednesday, 7 August 2019 SCM 11176 CLG099591631 CHP 100,000 R&L 8/7/19 Wednesday, 7 August 2019 SCM 11176 CLG099591633 MPI 65,000 R&L 8/7/19 Wednesday, 7 August 2019 SCM 11176 CLG099591632 NIKL 90,000 R&L 8/13/19 Tuesday, 13 August 2019 SCM 11178 CLG99606370 BDO 15,000 R&L 9/12/19 Thursday, 12 September 2019 SCM 11202 CLG99699878 JFC 3,000 R&L 9/12/19 Thursday, 12 September 2019 SCM 11202 CLG99699886 PNB 10,000 R&L 9/17/19 Tuesday, 17 September 2019 SCM 11203 CLG99710907 RCI 300,000 R&L 9/18/19 Wednesday, 18 September 2019 SCM 11204 CLG99714767 ANS 20,000 R&L 9/18/19 Wednesday, 18 September 2019 SCM 11204 CLG99714766 RWM 25,700 R&L 9/18/19 Wednesday, 18 September 2019 SCM 11204 CLG99714768 BDO 3,000 R&L 9/20/19 Friday, 20 September 2019 SCM 11205 CLG996722761 BSC 700,000 R&L 9/20/19 Friday, 20 September 2019 SCM 11205 CLG99722762 SMC 4,000 R&L 10/9/19 Wednesday, 9 October 2019 SCM 11239 CLG99774482 PX 700,000 R&L 10/14/19 Monday, 14 October 2019 SCM 11268 CLG99785553 AXLM 500,000 R&L 10/15/19 Tuesday, 15 October 2019 SCM 11269 CLG99788560 HOME 100,000 R&L 10/18/19 Friday, 18 October 2019 SCM 11273 CLG099798550 HOME 100,000 R&L 10/22/19 Tuesday, 22 October 2019 SCM 11276 CLG99806853 PPG 30,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831061 PCOR 40,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831062 PGOLD 7,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831054 AGI 15,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831060 PX 90,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831056 PAL 6,200 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831089 MEG 60,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831055 JFC 900 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831057 ICT 2,000 R&L 10/31/19 Thursday, 31 October 2019 SCM 11353 CLG99831059 TBGI 1,300,000 R&L Fourth, there is also no merit in Respondents allegation that based on Sulapas trading pattern, Sulapas is day trader who executes numerous buying and selling transactions during the trading day which characterize Sulapas pattern of transactions as a day trader. 23 A day trader is defined by the United States Securities Commission as a customer who rapidly buys, sells and short-sells stocks throughout the day in the hope that the stocks continue climbing or falling in value for the seconds and minutes they hold the shares, allowing them to lock in quick profits. 24 It can be understood from the foregoing that a day trader refers to buying activity on a particular stock and selling them within the same day with the goal of making a profit or after a profit has been realized. In this case, based on Sulapas' itemized and summarized ledger attached as Annex "F" of the Complainant Position Paper reveal that Sulapas holds his securities for one to three days in average on several occasions. Thus, contrary to Respondents claim, the foregoing ledgers clearly show that Mr. Sulapas is not an active day trader. Fifth, Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L. It is difficult to believe the Respondents simplistic explanation that Ms. Aguilar repeatedly requested Mr. Sulapas to correct and update his information in the CAIF and for his failure to correct, VSI had merely duly noted that Mr. Sulapas maintained an account with another broker dealer for being inconsistent with ordinary experience and common sense. Such failure on the updating of Mr. Sulapas CAIF, at the first instance, should have alerted the Respondents that something was amiss in relation to the conduct of Mr. Sulapas securities transactions. Besides, despite numerous opportunities to do so, i.e. , Aguilar stated in her Affidavit that Mr. Sulapas personally goes to VSI Office in order to collect his checks, 25 still the Respondents failed to cause the updating of the CAIF. Obviously, Respondents did not take any steps to update the CAIF, which is the key component of KYC regulation. Despite Respondents knowledge that Mr. Sulapas is an account holder with other broker, they did not fulfill their mandatory obligation to update his CAIF. Fifth, another disturbing circumstances is the fact that Mr. Sulapas himself in his Sinumpaang Salaysay 26 dated 17 September 2020 and Supplemental Affidavit 27 dated 08 March 2021 denied and controverted the Respondents allegations regarding what transpired during the account opening of Mr. Sulapas and his alleged lack of knowledge or authorization pertaining to the Sulapas account trading transactions, thus: Sinumpaang Salaysay dated 17 September 2020: "15. Na pinapunta ako ulit ni Mar sa PSE makaraan ang mga tatlong linggo hanggang isang buwan. Doon lang po kami may tapat ng Ayala Triangle. Umakyat po kami sa isang gusali doon sa isang opisina sa ika-walong palapag. May kinausap siya doon, "Grace" ang pangalan. Tingin ko siya yung amo doon. Nung panahon na iyon, di ko alam yung opisina, pero ngayon alam ko na Venture Securities, Inc. yun. Binigyan ako ng mga dokumento at sinagutan ko naman. Nagbigay din ako ng mga ID na pina-photocopy nila. Pagkatapos noon ay umuwi na din ako;" xxx xxx xxx 41. Na gusto kong sabihin na wala akong alam tungkol sa scam na binibintang kay Mar. Ang alam ko lang yung mga text sa akin ni Mar tungkol doon sa mga tseke. Yung sa pagbebenta po ng shares, wala po ako alam doon. Supplemental Affidavit dated 08 March 2021: "xvi. Na wala akong alam sa mga nilalaman ng Venture Securities accounts na nakapangalan sa akin, o na may dalawa akong account sa Venture Securities. Wala rin akong natatandaan na kahit anung transaksyon na iniutos ko sa Venture Securities (pag-de-deposito ng pera o pagbenta o pagbili ng kahit anung securities). Ang alam ko lamang ay may mga dokumento akong pinirmahan na iniabot sa akin ni Krystel at ni Dianne ng Venture Securities. May mga pagkakataon din na si Krystel ang kumokontak sa akin para magpunta sa opisina ng Venture Securities para magpapirma ng mga dokumento. Pinapadalhan ako ng mensahe ni Marlo Moron sa cellphone kapag kukunin ko na ang mga tseke. Sa tuwing kukunin ko ang tseke, wala namang espesyal na pakikitungo sa akin sa Venture Securities. xvii. Na iisang CAIF lamang ang pinirmahan ko sa Venture Securities. Ang CAIF para sa SU026 na account sa pangalan ko sa Venture Securities ay hindi ko sulat kamay. Hindi rin pirma ko ang naka-cross signature sa CAIF at Signature Card ng Venture Securities. Maliban sa cross signature, sulat kamay ko ang mga pirma sa mga dokumentong ito;" xxx xxx xxx xxxi. Na may mga pagkakataon na inuutusan ako ni Diane na sabihan si Marlo Moron na hindi pa nahahatid ang mga securities. Sinabihan ko si Marlo Moron, at gagawin niya ang paghahatid. Hinihintay ko lang ang tseke sa Venture kapag ganun, at matapos ang 30 minuto ay nakukuha ko din naman ito. Wala akong natatandaan na nagtanong sa akin si Diane o si Krystel tunkol sa mga share na ihahatid. Si Marlo lamang ang kinakausap nila. Minsan nagbibigay din sa akin si Krystel o Dianne ng mga dokumento para pirmahan sa labas ng opisina ng Venture. Hindi ako nag-utos ng kahit na anung transaksyon sa Venture. Lahat ng mga transaksiyon ay nangaggaling kay Marlo sa pamamagitan ng text message. There is also no merit on the argument of Respondents that it is a violation of their right to due process to present the affidavits of Mr. Sulapas at this point because (i) Respondents were not afforded the opportunity to confront him with his allegations before the Formal Charge was filed, (ii) Mr. Sulapas is not a party to the case filed against Respondents and (iii) he was not present when Respondents appeared before the Market and Securities Regulation during their Investigation. 28 Contrary to their stance, Respondents were accorded due process when Complainant presented the affidavits of Mr. Sulapas as part of its evidence in this case. The Complainant was not also prohibited to obtain the affidavits of its witnesses who are not party to the case. It is not also required for the Respondents to confront Mr. Sulapas with his allegations before the filing of the Formal Charge. It will be sufficient for the satisfaction of the demands of due process that the Respondents were amply apprised of the affidavits, and then given the reasonable opportunity to refute, explain and present their defense. Respondents were able to do this via its Reply to Complainants Position Paper. Trite to state, to confront Mr. Sulapas prior to filing of Formal Charge is not necessary to comply with the requirements of due process. The essence of due process as applied to administrative proceedings is simply the opportunity to be heard. As the Court held in Securities and Exchange Commission v. Universal Rightfield Property Holdings, Inc. 29 "In A.Z. Arnaiz, Realty, Inc. v. Office of the President , the Court held that due process, as a constitutional precept, does not always, and in all situations, require a trial-type proceeding. Litigants may be heard through pleadings, written explanations, position papers, memoranda or oral arguments. The standard of due process that must be met in administrative tribunals allows a certain degree of latitude as long as fairness is not ignored. It is, therefore, not legally objectionable for being violative of due process for an administrative agency to resolve a case based solely on position papers, affidavits or documentary evidence submitted by the parties." Likewise, the claim of Respondents that the statements of Mr. Sulapas in his Sinumpaang Salaysay and Supplemental Affidavit cannot be used against them in this case under the doctrine of res inter alios acta as embodied under Section 31, Rule 130 and as seen in the case of Office of the Ombudsman v. Mislang that said doctrine finds application even in administrative cases 30 is untenable. The Commission as an administrative body is not strictly bound by the technical rules of procedure as it is allowed to be liberal in the application of its rules in deciding administrative and adjudicatory cases. The 2016 SEC Rules of Procedure state that: SEC. 1-4. Construction of Rules. a. These Rules shall be liberally construed and administered to promote public interest, to secure a just, prompt, expeditious, and inexpensive determination of every action and proceeding before the Commission and to carry out the objectives of the laws it is mandated to implement. SEC. 1-6. Suppletory Application of the Rules of Court. The pertinent provisions of the Rules of Court may, in the interest of expeditious dispensation of justice and whenever practicable, be applied by analogy or in a suppletory character and effect. In Divina Palao v. Florentino International, Inc. , 31 the Court had the occasion to explain: "[A]dministrative bodies are not bound by the technical niceties of law and procedure and the rules obtaining in courts of law. Administrative tribunals exercising quasi-judicial powers are unfettered by the rigidity of certain procedural requirements, subject to the observance of fundamental and essential requirements of due process in justiciable cases presented before them. In administrative proceedings, technical rules of procedure and evidence are not strictly applied and administrative due process cannot be fully equated with due process in its strict judicial sense." In any case, even if it is assumed that the rule on res inter alios acta were to apply in this case, the treatment of the statements in the affidavits of Mr. Sulapas as hearsay is bound by the exception on independently relevant statements. "Under the doctrine of independently relevant statements, regardless of their truth or falsity, the fact that such statements have been made is relevant. The hearsay rule does not apply, and the statements are admissible as evidence. Evidence as to the making of such statement is not secondary but primary, for the statement itself may constitute a fact in issue or be circumstantially relevant as to the existence of such a fact. 32 Verily, Mr. Sulapas statement in his affidavits is independently relevant to prove the participation of Respondents in the instant controversy considering the vital role of his securities transaction in the commission of the securities fraud. Thus, such statements made by Mr. Sulapas, who was the alleged owner of the accounts subject of controversy, should be given consideration by the panel as it is directly relevant to the issue at hand. Regarding the claim of Mr. Racadio that he cannot be made liable under SRC Rule 30.2.1.2.4.1, Rule 30.2.1.2.4.3, and Rule 30.2.1.2.4.6 since he is not a registered person, is bereft of merit. As President, he is liable under the law and Rules as control person based on his failure to supervise VSI registered representatives in establishing the true and full identity of each of his clients, their financial situation, investment experience, and investment objectives to begin at least at the time he assumed office as the president of VSI. All told, from all indications, the failure of Respondents VSI, Racadio, Aguilar and Balabis to implement and comply with the requirements of the KYC Rule have resulted or at least contributed to the acts resulting to the prejudice of the investors and rendered the continuous conduct of the illegal trade transactions on Mr. Sulapas account, will make them liable for violating SRC Rule 30.2.1.2.4. on Information About Clients. B. On the Charge for Violation of Rules 52.1.6.8, 52.1.6.15 and 52.1.6.16 of the 2015 SRC Rules (Venture Securities, Inc., Wilfred Racadio, Adora Aguilar and Loreto Balabis) In the Formal Charge, 33 Complainant alleged that: 1. VSI does not have a clear customer acceptance policies and procedures that were applied to Julieto Sulapas. Properly knowing the client through the implementation of appropriate customer acceptance policy (KYC) is an important element in determining suspicious transactions for purposes of Anti-Money Laundering Council reporting. 2. Adora Aguilar does not have knowledge on the background of Julieto Sulapas. 3. Loreto Balabis narrated during the investigative proceedings that Marlo Moron approached him on the PSE trading floor to inform Loreto Balabis that a client of R&L, Julieto Sulapas wants to open an account with Venture. 4. Loreto Balabis also admitted that he merely gave Marlo Moron a blank Customer Account Information Form (CAIF) which was allegedly filled out by Julieto Sulapas without his presence. 5. Julieto Sulapas indicated in his CAIF that he does not have any other account with other broker dealers notwithstanding his existing account with R&L. Adora Aguilar admitted that she knew that Julieto Sulapas has an account with R & L, but she did not require him to correct this fact in the CAIF. 6. Based on the CAIFs and account ledgers of Julieto Sulapas submitted by VSI, the annual income of Julieto Sulapas is Php1 million but he was allowed to transact beyond his financial capability. 7. Adora Aguilar also admitted during the investigative proceedings that there was no verification made for the disclosed source of income (JS Lumber) of Julieto Sulapas. 8. Based on the CAIFs and account ledgers of Julieto Sulapas submitted by VSI, the annual income of Julieto Sulapas is Php1 million but he was allowed to transact way beyond his financial capability. 9. The abovementioned circumstances reveal that VSI lacks proper KYC procedures applied in the Julieto Sulapas accounts. 10. As the overseer of VSI, the President Wilfred Racadio also failed to ensure that proper customer acceptance policies and procedures are in place particularly as to the Julieto Sulapas accounts. In their answer, 34 Respondents countered: 1. The Respondents cannot be held liable under Rule 52.1.6.8, Rule 52.1.6.15, and Rule 52.1.6.16; 2. The Respondents have already sufficiently discussed above their customer acceptance and KYC procedures as well as its anti-money laundering procedures; 3. The Respondents properly identified and interviewed Mr. Sulapas when he went to the office of VSI on 29 May 2012. During this time, Mr. Sulapas was able to provide sufficient information for purposes of creating an account; 4. Based on his transactions from 2012-2019, the Respondents have been able to create a trading profile of Mr. Sulapas as well as determine more accurately his financial situation, investment background, and investment objectives. Based on this information, the Respondents have determined that Mr. Sulapas is able to sustain funding for his transactions almost entirely from his trading activities. Thus, it was well within his financial capacity to enter into his numerous transactions. There have also never been any adverse findings on the Sulapas account when it was part of the audits conducted by CMIC; 5. Ms. Aguilar repeatedly required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead, VSI just duly noted that Mr. Sulapas has another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as fraudulent. We are not persuaded by Respondents arguments. SRC Rule 52.1.6. on Customer Account Information Rule mandates the broker dealer to maintain information for each account. The pertinent provision of the Rule provides: 52.1.6.1. Every Broker Dealer shall maintain for each account, the following information and requirements: xxx xxx xxx 52.1.6.1.7. Signature of the salesman introducing the account and signature of the partner, officer or manager who accepts the account. xxx xxx xxx 52.1.6.8. The Broker Dealer shall develop clear customer acceptance policies and procedures when conducting business relations or accommodating specific transactions and shall exercise due diligence in implementing its policies and procedures. Furthermore, it shall adopt adequate internal control measures for verifying and recording the true and full identity of their customers. It shall require customers to produce original documents of identity issued by an official authority, preferably bearing a photograph of the customer and where practicable, maintain file copies of documents of identity; otherwise, relevant details on the identity documents will be recorded. xxx xxx xxx 52.1.6.13. All existing CAIFs shall be updated within one hundred eighty (180) days after the effectivity of these amendments and every two (2) years subsequent thereto . xxx xxx xxx 52.1.6.15. It is the Broker Dealer's duty to know its clients well and, accordingly, it shall be primarily responsible in keeping current all material information contained in the CAIF . 52.1.6.16. The Broker Dealer, its directors, officers, and associated persons, are required to report any suspicious client transaction to the Anti-Money Laundering Council (AMLC), pursuant to the provisions of the Anti-Money Laundering Act (RA 9160, as amended) . For purposes of this section, a suspicious client transaction shall mean any transaction which causes any ordinary person to have a feeling of apprehension or mistrust about the transaction considering (a) its unusual nature or circumstances, or (b) the person or group of persons with whom they are dealing, and based on the bringing together of all relevant factors including knowledge or the person's or persons' business or background (as well as behavioral factors). (Emphasis ours) xxx xxx xxx As already discussed above, it has already been established by substantial evidence that: (1) Mr. Balabis was not present during the Sulapas account opening; (2) the Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00 but based on the documents submitted there were numerous transactions which were evidently beyond the client's declared financial capacity; (3) Mr. Sulapas was not a day trader; (4) Respondents allowed Julieto Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L; (5) Respondents did not require Mr. Sulapas to update his CAIF; and, (6) Mr. Sulapas denied and controverted in his Sinumpaang Salaysay and Supplemental Affidavit the Respondents allegations regarding what transpired during the account opening of Mr. Sulapas and his allegation of lack of knowledge and authority pertaining to his account trading transactions. Further, both SRC Rule 52.1.6.1.7 and Item III (J) (1) (e) 35 on Books and Records Rule pertaining to minimum required information on CAIF of the Supervisory Procedures and Compliance Manual of VSI require the signature of the Salesman in the CAIF who was introducing the account. Looking at the CAIF, 36 it appears that it was signed by Mr. Balabis despite of his clear admission that he was not present at the time Mr. Sulapas allegedly opened the account with VSI and the fact that no face-to-face interview was done with Mr. Sulapas as required under the VSI Supervisory Procedures. The purpose of Mr. Balabis in affixing his signature in the CAIF is to attest that he verified the information indicated therein to be true and correct. Considering that Mr. Balabis was not present during the account opening and have not conducted a face-to-face interview, he should not have signed the document because he did not have personal knowledge as to the truth and correctness of what he signed. Thus, it must be noted at the outset that there was an infirmity on Mr. Sulapas account opening since the account could not be validly opened in the absence of Mr. Balabis. Furthermore, the allegation of Respondents that there had never been any adverse findings on the Sulapas account when it was part of the audits conducted by CMIC is unavailing for the same have no bearing on the clear violation of the Customer Account Information Rule committed by the Respondents. Under the Rule, updating of CAIF is mandatory and it is the legal duty of Broker Dealers to know its clients well and primarily responsible in keeping current all material information contained in the CAIF. Moreover, the CMIC itself debunked this assertion made by the Respondents since, ultimately, in its 19 December 2019 Report, 37 CMIC clearly stated that there were violations of the SRC and its IRR committed by VSI regarding the Sulapas account and his securities transactions. Besides, the Commission as the primary regulator being the government agency mandated to administer the SRC, 38 and is given regulatory powers 39 and "absolute jurisdiction, supervision and control over all corporations, partnerships' or associations" 40 is not bound on the inadvertence committed by CMIC in its audit findings, if any. To ensure compliance with the law and the rules, the Securities and Exchange Commission is also given the power to impose fines and penalties. It may also investigate motu proprio whether corporations comply with the Corporation Code, Securities Regulation Code, and rules implemented by the Securities and Exchange Commission. SEC. 5. Powers and Functions of the Commission . 5.1. The Commission shall act with transparency and shall have the powers and functions provided by this Code, Presidential Decree No. 902-A, the Corporation Code, the Investment Houses Law, the Financing Company Act and other existing laws. Pursuant thereto the Commission shall have, among others, the following powers and functions: xxx xxx xxx d. Regulate, investigate or supervise the activities of persons to ensure compliance; xxx xxx xxx f. Impose sanctions for the violation of laws and the rules, regulations and orders issued pursuant thereto; xxx xxx xxx i. Issue cease and desist orders to prevent fraud or injury to the investing public; xxx xxx xxx m. Suspend, or revoke, after proper notice and hearing the franchise or certificate of registration of corporations, partnerships or associations, upon any of the grounds provided by law; and n. Exercise such other powers as may be provided by law as well as those which may be implied from, or which are necessary or incidental to the carrying out of, the express powers granted the Commission to achieve the objectives and purposes of these laws. 41 Hence, the Commission may initiate and conduct its own audit and investigation anytime independently of CMIC on the Sulapas account, file charges and impose administrative sanctions if warranted by the attendant circumstances. There is also no merit in Respondents assertion that VSI has systems in place for purposes of Anti-Money Laundering since (1) VSI reports all covered transactions, including the transactions of Mr. Sulapas, (2) VSI did not make any suspicious transaction report on the transactions of Mr. Sulapas because all of his transactions were in accordance with his trading profile and with his established trading pattern, and (3) his EQ Trade transactions only formed a small part of his buying and selling transactions." 42 In support of this argument, Respondents appended in their Reply Annexes "21" and 21-A" the alleged VSI systems 43 in place relative to Anti-Money Laundering. In their claim that VSI also submits the required reports, samples of reports submitted by VSI to the Anti-Money Laundering Council are also attached as Annex "23" of their Reply. Contrary to the Respondents claim, based on the CMIC Report, CMIC found that the withdrawals from the Sulapas account from 4 June 2012 to 22 June 2017 were made so that each check would be lower than Five Hundred Thousand Pesos (Php500,000.00) to remove the transactions from the purview of the Anti-Money Laundering Council. CMIC also noted that multiple checks were prepared for a particular day. The pertinent portion of the Report provides and we quote: " B.3. Movement of Cash Based on Ledgers of Mr. Sulapas Based on the review of money movements in the accounts of Mr. Sulapas (SU026 and SU027), CMIC noted that that the client had made no cash deposits since inception date of the account. On the contrary, five hundred forty (540) check withdrawals, with an aggregate value of Six Hundred Three Million Eight Hundred Forty Thousand Seven Hundred Thirty and 70/100 pesos (Php603,840,730.70), were drawn in favor of Mr. Sulapas. CMIC found that the withdrawals from the accounts from 4 June 2012 to 22 June 2017 were made so that each check would be lower than Five Hundred Thousand Pesos (Php500,000.00) to remove the transactions from the purview of the Anti-Money Laundering Council. Similarly noted is the fact that multiple checks were prepared for a particular day. However, starting 23 June 2017, the checks being prepared were already based on actual amounts for disbursements; they were no longer divided into several checks. There are one hundred twenty-seven (127) checks issued subsequent to 22 June 2019, averaging P3,388,605 per check, with a total value of P430,352,880." Although Respondents allegation that VSI system is in place for purposes of Anti-Money Laundering may be true, the panel, nonetheless, observes that it is highly unlikely that Respondents VSI, Racadio and Aguilar did not have any participation in violating the Customer Account Information Rule, specifically Rule 52.1.6,16 which requires the Broker Dealer, its directors, officers, and associated persons, to report any suspicious client transaction to the Anti-Money Laundering Council, pursuant to the provisions of the Anti-Money Laundering Act. A review of the documents submitted by VSI during the investigation which forms part of the records of the case, the panel also noted that one of the signatories of the checks was Mr. Racadio. Notably, the fact that Respondent Racadio signed the multiple checks lower than Five Hundred Thousand Pesos (Php500,000.00) and prepared for the same day starting January 7, 2016 do not discount Respondent's participation to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council. Likewise, the samples of reports dated January 3-5, 2017 allegedly submitted by VSI to the Anti-Money Laundering Council attached as Annex "23" of their Reply appears not to have any relation to VSI reports pertaining to the transactions of Mr. Sulapas. From the foregoing, VSI, its directors, officers, and associated person, failed on their duty to report the suspicious Sulapas transaction to the Anti-Money Laundering Council, pursuant to the provisions of the Anti-Money Laundering Act (RA 9160, as amended) and as required by SRC Rule Sec. 52.1.6.16. The claim of Mr. Racadio that since he started as an employee (as President) of VSI only in July 2014, or over two (2) years after the opening of the Sulapas account, he may not be accused of failure to put in place and implement proper acceptance policies and procedures as to the Sulapas account at the time of the opening of the account and for a significant time after that 44 is also without merit. As President, he is liable under the Rules as control person based on his failure to supervise VSI registered representatives in requiring the updating of the Sulapas account and the Respondents' (including Racadio) duty to report the suspicious Sulapas transaction to the Anti-Money Laundering Council as required by the Rule at least beginning at the time he assumed the office as president of VSI. Likewise, the Customer Account Information Rule mandates the broker dealer to maintain information pertaining to the account after its opening like updating in every two years and keeping current all material information in the CAIF. Clearly, VSI, Racadio, Aguilar and Balabis, for their failure to ensure that proper customer acceptance policies and procedures are in place and implemented in the Julieto Sulapas accounts, have violated Rule 52.1.6 Customer Account Information Rule. C. On the Charge for Violation of Rule 48.2 in connection with Rule 48.1 of the 2015 SRC Rules (VSI and Racadio) D. On the Charge for Violation of Rule 50.1 of the 2015 SRC Rules (VSI and Racadio) The above issues shall be discussed together because they are intertwined with each other. On the alleged violation of Rule 48.2 in relation to 48.1, Complainant alleges that: 45 1. Among the documents received from VSI is a credit line agreement in favor of Julieto Sulapas which includes a provision on interest. This indicates that the Sulapas account is a margin account. 2. The Julieto Sulapas account does not comply with the Rules and Regulations of the Commission on margin accounts as enumerated under Rules 48.1 and 48.2 of the 2015 Implementing Rules and Regulations to the Securities Regulation Code. 3. Despite such non-compliance, the credit line agreement is still signed by Wilfred Racadio as the representative of VSI. Respondents argued, that: 46 1. Mr. Racadio cannot be held liable under Rule 48.2 in connection with Rule 48.1 of the SRC-IRR regarding margin accounts; 2. Mr. Racadio maintains that the Sulapas is a cash account. Moreover, even assuming without conceding that the Sulapas Account is a margin account, the said account complies with all the requirements for a margin account as set forth in Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5, and 48.2.2; 3. Under the terms of the credit line agreement, Mr. Sulapas was allowed to borrow up to 40% of the current market value of his present stock holdings. The amount Mr. Sulapas was allowed to borrow was much lower compared to the limit set under Rule 48.1.1 of the SRC-IRR; 4. Mr. Sulapas was also required to maintain a margin of at least 60% of the current market value of his present stock holdings. This is much higher compared to the minimum amount set in Rule 48.1.2 of the SRC-IRR; 5. Sulapas settled all "margin calls" made by VSI without any issues; 6. Mr. Sulapas always maintained sufficient collateral on securities in accordance with Rule 48.2.2 of the SRC-IRR. Venture Securities also did not encounter any problems with Mr. Sulapas; 7. Based on the foregoing, there is no intention on the part of Mr. Racadio and the rest of the Respondents to evade the requirements for margin accounts under the SRC and the SRC-IRR. On the alleged violation of Rule 50.1, Complainant alleges that: 47 1. During the administrative proceedings, Adora Aguilar insisted that the Julieto Sulapas account is a cash account. 2. Assuming arguendo that the account is indeed a cash account, the account ledger of Julieto Sulapas submitted by VSI however shows that Julieto Sulapas did not settle his purchases within T+3 in violation of the SRC-IRR. 3. The President Wilfred Racadio has the duty to oversee the day to day operations of Venture Securities, including ensuring the compliance of the broker dealer to the requirements for cash accounts under the Securities Regulation Code and its Implementing Rules and Regulations. Wilfred Racadio failed to ensure compliance to the T+3 requirement in this case. 4. Hence, VSI and Wilfred Racadio violated Rule 50.1 of the 2015 SRC Rules. On the other hand, Respondents contended that: 48 1. VSI and Mr. Racadio cannot be made liable for violating Rule 50.1 of the SRC-IRR with regard to the Sulapas Account; 2. The account ledgers of the Sulapas account show that Mr. Sulapas settled his purchases within T+3 days. Mr. Sulapas settled his purchases by selling shares within T+3 days (with proceeds enough to pay for the purchases), or by availing of his Credit Line, or by paying in cash. Mr. Sulapas did not need to avail of his Credit Line Agreement for the majority of his purchases. For all of his transactions where he did not avail of the Credit Line Agreement, Mr. Sulapas was able to settle his purchases within T+3 days; 3. As previously discussed, the account of Mr. Sulapas complies with Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5, and 48.2.2. of the SRC-IRR. In weighing the arguments of the parties on these issues, it is important to examine the evidence presented. Based on the CAIF's and the account opening agreement (Terms and Conditions) submitted, we are inclined to believe that the Sulapas account is a cash account. Interestingly, no other than the Complainant submitted the CMIC Report dated 19 December 2020 as part of its evidence stating that the Sulapas Account with VSI is a Cash Account. The pertinent portion of the Report, reads: "Lastly CMIC noted that one of the accounts of Mr. Sulapas, not identified as margin account in the ACD Form 01, a form requested by each trading participant prior to commencement of audit, had been charged interest by Venture beginning 2015. This may amount to violations of the pertinent laws. Total interest charges amounted to Eight Million Seven Hundred Thirty-One Thousand Four Hundred Forty-Seven and 23/100 pesos (8,731,447.23)." 49 On this point, we agree with the Respondents that Mr. Sulapas Account is a Cash Accounts and not a Margin Accounts. The provisions governing the above issues are Sections 48.2 and 50 of the SRC 50 and SRC Rules 48.2, 48.1 and 50, which state as follows: " Section 48 . Margin Requirements . xxx xxx xxx 48.2. No member of an Exchange or broker or dealer shall , directly or indirectly, extend or maintain credit or arrange for the extension or maintenance of credit to or for any customer : a) On any security unless such credit is extended and maintained in accordance with the rules and regulations which the Commission shall prescribe under this Section including rules setting credit in relation to net capital of such member, broker or dealer ; and b) Without collateral or any collateral other than securities, except (i) to maintain a credit initially extended in conformity with rules and regulations of the Commission and (ii) in cases where the extension or maintenance of credit is not for the purpose of purchasing or carrying securities or of evading or circumventing the provisions of paragraph (a) of this subsection. (Emphasis ours) xxx xxx xxx" " Section 50. Enforcement of Margin Requirement and Restrictions on Borrowing . To prevent indirect violations of the margin requirements under Section 48, the broker or dealer shall require the customer in non-margin transactions to pay the price of the security purchased for his account within such period as the Commission may prescribe , which shall in no case exceed the prescribed settlement date. Otherwise, the broker shall sell the security purchased starting on the next trading day but not beyond ten (10) trading days following the last day for the customer to pay such purchase price, unless such sale cannot be effected within said period for justifiable reasons . x x x" SRC Rule 48.2 Prohibitions on Extension of Credit No member of an Exchange or broker or dealer shall, directly or indirectly, extend or maintain credit or arrange for the extension or maintenance of credit to or for any customer on the following: 48.2.1. On any security unless such credit is extended and maintained in accordance with the rules and regulations which the Commission shall prescribe under this Section including rules setting credit in relation to net capital of such member, broker or dealer; SRC Rule 48.1 Margin 48.1.1. A Broker Dealer shall not extend credit to a customer in an amount that exceeds fifty percent (50%) of the current market value of the security at the time of the transaction. In no event shall new or additional credit be extended to an account in which the equity is less than Fifty Thousand Pesos (PhP50,000.00). 48.1.2. The margin maintained in a margin account of a customer shall be no less than twenty five percent (25%) of the current market value of all securities "long" in the account and thirty percent (30%) of the current market value of securities "short" in the account. 48.1.3. When there is an insufficiency of margin, a call for additional margin shall be issued promptly by the Broker Dealer to the customer. A call for initial margin shall be satisfied within five (5) business days from receipt of the call. A call for maintenance margin shall be satisfied within twenty four (24) hours after the call is received. No purchase or sell order from the customer on the margin account shall be executed by the Broker Dealer from the time of insufficiency up to the satisfaction of the call. 48.1.4. If a margin call is not satisfied within the time prescribed in SRC Rule 48.1.3, the Broker Dealer shall liquidate securities sufficient to meet the margin call or eliminate the margin deficiency existing on the day such liquidation is required, whichever is less. The Broker Dealer shall liquidate the securities through the Exchange in which it is traded before the close the next trading day. 48.1.5. The required payment date for a call for initial margin may be extended by seven (7) days upon written application delivered by hand, facsimile transmission, email or equally prompt means by the Broker Dealer to an Exchange, in the case of members of that Exchange, or to the Commission, in the case of non-Exchange members. In granting such an extension, the Exchange or Commission will take into consideration whether the Broker Dealer and the customer are acting in good faith and whether exceptional circumstances warrant such extension. Application for the extension must be received and acted upon before the expiration of the original payment period or the expiration of any previous extension. SRC Rule 50 Purchases and Sales in Cash Account 50.1. Purchases by a customer in a cash account shall be paid in full within three (3) business days after the trade date. 50.2. If full payment is not received within the required time period, the Broker Dealer shall cancel or otherwise liquidate the transaction, or the unsettled portion thereof, starting on the next business day but not beyond ten (10) business days following the last day for the customer to pay, unless such sale cannot be effected within said period for justifiable reasons in which case, notification in writing shall be made with the Exchange and the Commission. 50.3. If a transaction is cancelled or otherwise liquidated as a result of non-payment by the customer, prior to any subsequent purchase during the next ninety (90) days, the customer shall be required to deposit sufficient funds in the account to cover each purchase transaction prior to execution. 50.4. If the amount of money due from a customer in a cash account is less than Ten Thousand Pesos (PhP10,000.00) the Broker Dealer may choose not to take the action required by SRC Rule 50.2. 50.5. Exceptions to SRC Rules 50.1, 50.2, and 50.3 include when the security purchased is unissued or where the purchase is made by the customer with the understanding that payment is to be made upon delivery. 50.6. Written application for an extension of the period of time required for payment under SRC Rule 50.1 may be made by the Broker Dealer to the Exchange in the case of a member of that Exchange or to the Commission, in the case of a non-member of the Exchange. Applications for the extension must be based upon exceptional circumstances and must be filed and acted upon before the expiration of the original payment period or the expiration of any subsequent extension. xxx xxx xxx Section 48.2 of the SRC and Rule 48.2 above make it unlawful for a broker to extend or maintain credit on any securities other than in conformity with the rules and regulations issued by the Commission. Section 50 of the SRC and SRC Rule 50 set forth the rules on purchases and sales by customers in cash account to prevent indirect violations of Section 48.2 by brokers dealers. SRC Rule 50 prescribes in detail the regulations governing cash accounts and lays down the exceptions to the general rule ( i.e. , that full payment must be made within 3 days) which include a situation where the purchase is made by the customer with the understanding that payment is to be made upon delivery. The Supreme Court in the case of Abacus Securities Corporation v. Ampil 51 had the occasion to discuss the general rule and the purpose of margin requirements, to wit: "The United States, from which our country's security policies are patterned, abound with authorities explaining the main purpose of the above statute on margin requirements. [The main purpose of the statute] is to regulate the volume of credit flow , by way of speculative transactions, into the securities market and redirect resources into more productive uses. Specifically, the main objective of the law on margins is explained in this wise: 'The main purpose of these margin provisions x x x is not to increase the safety of security loans for lenders. Banks and brokers normally require sufficient collateral to make themselves safe without the help of law. Nor is the main purpose even protection of the small speculator by making it impossible for him to spread himself too thinly although such a result will be achieved as a byproduct of the main purpose. xxx xxx xxx 'The main purpose is to give a [g]overnment credit agency an effective method of reducing the aggregate amount of the nation's credit resources which can be directed by speculation into the stock market and out of other more desirable uses of commerce and industry x x x.' A related purpose of the governmental regulation of margins is the stabilization of the economy . Restrictions on margin percentages are imposed 'in order to achieve the objectives of the government with due regard for the promotion of the economy and prevention of the use of excessive credit.' Otherwise stated, the margin requirements set out in the [SRC] are primarily intended to achieve a macroeconomic purpose the protection of the overall economy from excessive speculation in securities . Their recognized secondary purpose is to protect small investors. The law places the burden of compliance with margin requirements primarily upon the brokers and dealers. [Sections 48.2 and 50 of the SRC and SRC Rule 50], otherwise known as the 'mandatory close-out rule,' clearly vest upon petitioner the OBLIGATION, not just the right, TO CANCEL or otherwise LIQUIDATE a customer's order, if payment is NOT RECEIVED WITHIN THREE DAYS from the date of purchase . The word "shall" as opposed to the word "may," is imperative and operates to impose a duty, which may be legally enforced. For transactions subsequent to an unpaid order, the broker should require its customer to deposit funds into the account sufficient to cover each purchase transaction prior to its execution. These duties are imposed upon the broker to ensure faithful compliance with the margin requirements of the law, which forbids a broker from extending undue credit to a customer. It will be noted that trading on credit (or 'margin trading') allows investors to buy more securities than their cash position would normally allow. Investors pay only a portion of the purchase price of the securities; their broker advances for them the balance of the purchase price and keeps the securities as collateral for the advance or loan. Brokers take these securities/stocks to their bank and borrow the 'balance' on it, since they have to pay in full for the traded stock. Hence, increasing margins, i.e. , decreasing the amounts which brokers may lend for the speculative purchase and carrying of stocks is the most direct and effective method of discouraging an abnormal attraction of funds into the stock market and achieving a more balanced use of such resources. 'x x x [T]he x x x primary concern is the efficacy of security credit controls in preventing speculative excesses that produce dangerously large and rapid securities price rises and accelerated declines in the prices of given securities issues and in the general price level of securities. Losses to a given investor resulting from price declines in thinly margined securities are not of serious significance from a regulatory point of view. When forced sales occur and put pressures on securities prices, however, they may cause other forced sales and the resultant snowballing effect may in turn have a general adverse effect upon the entire market.' The nature of the stock brokerage business enables brokers, not the clients, to verify, at any time, the status of the client's account. Brokers, therefore, are in the superior position to prevent the unlawful extension of credit. Because of this awareness, the law imposes upon them the primary obligation to enforce the margin requirements. Right is one thing; obligation is quite another. A right may not be exercised; it may even be waived. An obligation, however, must be performed; those who do not discharge it prudently must necessarily face the consequence of their dereliction or omission." (Emphasis ours) As can be gleaned from the case of Abacus , the purpose of the general rule is to regulate the credit flow in the securities market when shares of stock are purchased by an investor, as in this instant case, when the shares were purchased by Mr. Sulapas. As a consequence, brokers and dealers are forbidden from extending credit under Section 48.2 of the SRC, and SRC Rules 48.2 and 50 obligate them to liquidate the shares in a customer's order, if payment is not received within three (3) days from the date of purchase. In this case, the Respondents alleged that the account ledgers of the Sulapas account show that Mr. Sulapas settled his purchases within T+3 days. Mr. Sulapas settled his purchases by "selling" shares within T+3 days (with proceeds enough to pay for the purchases), or by availing of his Credit Line , or by paying in cash. Mr. Sulapas did not need to avail of his Credit Line Agreement for the majority of his purchases. For all of his transactions where he did not avail of the Credit Line Agreement, Mr. Sulapas was able to settle his purchases within T+3 days. 52 Unfortunately for the Respondents, they unlawfully applied the payment on some of the purchases of Sulapas allegedly within T+3 by availing a credit line since the Sulapas account is a cash account. The provision of SRC Rule 50 is specific. It provides that "purchases by a customer in a cash account shall be paid in full within three (3) business days after the trade date. If full payment is not received within the required time period, the Broker Dealer shall cancel or otherwise liquidate the transaction, or the unsettled portion thereof, starting on the next business day but not beyond ten (10) business days following the last day for the customer to pay, unless such sale cannot be effected within said period for justifiable reasons in which case, notification in writing shall be made with the Exchange and the Commission. If a transaction is cancelled or otherwise liquidated as a result of non-payment by the customer, prior to any subsequent purchase during the next ninety (90) days, the customer shall be required to deposit sufficient funds in the account to cover each purchase transaction prior to execution. To repeat, based on Sulapas ledger (SU026), there was only one event that Sulapas paid cash for his transactions in the amount of Php981,612.00 on 04 November 2019 for the transaction Buy 87228 dated 29 October 2019 for 20,000 shares of ALI at P48.80 per shares. To be clear, the Sulapas account had 559 transactions from 2012 to 2019 which were not paid in cash within T+3 taking into consideration the net payable amount based on the previous day credit balance enumerated herein below. 2012 T+0 No. Friday, 8 June 2012 1 Date Ref. No. Transaction Particulars Amount Friday, 8 June 2012 39703 BUY 300,000 VMC Shares 526,650.94 Friday, 8 June 2012 47223 SELL 10,000 EW shares -186,374.70 Friday, 8 June 2012 47228 SELL 150,000 VMC Shares -241,377.00 Due Clearing (06/14/2012) 98,899.24 Cr. as of Settlement Date (06/14/2012) -92,521.94 Net Payable Amount (06/14/2012) 6,377.30 Friday, 22 June 2012 2 Date Ref. No. Transaction Particulars Amount Friday, 22 June 2012 39825 BUY 20,000 DIZ shares 683,910.00 Friday, 22 June 2012 39828 BUY 118,800 NI shares 1,050,400.29 Friday, 22 June 2012 39829 BUY 81,200 NI shares 721,565.29 Friday, 22 June 2012 39831 BUY 100,000 ORE shares 552,369.98 Friday, 22 June 2012 47890 SELL 12,700 DIZ shares -452,596.70 Friday, 22 June 2012 47391 SELL 2,300 DIZ shares -82,364.95 Friday, 22 June 2012 47392 SELL 5,000 DIZ shares -179,553.82 Friday, 22 June 2012 47396 SELL 100,000 MARC shares -252,456.60 Friday, 22 June 2012 47401 SELL 100,000 ORE shares -529,743.38 Friday, 22 June 2012 47406 SELL 900,000 VMC shares -1,326,584.25 Due Clearing (06/27/2012) 184,945.86 Cr. as of Settlement Date (06/27/2012) -172,500.85 Net Payable Amount (06/27/2012) 12,445.01 Monday, 25 June 2012 3 Date Ref. No. Transaction Particulars Amount Monday, 25 June 2012 39838 BUY 100,000 DIZ Shares 3,872,137.50 Monday, 25 June 2012 47409 SELL 48,900 DIZ Shares 1,790,458.40 Monday, 25 June 2012 47410 SELL 1,100 DIZ Shares -40,549.36 Monday, 25 June 2012 47416 SELL 200,000 NI Shares -1,721,295.00 Net Payable Amount (06/28/2012) 319,834.74 Friday, 29 June 2012 4 Date Ref. No. Transaction Particulars Amount Friday, 29 June 2012 39879 BUY 2,000,000 LIHC shares 2,604,892.50 Friday, 29 June 2012 39883 BUY 500,000 RFM shares 1,759,982.05 Friday, 29 June 2012 47468 SELL 500,000 TDY shares 2,229,848.64 Friday, 29 June 2012 47475 SELL 500,000 RFM shares 1,760,864.99 Net Payable Amount (07/04/2012) 374,160.92 Monday, 2 July 2012 5 Date Ref. No. Transaction Particulars Amount Monday, 2 July 2012 39898 BUY 1,000,000 MEG shares 2,252,880.00 Net Payable Amount (07/05/2012) 2,252,880.00 Wednesday, 4 July 2012 6 Date Ref. No. Transaction Particulars Amount Wednesday, 4 July 2012 39938 BUY 1,000,000 GERI 2,045,433.99 Wednesday, 4 July 2012 47553 SELL 1,500,000 LIHC -1,825,166.25 Net Payable Amount (07/09/2012) 220,267.74 Friday, 6 July 2012 7 Date Ref. No. Transaction Particulars Amount Friday, 6 July 2012 39978 BUY 500,000 BEL shares 2,614,950.00 Friday, 6 July 2012 39992 BUY 300,000 LR shares 2,684,321.62 Friday, 6 July 2012 39993 BUY 100,000,000 OPMB shares 2,011,500.00 Friday, 6 July 2012 47586 SELL 500,000 BEL shares -2,621,512.50 Friday, 6 July 2012 47591 SELL 35,700 DIZ shares 1,247,112.83 Friday, 6 July 2012 47592 SELL 14,300 DIZ shares -501,895.98 Friday, 6 July 2012 47597 SELL 500,000 LIHC shares -638,066.26 Friday, 6 July 2012 47602 SELL 136,100 LR shares 1,161,156.90 Friday, 6 July 2012 47603 SELL 63,900 LR shares -547,425.24 Net Payable Amount (07/11/2012) 593,601.91 Monday, 9 July 2012 8 Date Ref. No. Transaction Particulars Amount Monday, 9 July 2012 40007 BUY 1,500,000 LC shares 2,247,851.25 Monday, 9 July 2012 40009 BUY 2,000,000 LCB shares 3,097,710.00 Monday, 9 July 2012 47612 SELL 300,000 BLOOM shares 3,163,621.50 Net Payable Amount (07/12/2012) 2,181,939.75 Thursday, 12 July 2012 9 Date Ref. No. Transaction Particulars Amount Thursday, 12 July 2012 40054 BUY 100,000,000 GREEN shares 1,508,625.00 Thursday, 12 July 2012 40070 BUY 110,000 PGOLD shares 2,987,077.50 Due Clearing (07/17/2012) 4,495,702.50 Cr. as of Settlement Date (07/17/2012) -344,050.84 Net Payable Amount (07/17/2012) 4,151,651.66 Friday, 13 July 2012 10 Date Ref. No. Transaction Particulars Amount Friday, 13 July 2012 40080 BUY 5,000,000 ABA shares 4,525,875.00 Friday, 13 July 2012 47686 SELL 1,000,000 ABA shares -830,970.00 Friday, 13 July 2012 47704 SELL 100,000 PGOLD shares 2,641,297.50 Net Payable Amount (07/18/2012) 1,053,607.50 Tuesday, 17 July 2012 11 Date Ref. No. Transaction Particulars Amount Tuesday, 17 July 2012 40117 BUY 5,000,000 ELI shares 4,508,928.11 Tuesday, 17 July 2012 47726 SELL 5,000,000 ELI shares 4,313,149.79 Net Payable Amount (07/20/2012) 195,778.32 Thursday, 19 July 2012 12 Date Ref. No. Transaction Particulars Amount Thursday, 19 July 2012 40156 BUY 2,000,000 ABA shares 1,850,580.00 Thursday, 19 July 2012 40165 BUY 2,000,000 GEO shares 1,206,900.00 Thursday, 19 July 2012 47747 SELL 2,000,000 ABA shares -1,859,790.00 Net Payable Amount (07/24/2012) 604,140.00 Tuesday, 24 July 2012 13 Date Ref. No. Transaction Particulars Amount Tuesday, 24 July 2012 40201 BUY 4,000,000 ABA shares 3,942,540.00 Tuesday, 24 July 2012 40202 BUY 2,000,000 ABA shares 2,051,730.00 Tuesday, 24 July 2012 47778 SELL 1,000,000 GEO shares -593,550.00 Net Payable Amount (07/27/2012) 2,833,616.25 Tuesday, 31 July 2012 14 Date Ref. No. Transaction Particulars Amount Tuesday, 31 July 2012 40279 BUY 700,000 PIP shares 2,307,924.69 Tuesday, 31 July 2012 40280 BUY 500,000 PIP shares 1,682,438.71 Tuesday, 31 July 2012 47840 SELL 3,000,000 ABA shares -2,789,685.00 Net Payable Amount (08/03/2012) 1,200,678.40 Wednesday, 1 August 2012 15 Date Ref. No. Transaction Particulars Amount Wednesday, 1 August 2012 40289 BUY 590,000 VMC shares 872,286.98 Wednesday, 1 August 2012 40302 BUY 300,000 TDY shares 2,202,592.50 Wednesday, 1 August 2012 40309 BUY 1,410,000 VMC shares 1,981,689.57 Wednesday, 1 August 2012 47855 SELL 2,000,000 ABA shares -1,859,790.00 Wednesday, 1 August 2012 47878 SELL 300,000 TDY shares -2,270,328.74 Net Payable Amount (08/06/2012) 926,450.31 Friday, 3 August 2012 16 Date Ref. No. Transaction Particulars Amount Friday, 3 August 2012 40349 BUY 500,000 MJC shares 1,634,042.02 Friday, 3 August 2012 40368 BUY 201,400 TDY shares 2,349,210.73 Friday, 3 August 2012 40369 BUY 142,100 TDY shares 1,839,977.38 Friday, 3 August 2012 40370 BUY 238,500 TDY shares 3,319,809.75 Friday, 3 August 2012 40371 BUY 261,500 TDY shares 3,680,753.35 Friday, 3 August 2012 47931 SELL 237,000 CAL shares 1,407,643.40 Friday, 3 August 2012 47932 SELL 13,000 CAL shares -77,586.88 Friday, 3 August 2012 47938 SELL 200,000 MJC shares -675,657.74 Friday, 3 August 2012 47968 SELL 243,500 TDY shares 2,949,160.01 Friday, 3 August 2012 47969 SELL 400,000 TDY shares -5,468,574.00 Due Clearing (08/08/2012) 2,245,171.20 Cr. as of Settlement Date (08/08/2012) -397,697.80 Net Payable Amount (08/08/2012) 1,847,473.40 Wednesday, 8 August 2012 17 Date Ref. No. Transaction Particulars Amount Wednesday, 8 August 2012 40398 BUY 1,000,000 CMT shares 2,524,432.50 Wednesday, 8 August 2012 40409 BUY 63,000 TDY shares 758,928.89 Wednesday, 8 August 2012 40410 BUY 610,000 TDY shares 7,639,375.27 Wednesday, 8 August 2012 40411 BUY 145,200 TDY shares 1,898,087.62 Wednesday, 8 August 2012 48009 SELL 31,000 CMT shares -75,133.53 Wednesday, 8 August 2012 48015 SELL 98300 PGOLD shares -2,751,984.69 Wednesday, 8 August 2012 48025 SELL 445,100 TDY shares -5,638,265.99 Wednesday, 8 August 2012 48026 SELL 154,900 TDY shares -1,980,597.20 Wednesday, 8 August 2012 48027 SELL 18,200 TDY shares -233,696.46 Due Clearing (08/13/2012) 2,141,146.41 Cr. as of Settlement Date (08/13/2012) -599,196.86 Net Payable Amount (08/13/2012) 1,541,949.55 Thursday, 9 August 2012 18 Date Ref. No. Transaction Particulars Amount Thursday, 9 August 2012 40423 BUY 700,000 ACE shares 1,233,049.50 Thursday, 9 August 2012 40434 BUY 200,000 TDY shares 2,635,065.00 Thursday, 9 August 2012 48042 SELL 158,200 CAL shares -1,001,704.64 Thursday, 9 August 2012 48049 SELL 50,000 PGOLD shares -1,373,039.43 Net Payable Amount (08/14/2012) 1,493,370.43 Monday, 13 August 2012 19 Date Ref. No. Transaction Particulars Amount Monday, 13 August 2012 40463 BUY 10,000,000 BHI shares 1,757,930.32 Monday, 13 August 2012 40465 BUY 500,000 CMT shares 1,181,756.26 Monday, 13 August 2012 40475 BUY 42,000 TDY shares 520,117.57 Monday, 13 August 2012 40476 BUY 127,700 TDY shares 1,591,619.49 Monday, 13 August 2012 40477 BUY 130,300 TDY shares 1,636,413.60 Monday, 13 August 2012 48084 SELL 500,000 CMT shares -1,172,755.88 Net Payable Amount (08/16/2012) 5,515,081.36 Thursday, 16 August 2012 20 Date Ref. No. Transaction Particulars Amount Thursday, 16 August 2012 40551 BUY 200,000,000 GREEN shares 3,520,125.00 Thursday, 16 August 2012 48163 SELL 235,000 TDY shares -2,562,652.12 Thursday, 16 August 2012 48164 SELL 65,000 TDY shares -713,743.87 Net Payable Amount (08/23/2012) 243,729.01 Friday, 24 August 2012 21 Date Ref. No. Transaction Particulars Amount Friday, 24 August 2012 40645 BUY 3,000,000 MEG shares 6,849,157.50 Friday, 24 August 2012 48236 SELL 2,000,000 MEG shares -4,521,871.64 Net Payable Amount (08/30/2012) 2,327,285.86 Tuesday, 28 August 2012 22 Date Ref. No. Transaction Particulars Amount Tuesday, 28 August 2012 40653 BUY 300,000 AGI shares 3,427,596.00 Tuesday, 28 August 2012 40665 BUY 1,000,000 MEG shares 2,293,110.00 Tuesday, 28 August 2012 40671 BUY 116,000 TDY shares 1,506,693.96 Tuesday, 28 August 2012 40672 BUY 184,000 TDY shares 2,401,710.89 Tuesday, 28 August 2012 48252 SELL 300,000 AGI shares -3,424,783.50 Tuesday, 28 August 2012 48261 SELL 2,000,000 MEG shares -4,471,410.00 Tuesday, 28 August 2012 48266 SELL 100,000 PCOR shares -1,005,078.00 Net Payable Amount (08/31/2012) 727,839.35 Friday, 31 August 2012 23 Date Ref. No. Transaction Particulars Amount Friday, 31 August 2012 40705 BUY 3,000,000 ABA shares 2,363,512.50 Net Payable Amount (09/05/2012) 2,363,512.50 Tuesday, 4 September 2012 24 Date Ref. No. Transaction Particulars Amount Tuesday, 4 September 2012 40739 BUY 500,000 CMT shares 1,216,957.50 Tuesday, 4 September 2012 22308 CM Cash Dividend -192.5 Net Payable Amount (09/07/2012) 1,216,765.00 Friday, 14 September 2012 25 Date Ref. No. Transaction Particulars Amount Friday, 14 September 2012 46684 C /V Partial Payment of Net Credit Balance 200,000.00 Friday, 14 September 2012 40871 BUY 2,000,000 MEG shares 4,505,760.00 Friday, 14 September 2012 40878 BUY 200,000 PX shares 3,198,285.00 Friday, 14 September 2012 48559 SELL 2,000,000 MEG shares -4,431,840.00 Due Clearing (09/19/2012) 3,472,205.00 Cr. as of Settlement Date (09/19/2012) -882,406.31 Net Payable Amount (09/19/2012) 2,589,798.69 Monday, 17 September 2012 26 Date Ref. No. Transaction Particulars Amount Monday, 17 September 2012 40888 BUY 2,000,000 CYBR shares 1,810,350.00 Net Payable Amount (09/20/2012) 1,810,350.00 Thursday, 20 September 2012 27 Date Ref. No. Transaction Particulars Amount Thursday, 20 September 2012 40918 BUY 1,500,000 CMT shares 3,922,425.00 Thursday, 20 September 2012 48621 SELL 48,000 CMT shares -121,084.20 Thursday, 20 September 2012 48626 SELL 100,000 PX shares -1,566,972.00 Net Payable Amount (09/25/2012) 2,234,368.80 Friday, 21 September 2012 28 Date Ref. No. Transaction Particulars Amount Friday, 21 September 2012 40939 Buy 200,000 PX shares 2,989,089.00 Friday, 21 September 2012 48641 SELL 200,000 PX shares -2,948,376.53 Net Payable Amount (09/26/2012) 40,712,47 Tuesday, 25 September 2012 29 Date Ref. No. Transaction Particulars Amount Tuesday, 25 September 2012 40973 BUY 3,000,000 PHES shares 2,283,052.50 Tuesday, 25 September 2012 48697 SELL 1,000,000 PHES shares -732,045.00 Net Payable Amount (09/28/2012) 1,551,007.50 Monday, 1 October 2012 30 Date Ref. No. Transaction Particulars Amount Monday, 1 October 2012 41038 BUY 600,500 BLOOM shares 6,927,404.85 Monday, 1 October 2012 48769 SELL 513,400 BLOOM shares -5,692,793.44 Monday, 1 October 2012 48770 SELL 86,600 BLOOM shares -964,997.55 Net Payable Amount (10/04/2012) 269,613.86 Thursday, 4 October 2012 31 Date Ref. No. Transaction Particulars Amount Thursday, 4 October 2012 41088 BUY 1,296,000 CMT shares 3,150,451.52 Thursday, 4 October 2012 41093 BUY 50,000,000 MA shares 2,564,662.50 Thursday, 4 October 2012 41094 BUY 20,000,000 MAB shares 1,025,865.00 Thursday, 4 October 2012 48835 SELL 200,000,000 APM shares -5,638,725.00 Net Payable Amount (10/09/2012) 1,102,254.02 Friday, 5 October 2012 32 Date Ref. No. Transaction Particulars Amount Friday, 5 October 2012 41113 BUY 140,000,000 APM shares 4,646,565.00 Friday, 5 October 2012 41118 BUY 175,500 LR shares 1,568,291.14 Friday, 5 October 2012 41119 BUY 24,500 LR shares 219,303.79 Friday, 5 October 2012 41130 BUY 11,070,000 SFI shares 2,260,423.14 Friday, 5 October 2012 48874 SELL 140,000,000 APM shares -4,985,820.00 Friday, 5 October 2012 48880 SELL 100,000 CMT shares -239,398.50 Friday, 5 October 2012 48881 SELL 1,975,000 CYBR shares -1,682,516.40 Friday, 5 October 2012 48896 SELL 200,000 LR shares 1,733,782.30 Net Payable Amount (10/10/2012) 53,065.87 Wednesday, 10 October 2012 33 Date Ref. No. Transaction Particulars Amount Wednesday, 10 October 2012 41195 BUY 100,000,000 APM shares 6,436,960.93 Wednesday, 10 October 2012 48990 SELL 1,000,000 CMT shares -2,423,662.49 Net Payable Amount (10/15/2012) 4,013,298.44 Tuesday, 16 October 2012 34 Date Ref. No. Transaction Particulars Amount Tuesday, 16 October 2012 46856 C/V Partial Payment of Net Credit Balance 200,000.00 Tuesday, 16 October 2012 41287 BUY 560,000 CLOUD shares 1,688,895.63 Tuesday, 16 October 2012 41288 BUY 40,000 CLOUD shares 124,713.00 Tuesday, 16 October 2012 41298 BUY 90,000,000 EG shares 4,877,887.51 Tuesday, 16 October 2012 41300 BUY 300,000,000 GREEN shares 6,336,225.00 Tuesday, 16 October 2012 49106 SELL 40,000,000 EG shares -2,136,760.00 Tuesday, 16 October 2012 49108 SELL 215,800,000 GREEN shares 4,483,083.15 Tuesday, 16 October 2012 49110 SELL 3,640,000 MAB shares -194,446.97 Due Clearing (10/19/2012) 6,413,411.02 Cr. as of Settlement Date (10/19/2012) -838,764.81 Net Payable Amount (10/19/2012) 5,574,646.21 Thursday, 18 October 2012 35 Date Ref. No. Transaction Particulars Amount Thursday, 18 October 2012 41349 BUY 20,000,000 APM shares 2,896,560.00 Thursday, 18 October 2012 41373 BUY 7,000 YEHEY shares 17,614.62 Thursday, 18 October 2012 49155 SELL 600,000 CMT shares -1,477,939.50 Thursday, 18 October 2012 49181 SELL 7,000 YEHEY shares -20,081.77 Net Payable Amount (10/23/2012) 1,416,153.35 Monday, 29 October 2012 36 Date Ref. No. Transaction Particulars Amount Monday, 29 October 2012 41542 BUY 1,000,000 VITA shares 1,850,580.00 Monday, 29 October 2012 49368 SELL 10,380,000 APM shares -1,663,483.22 Net Payable Amount (11/05/2012) 187,096.78 Monday, 5 November 2012 37 Date Ref. No. Transaction Particulars Amount Monday, 5 November 2012 41595 BUY 49,030,000 APM shares 6,176,924.26 Monday, 5 November 2012 41596 BUY 60,970,000 APM shares 8,071,274.50 Monday, 5 November 2012 41601 BUY 71,000,000 GREEN shares 1,499,573.25 Monday, 5 November 2012 49460 SELL 79,600,000 APM shares -10,203,065.14 Monday, 5 November 2012 49473 SELL 200,000,000 GREEN shares -4,352,700.00 Net Payable Amount (11/08/2012) 1,192,006.87 Tuesday, 6 November 2012 38 Date Ref. No. Transaction Particulars Amount Tuesday, 6 November 2012 41627 BUY 200,000,000 GREEN shares 4,626,450.00 Tuesday, 6 November 2012 41637 BUY 1,000,000 VITA shares 1,478,452.51 Tuesday, 6 November 2012 49509 SELL 200,000,000 GREEN shares -4,748,400.00 Net Payable Amount (11/09/2012) 1,356,502.51 Thursday, 8 November 2012 39 Date Ref. No. Transaction Particulars Amount Thursday, 8 November 2012 41682 BUY 10,000,000 BHI shares 1,659,487.50 Thursday, 8 November 2012 41710 BUY 80,000,000 APM shares 8,522,936.71 Thursday, 8 November 2012 49565 SELL 30,000,000 APM shares -3,462,375.00 Thursday, 8 November 2012 49576 SELL 104,800,000 GREEN shares -2,384,488.20 Net Payable Amount (11/13/2012) 4,335,561.01 Friday, 9 November 2012 40 Date Ref. No. Transaction Particulars Amount Friday, 9 November 2012 41723 BUY 20,000,000 APM shares 2,574,720.00 Friday, 9 November 2012 41727 BUY 100,000,000 GREEN shares 2,413,800.00 Friday, 9 November 2012 41753 BUY 1,000,000 VUL shares 2,004,228.42 Friday, 9 November 2012 49617 SELL 50,000,000 APM shares 6,380,662.50 Net Payable Amount (11/14/2012) 612,085.92 Wednesday, 14 November 2012 41 Date Ref. No. Transaction Particulars Amount Wednesday, 14 November 2012 41806 BUY 30,000,000 APM shares 4,103,460.00 Wednesday, 14 November 2012 41867 BUY 300,000 VUL shares 509,915.25 Wednesday, 14 November 2012 49722 SELL 19,580,000 APM shares -2,614,884.53 Net Payable Amount (11/19/2012) 1,998,490.72 Thursday, 15 November 2012 42 Date Ref. No. Transaction Particulars Amount Thursday, 15 November 2012 41841 BUY 30,000,000 APM shares 3,982,770.00 Thursday, 15 November 2012 49738 SELL 30,000,000 APM shares -3,800,045.59 Thursday, 15 November 2012 49794 SELL 2,000,000 PHES shares -1,602,585.00 Net Payable Amount (11/20/2012) 182,724.41 Monday, 19 November 2012 43 Date Ref. No. Transaction Particulars Amount Monday, 19 November 2012 41898 BUY 100,000,000 GREEN shares 2,514,375.00 Monday, 19 November 2012 49823 SELL 276,000 VUL shares -395,897.85 Net Payable Amount (11/22/2012) 2,118,477.15 Tuesday, 27 November 2012 44 Date Ref. No. Transaction Particulars Amount Tuesday, 27 November 2012 47087 C/V Partial Payment of Net Credit Balance 191,848.97 Tuesday, 27 November 2012 42034 BUY 83,000,000 GREEN shares 1,919,976.75 Tuesday, 27 November 2012 42051 BUY 569,000 VITA shares 635,221.64 Due Clearing (12/03/2012) 2,747,047.36 Cr. as of Settlement Date (12/03/2012) -412,071.47 Net Payable Amount (12/03/2012) 2,334,975.89 Wednesday, 28 November 2012 45 Date Ref. No. Transaction Particulars Amount Wednesday, 28 November 2012 42090 BUY 111,300 WEB shares 1,578,353.65 Net Payable Amount (12/03/2012) 1,578,353.65 Tuesday, 4 December 2012 46 Date Ref. No. Transaction Particulars Amount Tuesday, 4 December 2012 23218 CM Cash Dividend -18,000.00 Tuesday, 4 December 2012 42116 BUY 45,000 BLOOM shares 634,527.68 Tuesday, 4 December 2012 42122 BUY 17,000,000 GREEN shares 393,248.26 Net Payable Amount (12/07/2012) 1,009,775.94 Friday, 7 December 2012 47 Date Ref. No. Transaction Particulars Amount Friday, 7 December 2012 42193 BUY 200,000,000 GREEN shares 4,626,450.00 Friday, 7 December 2012 50169 SELL 100,000 WEB shares 1,297,896.00 Net Payable Amount (12/12/2012) 3,328,554.00 Tuesday, 11 December 2012 48 Date Ref. No. Transaction Particulars Amount Tuesday, 11 December 2012 42241 BUY 200,000,000 GREEN shares 5,028,750.01 Tuesday, 11 December 2012 50235 SELL 2,552,000 VUL shares -3,788,362.56 Tuesday, 11 December 2012 50236 SELL 25,000 VUL shares -38,086.12 Net Payable Amount (12/14/2012) 1,202,301.33 Monday, 17 December 2012 49 Date Ref. No. Transaction Particulars Amount Monday, 17 December 2012 42359 BUY 1,500,000 PHES shares 1,229,740.58 Due Clearing (12/20/2012) 1,229,740.58 Cr. as of Settlement Date (12/20/2012) -1,210,735.49 Net Payable Amount (12/20/2012) 19,005.09 Tuesday, 18 December 2012 50 Date Ref. No. Transaction Particulars Amount Tuesday, 18 December 2012 42381 BUY 5,000,000 EVER shares 2,058,870.83 Tuesday, 18 December 2012 50342 SELL 20,000 DNL shares -89,032.50 Net Payable Amount (12/21/2012) 1,969,838.33 Thursday, 27 December 2012 51 Date Ref. No. Transaction Particulars Amount Thursday, 27 December 2012 42476 BUY 6,000 CLOUD shares 19,084.84 Thursday, 27 December 2012 42477 BUY 9,000 CLOUD shares 28,865.03 Net Payable Amount (01/03/2013) 47,949.87 Friday, 28 December 2012 52 Date Ref. No. Transaction Particulars Amount Friday, 28 December 2012 42494 BUY 14,000 CAL shares 55,527.45 Friday, 28 December 2012 42495 BUY 24,000 CAL shares 96,109.48 Friday, 28 December 2012 42496 BUY 62,000 CAL shares 249,426.00 Net Payable Amount (01/04/2013) 401,062.93 2013 Tuesday, 8 January 2013 53 Date Ref. No. Transaction Particulars Amount Tuesday, 8 January 2013 42633 BUY 777,000 CPG shares 1,356,796.97 Tuesday, 8 January 2013 42634 BUY 223,000 CPG shares 392,493.94 Net Payable Amount (01/11/2013) 1,749,290.91 Thursday, 10 January 2013 54 Date Ref. No. Transaction Particulars Amount Thursday, 10 January 2013 42694 BUY 500,000 CPG shares 859,041.24 Net Payable Amount (01/15/2013) 859,041.24 Tuesday, 15 January 2013 55 Date Ref. No. Transaction Particulars Amount Tuesday, 15 January 2013 42812 BUY 3,000,000 ZHI shares 2,081,902.50 Net Payable Amount (01/18/2013) 2,081,902.50 Thursday, 17 January 2013 56 Date Ref. No. Transaction Particulars Amount Thursday, 17 January 2013 42872 BUY 1,000,000 ARA shares 1,284,553.96 Thursday, 17 January 2013 42882 BUY 2,000,000 CYBR shares 1,693,612.59 Thursday, 17 January 2013 42904 BUY 2,000,000 ZHI shares 1,408,050.00 Thursday, 17 January 2013 50837 SELL 20,000 ARA shares -25,918.35 Net Payable Amount (01/22/2013) 4,360,298.20 Tuesday, 5 February 2013 57 Date Ref. No. Transaction Particulars Amount Tuesday, 5 February 2013 43315 BUY 300,000 CHI shares 1,504,420.97 Tuesday, 5 February 2013 43350 BUY 2,000,000 TA shares 3,691,102.50 Due Clearing (02/08/2013) 5,195,523.47 Cr. as of Settlement Date (02/08/2013) -217,442.96 Net Payable Amount (02/08/2013) 4,978,080.51 Wednesday, 13 February 2013 58 Date Ref. No. Transaction Particulars Amount Wednesday, 13 February 2013 43555 BUY 2,000,000 EVER shares 764,370.00 Net Payable Amount (02/18/2013) 764,370.00 Monday, 18 February 2013 59 Date Ref. No. Transaction Particulars Amount Monday, 18 February 2013 43641 BUY 500,000 DNL shares 3,416,170,67 Monday, 18 February 2013 43681 BUY 2,000,000 TA shares 3,942,670.76 Due Clearing (02/21/2013) 7,358,841.43 Cr. as of Settlement Date (02/21/2013) -901,559.73 Net Payable Amount (02/21/2013) 6,457,281.70 Thursday, 21 February 2013 60 Date Ref. No. Transaction Particulars Amount Thursday, 21 February 2013 43800 BUY 2,000,000 TA shares 3,862,080.00 Net Payable Amount (02/27/2013) 3,862,080.00 Thursday, 28 February 2013 61 Date Ref. No. Transaction Particulars Amount Thursday, 28 February 2013 43987 BUY 700,000 BEL shares 4,083,345.00 Thursday, 28 February 2013 51944 SELL 1,000,000 SLI shares -842,850.88 Due Clearing (03/05/2013) 3,240,494.12 Cr. as of Settlement Date (03/05/2013) -1,112,393.49 Net Payable Amount (03/05/2013) 2,128,100.63 Monday, 4 March 2013 62 Date Ref. No. Transaction Particulars Amount Monday, 4 March 2013 44097 BUY 1,000,000 SLI shares 1,257,187.50 Monday, 4 March 2013 44111 BUY 2,000,000 TA shares 4,721,050.85 Monday, 4 March 2013 52046 SELL 1,000,000 SLI shares 1,167,315.00 Net Payable Amount (03/07/2013) 4,810,923.35 Tuesday, 5 March 2013 63 Date Ref. No. Transaction Particulars Amount Tuesday, 5 March 2013 44139 BUY 300,000 BLOOM shares 4,820,805.15 Tuesday, 5 March 2013 52061 SELL 650,000 BEL shares -3,934,257.14 Tuesday, 5 March 2013 52062 SELL 50,000 BEL shares -303,699.74 Net Payable Amount (03/08/2013) 582,848.27 Wednesday, 6 March 2013 64 Date Ref. No. Transaction Particulars Amount Wednesday, 6 March 2013 44204 BUY 2,000,000 SLI shares 2,604,892.50 Wednesday, 6 March 2013 52152 SELL 56,500,000 GREEN shares 1,061,959.88 Net Payable Amount (03/11/2013) 1,542,932.62 Friday, 8 March 2013 65 Date Ref. No. Transaction Particulars Amount Friday, 8 March 2013 44310 BUY 2,000,000 TA shares 5,329,881.62 Friday, 8 March 2013 52263 SELL 100,000,000 GREEN shares -1,978,500.00 Net Payable Amount (03/13/2013) 3,351,381.62 Tuesday, 12 March 2013 66 Date Ref. No. Transaction Particulars Amount Tuesday, 12 March 2013 44403 BUY 1,000,000 TA shares 2,423,857.50 Net Payable Amount (03/15/2013) 2,423,857.50 Tuesday, 19 March 2013 67 Date Ref. No. Transaction Particulars Amount Tuesday, 19 March 2013 44565 BUY 2,000,000 TA shares 4,547,257.26 Tuesday, 19 March 2013 52455 SELL 107,900 MMI shares -732,120.17 Tuesday, 19 March 2013 52456 SELL 92,100 MMI shares -659,635.86 Net Payable Amount (03/22/2013) 3,155,501.23 Wednesday, 20 March 2013 68 Date Ref. No. Transaction Particulars Amount Wednesday, 20 March 2013 44593 BUY 150,000 MMI shares 1,156,612.51 Wednesday, 20 March 2013 44597 BUY 6,000 PRIM shares 11,533.71 Wednesday, 20 March 2013 44598 BUY 1,000 PRIM shares 2,032.29 Wednesday, 20 March 2013 52490 SELL 150,000 MMI shares -1,135,179.20 Net Payable Amount (03/25/2013) 34,999.31 Wednesday, 27 March 2013 69 Date Ref. No. Transaction Particulars Amount Wednesday, 27 March 2013 44812 BUY 20,000,000 BHI shares 2,755,755.00 Wednesday, 27 March 2013 52660 SELL 100,000 BLOOM shares -1,484,950.00 Net Payable Amount (04/03/2013) 1,370,805.00 Friday, 5 April 2013 70 Date Ref. No. Transaction Particulars Amount Friday, 5 April 2013 45018 BUY 1,000,000 MED shares 543,105.00 Friday, 5 April 2013 45030 BUY 110,000 T shares 289,857.15 Friday, 5 April 2013 45031 BUY 65,000 T shares 175,251.94 Friday, 5 April 2013 45032 BUY 100,000 T shares 275,575.50 Net Payable Amount (04/11/2013) 1,283,789.59 Monday, 8 April 2013 71 Date Ref. No. Transaction Particulars Amount Monday, 8 April 2013 45049 BUY 200,000 T shares 522,869.32 Net Payable Amount (04/12/2013) 522,869.32 Monday, 15 April 2013 72 Date Ref. No. Transaction Particulars Amount Monday, 15 April 2013 45507 BUY 700,000 MPI shares 4,212,757.88 Monday, 15 April 2013 45508 BUY 778,000 TA shares 1,885,761.13 Monday, 15 April 2013 45509 BUY 1,222,000 TA shares 2,949,663.60 Due Clearing (04/18/2013) 9,048,182.61 Cr. as of Settlement Date (04/18/2013) -1,484,565.77 Net Payable Amount (04/18/2013) 7,563,616.84 Tuesday, 16 April 2013 73 Date Ref. No. Transaction Particulars Amount Tuesday, 16 April 2013 45297 BUY 500,000 MPI shares 2,831,186.25 Tuesday, 16 April 2013 45310 BUY 2,000,000 TA shares 4,666,680.00 Tuesday, 16 April 2013 53057 SELL 1,200,000 MPI shares 6,529,050,00 Net Payable Amount (04/19/2013) 968,816.25 Wednesday, 17 April 2013 74 Date Ref. No. Transaction Particulars Amount Wednesday, 17 April 2013 45313 BUY 44,700 ABS shares 1,910,673.57 Wednesday, 17 April 2013 45359 BUY 916,000 VUL shares 1,631,648.35 Wednesday, 17 April 2013 45360 BUY 1134,000 VUL shares 2,047,978.56 Wednesday, 17 April 2013 53141 SELL 50,000 VUL shares -94,968.00 Net Payable Amount (04/22/2013) 5,495,332.48 Monday, 22 April 2013 75 Date Ref. No. Transaction Particulars Amount Monday, 22 April 2013 45526 BUY 7,000,000 APC shares 6,336,225.00 Monday, 22 April 2013 45578 BUY 50,000 PNB shares 5,431,050.00 Monday, 22 April 2013 53304 SELL 222,000 ACR shares -311,851.18 Monday, 22 April 2013 53347 SELL 2,000,000 TA shares 5,025,390.00 Net Payable Amount (04/25/2013) 6,430,033.82 Wednesday, 24 April 2013 76 Date Ref. No. Transaction Particulars Amount Wednesday, 24 April 2013 45859 BUY 1,000,000 TA shares 2,665,237.50 Wednesday, 24 April 2013 45861 BUY 2,000,000 TA shares 5,431,050.00 Due Clearing (04/29/2013) 8,096,287.50 Cr. as of Settlement Date (04/29/2013) -527,238.94 Net Payable Amount (04/29/2013) 7,569,048.56 Thursday, 25 April 2013 77 Date Ref. No. Transaction Particulars Amount Thursday, 25 April 2013 45864 BUY 2,000,000 SUN shares 1,890,810.00 Thursday, 25 April 2013 53509 SELL 508,000 ACR shares -705,542.99 Net Payable Amount (04/30/2013) 1,185,267.01 Monday, 29 April 2013 78 Date Ref. No. Transaction Particulars Amount Monday, 29 April 2013 45952 BUY 1,000,000 TA shares 2,765,812.50 Net Payable Amount (05/03/2013) 2,765,812.50 Tuesday, 30 April 2013 79 Date Ref. No. Transaction Particulars Amount Tuesday, 30 April 2013 45999 BUY 1,342,000 SLI shares 1,368,051.32 Tuesday, 30 April 2013 46000 BUY 658,000 SLI shares 681,637.00 Tuesday, 30 April 2013 46053 BUY 2,000,000 TA shares 5,732,775.01 Tuesday, 30 April 2013 53691 SELL 2,000,000 SLI shares 1,920,737.70 Net Payable Amount (05/06/2013) 5,861,725.63 Monday, 6 May 2013 80 Date Ref. No. Transaction Particulars Amount Monday, 6 May 2013 46139 BUY 20,100 H2O shares 168,261.98 Monday, 6 May 2013 46140 BUY 121,500 H2O shares 1,063,128.04 Net Payable Amount (05/09/2013) 1,231,390.02 Tuesday, 7 May 2013 81 Date Ref. No. Transaction Particulars Amount Tuesday, 7 May 2013 24712 CM Cash Dividend -144,000.00 Tuesday, 7 May 2013 46228 BUY 1,971,000 TA shares 5,257,920.21 Tuesday, 7 May 2013 46229 BUY 29,000 TA shares 77,875.23 Tuesday, 7 May 2013 46888 BUY 20,000,000 BHI shares 4,002,885.00 Net Payable Amount (05/10/2013) 9,194,680.44 Tuesday, 14 May 2013 82 Date Ref. No. Transaction Particulars Amount Tuesday, 14 May 2013 46549 BUY 2,000,000 TA shares 5,531,625.00 Tuesday, 14 May 2013 54151 SELL 1,295,000 TA shares 3,587,020.49 Net Payable Amount (05/17/2013) 1,944,604.51 Tuesday, 21 May 2013 83 Date Ref. No. Transaction Particulars Amount Tuesday, 21 May 2013 46760 BUY 85400 H2O shares 688,043.65 Tuesday, 21 May 2013 46761 BUY 13,000 H2O shares 105,905.47 Tuesday, 21 May 2013 46791 BUY 1,500,000 VUL shares 3,240,858,41 Tuesday, 21 May 2013 54340 SELL 356,000 TA shares -975,519.22 Net Payable Amount (05/24/2013) 3,059,288.31 Wednesday, 22 May 2013 84 Date Ref. No. Transaction Particulars Amount Wednesday, 22 May 2013 46804 BUY 40,200 H2O shares 332,344.05 Net Payable Amount (05/27/2013) 332,344.05 Friday, 24 May 2013 85 Date Ref. No. Transaction Particulars Amount Friday, 24 May 2013 46902 BUY 2,000,000 MEG shares 8,066,115.00 Friday, 24 May 2013 54435 SELL 644,000 TA shares 1,637,287.88 Friday, 24 May 2013 54464 SELL 1,500,000 VUL shares 2,982,588.75 Net Payable Amount (05/29/2013) 3,446,238.37 Tuesday, 28 May 2013 86 Date Ref. No. Transaction Particulars Amount Tuesday, 28 May 2013 47014 BUY 300,000 MMI shares 600,432.75 Tuesday, 28 May 2013 47037 BUY 4600 H2O shares 33,865.61 Net Payable Amount (05/31/2013) 634,298.36 Friday, 31 May 2013 87 Date Ref. No. Transaction Particulars Amount Friday, 31 May 2013 47234 BUY 4,000,000 LCB shares 3,017,250.00 Net Payable Amount (06/05/2013) 3,017,250.00 Tuesday, 4 June 2013 88 Date Ref. No. Transaction Particulars Amount Tuesday, 4 June 2013 47291 BUY 500,000 COSCO shares 5,310,360.01 Tuesday, 4 June 2013 47298 BUY 3,000,000 MEG shares 11,334,802.51 Tuesday, 4 June 2013 54730 SELL 3,000,000 MEG shares 10,980,675.00 Net Payable Amount (06/07/2013) 5,664,487.52 Monday, 10 June 2013 89 Date Ref. No. Transaction Particulars Amount Monday, 10 June 2013 47425 BUY 150,000 DMPL shares 4,377,526.88 Monday, 10 June 2013 47437 BUY 2,000,000 SUN shares 1,799,739.34 Net Payable Amount (06/14/2013) 6,177,266.22 Monday, 17 June 2013 90 Date Ref. No. Transaction Particulars Amount Monday, 17 June 2013 47591 BUY 1,500,000 MEG shares 5,317,460.59 Due Clearing (06/20/2013) 5,317,460.59 Cr. as of Settlement Date (06/20/2013) -1,197,236.11 Net Payable Amount (06/20/2013) 4,120,224.48 Wednesday, 19 June 2013 91 Date Ref. No. Transaction Particulars Amount Wednesday, 19 June 2013 47637 BUY 1,000,000 TA shares 2,309,101.43 Wednesday, 19 June 2013 55111 SELL 500,000 MEG shares 1,760,865.00 Net Payable Amount (06/24/2013) 548,236.43 Monday, 24 June 2013 92 Date Ref. No. Transaction Particulars Amount Monday, 24 June 2013 47734 BUY 300,000 MCP shares 2,715,525.00 Net Payable Amount (06/27/2013) 2,715,525.00 Tuesday, 25 June 2013 93 Date Ref. No. Transaction Particulars Amount Tuesday, 25 June 2013 47760 BUY 100,000 MCP shares 824,715.00 Net Payable Amount (06/28/2013) 824,715.00 Wednesday, 26 June 2013 94 Date Ref. No. Transaction Particulars Amount Wednesday, 26 June 2013 47795 BUY 734,000 CYBR shares 443,334.59 Net Payable Amount (07/01/2013) 443,334.59 Friday, 28 June 2013 95 Date Ref. No. Transaction Particulars Amount Friday, 28 June 2013 47879 BUY 3,000,000 MEG shares 10,047,442.50 Friday, 28 June 2013 55405 SELL 200,000 PGOLD shares -7,125,399.57 Net Payable Amount (07/03/2013) 2,922,042.93 Wednesday, 3 July 2013 96 Date Ref. No. Transaction Particulars Amount Wednesday, 3 July 2013 48005 BUY 500,000 CYBR shares 357,041.25 Wednesday, 3 July 2013 48073 BUY 3,000,000 MEG shares 9,685,372.50 Wednesday, 3 July 2013 55520 SELL 135,000 MCP shares -1,282,068.00 Wednesday, 3 July 2013 55528 SELL 69,500 PGOLD shares -2,512,917.57 Wednesday, 3 July 2013 55533 SELL 146,000 TA shares -324,968.62 Due Clearing (07/08/2013) 5,922,459.56 Cr. as of Settlement Date (07/08/2013) -640,589.52 Net Payable Amount (07/08/2013) 5,281,870.04 Thursday, 4 July 2013 97 Date Ref. No. Transaction Particulars Amount Thursday, 4 July 2013 48017 BUY 1,000,000 CYBR shares 764,370.00 Thursday, 4 July 2013 48022 BUY 4,000,000 LC shares 2,312,520.97 Thursday, 4 July 2013 48037 BUY 72,600 MCP shares 733,964.17 Thursday, 4 July 2013 48038 BUY 109,400 MCP shares 1,122,919.88 Thursday, 4 July 2013 48039 BUY 47,300 MCP shares 488,903.13 Thursday, 4 July 2013 48040 BUY 15,700 MCP shares 164,037.83 Thursday, 4 July 2013 48076 BUY 1,000,000 MMI shares 1,196,842,51 Thursday, 4 July 2013 55556 SELL 145,000 MCP shares -1,389,797.31 Net Payable Amount (07/09/2013) 5,393,761.18 Thursday, 11 July 2013 98 Date Ref. No. Transaction Particulars Amount Thursday, 11 July 2013 48274 BUY 390500 COSCO shares 4,023,022.10 Thursday, 11 July 2013 48275 BUY 609,500 COSCO shares 6,311,489.58 Thursday, 11 July 2013 48276 BUY 5,000,000 LC shares 2,609,921.25 Due Clearing (07/16/2013) 12,944,432.93 Cr. as of Settlement Date (07/16/2013) -8,289,666.33 Net Payable Amount (07/16/2013) 4,654,766.60 Friday, 12 July 2013 99 Date Ref. No. Transaction Particulars Amount Friday, 12 July 2013 48283 BUY 500,000 BLOOM shares 5,257,793.49 Net Payable Amount (07/17/2013) 5,257,793.49 Wednesday, 17 July 2013 100 Date Ref. No. Transaction Particulars Amount Wednesday, 17 July 2013 48514 BUY 1,000,000 LC shares 522,990.00 Net Payable Amount (07/22/2013) 522,990.00 Thursday, 18 July 2013 101 Date Ref. No. Transaction Particulars Amount Thursday, 18 July 2013 48587 BUY 2,000,000 TA shares 4,928,175.00 Net Payable Amount (07/23/2013) 4,928,175.00 Tuesday, 23 July 2013 102 Date Ref. No. Transaction Particulars Amount Tuesday, 23 July 2013 48758 BUY 400,000 SMPH shares 7,442,501.74 Tuesday, 23 July 2013 48776 BUY 419,000 TA shares 1,131,046.32 Tuesday, 23 July 2013 48844 BUY 1,631,000 TA shares 4,429,021.27 Due Clearing (07/26/2013) 13,002,569.33 Cr. as of Settlement Date (07/26/2013) -3,776,117.43 Net Payable Amount (07/26/2013) 9,226,451.90 Thursday, 25 July 2013 103 Date Ref. No. Transaction Particulars Amount Thursday, 25 July 2013 48847 BUY 10,800 ALPHA shares 540,826.99 Thursday, 25 July 2013 48848 BUY 29,200 ALPHA shares 1,468,395.00 Thursday, 25 July 2013 56168 SELL 100,000 MCP shares -1,036,734.00 Net Payable Amount (07/30/2013) 972,487.99 Thursday, 1 August 2013 104 Date Ref. No. Transaction Particulars Amount Thursday, 1 August 2013 49180 BUY 10,000,000 LC shares 6,436,800.01 Thursday, 1 August 2013 48601 C/V Payment of Account 300,000.00 Due Clearing (08/06/2013) 6,736,800.01 Cr. as of Settlement Date (08/06/2013) -4,470,293.00 Net Payable Amount (08/06/2013) 2,266,507.01 Thursday, 8 August 2013 105 Date Ref. No. Transaction Particulars Amount Thursday, 8 August 2013 49293 BUY 100,000 TSI shares 1,158,624.00 Net Payable Amount (08/13/2013) 1,158,624.00 Wednesday, 14 August 2013 106 Date Ref. No. Transaction Particulars Amount Wednesday, 14 August 2013 49367 BUY 50,000 SECB shares 6,739,530.75 Net Payable Amount (08/19/2013) 6,739,530.75 Thursday, 22 August 2013 107 Date Ref. No. Transaction Particulars Amount Thursday, 22 August 2013 49553 BUY 400,000 IRC shares 660,355.32 Thursday, 22 August 2013 49554 BUY 600,000 IRC shares 1,005,448.26 Net Payable Amount (08/28/2013) 1,665,803.58 Friday, 30 August 2013 108 Date Ref. No. Transaction Particulars Amount Friday, 30 August 2013 49821 BUY 777,000 SUN shares 1,410,413.53 Friday, 30 August 2013 49822 BUY 1,786,000 SUN shares 3,311,130.14 Friday, 30 August 2013 56885 SELL 1,000,000 SUN shares -1,638,524.46 Friday, 30 August 2013 56886 SELL 1,000,000 SUN shares -1,671,832.50 Net Payable Amount (09/04/2013) 1,411,186.71 Monday, 2 September 2013 109 Date Ref. No. Transaction Particulars Amount Monday, 2 September 2013 49847 BUY 500,000 SMPH shares 8,146,575.00 Monday, 2 September 2013 56922 SELL 4,703,000 LC shares -2,475,687.16 Net Payable Amount (09/05/2013) 5,670,887.84 Wednesday, 4 September 2013 110 Date Ref. No. Transaction Particulars Amount Wednesday, 4 September 2013 49917 BUY 159,000 SMPH shares 2,558,628.00 Due Clearing (09/09/2013) 2,558,628.00 Cr. as of Settlement Date (09/09/2013) -850,239.07 Net Payable Amount (09/09/2013) 1,708,388.93 Monday, 9 September 2013 111 Date Ref. No. Transaction Particulars Amount Monday, 9 September 2013 49997 BUY 500,000 SMPH shares 8,196,862.50 Monday, 9 September 2013 57107 SELL 359,000 SMPH shares 5,774,588.60 Monday, 9 September 2013 57111 SELL 563,000 SUN shares -843,216.92 Net Payable Amount (09/12/2013) 1,579,056.98 Tuesday, 10 September 2013 112 Date Ref. No. Transaction Particulars Amount Tuesday, 10 September 2013 50039 BUY 100,000 GSMI shares 2,162,493.25 Net Payable Amount (09/13/2013) 2,162,493.25 Monday, 16 September 2013 113 Date Ref. No. Transaction Particulars Amount Monday, 16 September 2013 50236 BUY 100,000 GSMI shares 2,110,536.21 Net Payable Amount (09/19/2013) 2,110,536.21 Tuesday, 17 September 2013 114 Date Ref. No. Transaction Particulars Amount Tuesday, 17 September 2013 50315 BUY 50,800 TSI shares 605,139.65 Tuesday, 17 September 2013 50316 BUY 39,600 TSI shares 476,339.30 Tuesday, 17 September 2013 50317 BUY 111,600 TSI shares 1,351,828.58 Tuesday, 17 September 2013 50318 BUY 198,000 TSI shares 2,988,063.14 Tuesday, 17 September 2013 50319 BUY 500,000 TSI shares 8,277,322.50 Tuesday, 17 September 2013 57302 SELL 9,750,000 LCB shares -4,347,803.21 Tuesday, 17 September 2013 57303 SELL 250,000 LCB shares -116,236.87 Tuesday, 17 September 2013 57314 SELL 491,900 PX shares -4,136,400.47 Tuesday, 17 September 2013 57315 SELL 8,100 PX shares -68,350.24 Net Payable Amount (09/20/2013) 5,029,902.38 Friday, 20 September 2013 115 Date Ref. No. Transaction Particulars Amount Friday, 20 September 2013 50483 BUY 100,000 TSI shares 975,577.50 Friday, 20 September 2013 57548 SELL 26,300,000 MA shares -676,449.15 Net Payable Amount (09/25/2013) 299,128.35 Monday, 23 September 2013 116 Date Ref. No. Transaction Particulars Amount Monday, 23 September 2013 50502 BUY 1,000,000 VITA shares 949,850.41 Monday, 23 September 2013 57590 SELL 2,200,000 MA shares -56,585.10 Net Payable Amount (09/26/2013) 893,265.31 Tuesday, 1 October 2013 117 Date Ref. No. Transaction Particulars Amount Tuesday, 1 October 2013 50692 BUY 100,000 GSMI shares 2,673,484.65 Tuesday, 1 October 2013 57767 SELL 71,500,000 MA shares -1,697,553.00 Net Payable Amount (10/04/2013) 975,931.65 Thursday, 3 October 2013 118 Date Ref. No. Transaction Particulars Amount Thursday, 3 October 2013 50785 BUY 86,900 GSMI shares 2,320,114.39 Net Payable Amount (10/08/2013) 2,320,114.39 Tuesday, 8 October 2013 119 Date Ref. No. Transaction Particulars Amount Tuesday, 8 October 2013 50905 BUY 100,000 PX shares 872,991.00 Net Payable Amount (10/11/2013) 872,991.00 Thursday, 10 October 2013 120 Date Ref. No. Transaction Particulars Amount Thursday, 10 October 2013 51033 BUY 51,600 MCP shares 619,628.51 Thursday, 10 October 2013 51034 BUY 648,400 MCP shares 7,825,135.30 Thursday, 10 October 2013 58057 SELL 20,000,000 BHI shares 3,072,551.13 Net Payable Amount (10/15/2013) 5,372,212.68 Monday, 14 October 2013 121 Date Ref. No. Transaction Particulars Amount Monday, 14 October 2013 51125 BUY 1,000,000 MARC shares 2,614,950.00 Net Payable Amount (10/17/2013) 2,614,950.00 Thursday, 17 October 2013 122 Date Ref. No. Transaction Particulars Amount Thursday, 17 October 2013 51176 BUY 50,000 GSMI shares 1,282,331.25 Net Payable Amount (10/22/2013) 1,282,331.25 Friday, 18 October 2013 123 Date Ref. No. Transaction Particulars Amount Friday, 18 October 2013 51270 BUY 45,000 PRIM shares 70,000.20 Friday, 18 October 2013 51271 BUY 57,000 PRIM shares 90,386.75 Friday, 18 October 2013 51272 BUY 97,000 PRIM shares 165,848.18 Net Payable Amount (10/23/2013) 326,235.13 Monday, 21 October 2013 124 Date Ref. No. Transaction Particulars Amount Monday, 21 October 2013 51284 BUY 246,000 BKD shares 496,277.26 Monday, 21 October 2013 51285 BUY 354,000 BKD shares 765,476.33 Monday, 21 October 2013 51315 BUY 1,500,000 MARC shares 4,974,077.42 Net Payable Amount (10/24/2013) 6,235,831.01 Wednesday, 30 October 2013 125 Date Ref. No. Transaction Particulars Amount Wednesday, 30 October 2013 51581 BUY 1,700,000 TUGS shares 3,382,618.86 Wednesday, 30 October 2013 51585 BUY 300,000 TUGS shares 567,243.00 Net Payable Amount (11/05/2013) 3,949,861.86 Monday, 4 November 2013 126 Date Ref. No. Transaction Particulars Amount Monday, 4 November 2013 51756 BUY 798,000 MARC shares 2,773,838.39 Net Payable Amount (11/07/2013) 2,773,838.39 Friday, 8 November 2013 127 Date Ref. No. Transaction Particulars Amount Friday, 8 November 2013 51870 BUY 512,000 BKD shares 1,197,848.25 Friday, 8 November 2013 51871 BUY 1,988,000 BKD shares 4,997,159.40 Friday, 8 November 2013 51878 BUY 700,000 LTG shares 10,912,387.51 Friday, 8 November 2013 58926 SELL 700,000 TUGS shares -1,177,207.49 Net Payable Amount (11/13/2013) 15,930,187.67 Tuesday, 12 November 2013 128 Date Ref. No. Transaction Particulars Amount Tuesday, 12 November 2013 52018 BUY 65,000 PRIM shares 127,659.86 Tuesday, 12 November 2013 52019 BUY 40,000 PRIM shares 80,057.71 Tuesday, 12 November 2013 52020 BUY 110,000 PRIM shares 225,489.15 Tuesday, 12 November 2013 52021 BUY 185,000 PRIM shares 381,430.69 Net Payable Amount (11/15/2013) 814,637.41 Wednesday, 13 November 2013 129 Date Ref. No. Transaction Particulars Amount Wednesday, 13 November 2013 52076 BUY 78,000 LMG shares 358,650.47 Wednesday, 13 November 2013 52077 BUY 138,000 LMG shares 640,240.35 Wednesday, 13 November 2013 52078 BUY 23,000 LMG shares 109,948.59 Wednesday, 13 November 2013 52079 BUY 96,000 LMG shares 461,699.61 Wednesday, 13 November 2013 52080 BUY 265,000 LMG shares 1,289,371.50 Net Payable Amount (11/18/2013) 2,859,910.52 Tuesday, 3 December 2013 130 Date Ref. No. Transaction Particulars Amount Tuesday, 3 December 2013 27311 CM Cash Dividend -44,100.00 Tuesday, 3 December 2013 52500 BUY 5,500,000 BHI shares 851,870.25 Net Payable Amount (12/06/2013) 807,770.25 Monday, 16 December 2013 131 Date Ref. No. Transaction Particulars Amount Monday, 16 December 2013 49366 C/V Payment of Net Credit Balance 425,733.43 Monday, 16 December 2013 52728 BUY 600,000 SMPH shares 9,351,873.84 Due Clearing (12/19/2013) 9,777,607.27 Cr. as of Settlement Date (12/19/2013) -592,687.93 Net Payable Amount (12/19/2013) 9,184,919.34 Tuesday, 17 December 2013 132 Date Ref. No. Transaction Particulars Amount Tuesday, 17 December 2013 52793 BUY 500,000 SMPH shares 7,533,067.51 Net Payable Amount (12/20/2013) 7,533,067.51 Thursday, 26 December 2013 133 Date Ref. No. Transaction Particulars Amount Thursday, 26 December 2013 52984 BUY 283,000 VMC shares 578,105.11 Thursday, 26 December 2013 52985 BUY 717,000 VMC shares 1,478,301.64 Thursday, 26 December 2013 60013 SELL 5,460,000 BHI shares -762,454.53 Net Payable Amount (01/03/2014) 1,293,952.22 2014 Monday, 6 January 2014 134 Date Ref. No. Transaction Particulars Amount Monday, 6 January 2014 53137 BUY 55,000 PRMX shares 240,786.62 Monday, 6 January 2014 53138 BUY 45,000 PRMX shares 198,917.24 Net Payable Amount (01/09/2014) 439,703.86 Monday, 20 January 2014 135 Date Ref. No. Transaction Particulars Amount Monday, 20 January 2014 53577 BUY 28,000 PRIM shares 55,064.82 Monday, 20 January 2014 53578 BUY 91,000 PRIM shares 182,392.77 Net Payable Amount (01/23/2014) 237,457.59 Tuesday, 21 January 2014 136 Date Ref. No. Transaction Particulars Amount Tuesday, 21 January 2014 53608 BUY 150,000,000 MA shares 2,866,387.50 Tuesday, 21 January 2014 53613 BUY 200,000 NI shares 485,465.47 Tuesday, 21 January 2014 53630 BUY 15,000 PRMX shares 51,283.19 Tuesday, 21 January 2014 53631 BUY 25,000 PRMX shares 86,243.06 Tuesday, 21 January 2014 53632 BUY 13,000 PRMX shares 45,490.08 Tuesday, 21 January 2014 53633 BUY 47,000 PRMX shares 165,445.87 Net Payable Amount (01/24/2014) 3,700,315.17 Wednesday, 22 January 2014 137 Date Ref. No. Transaction Particulars Amount Wednesday, 22 January 2014 53686 BUY 100,000,000 MA shares 1,910,925.00 Net Payable Amount (01/27/2014) 1,910,925.00 Wednesday, 29 January 2014 138 Date Ref. No. Transaction Particulars Amount Wednesday, 29 January 2014 53859 BUY 150,000,000 MA shares 3,017,250.00 Net Payable Amount (02/04/2014) 3,017,250.00 Wednesday, 12 February 2014 139 Date Ref. No. Transaction Particulars Amount Wednesday, 12 February 2014 54183 BUY 150,000,000 MA shares 3,017,250.00 Wednesday, 12 February 2014 61036 SELL 1,000,000 AR shares -5,160.70 Due Clearing (02/17/2014) 3,012,089.30 Cr. as of Settlement Date (02/17/2014) -982,531.95 Net Payable Amount (02/17/2014) 2,029,557.35 Monday, 17 February 2014 140 Date Ref. No. Transaction Particulars Amount Monday, 17 February 2014 54228 BUY 150,000,000 MA shares 2,866,387.50 Net Payable Amount (02/20/2014) 2,866,387.50 Thursday, 20 February 2014 141 Date Ref. No. Transaction Particulars Amount Thursday, 20 February 2014 54343 BUY 122,000 NI shares 354,124.58 Thursday, 20 February 2014 54344 BUY 178,000 NI shares 519,168.14 Thursday, 20 February 2014 54358 BUY 500,000 VMC shares 2,011,007.19 Net Payable Amount (02/26/2014) 2,884,299.91 Friday, 21 February 2014 142 Date Ref. No. Transaction Particulars Amount Friday, 21 February 2014 54423 BUY 500,000 VMC shares 1,959,522.84 Net Payable Amount (02/27/2014) 1,959,522.84 Wednesday, 26 February 2014 143 Date Ref. No. Transaction Particulars Amount Wednesday, 26 February 2014 54533 BUY 1,310,000 LRW shares 1,247,783.74 Wednesday, 26 February 2014 54534 BUY 690,000 LRW shares 684,412.88 Wednesday, 26 February 2014 54547 BUY 300,000 UNI shares 72,414.00 Wednesday, 26 February 2014 61461 SELL 500,000 VMC shares -1,980,478.50 Net Payable Amount (03/03/2014) 24,132.12 Friday, 28 February 2014 144 Date Ref. No. Transaction Particulars Amount Friday, 28 February 2014 54613 BUY 420,000 PHES shares 189,835.31 Friday, 28 February 2014 54614 BUY 80,000 PHES shares 35,402.40 Net Payable Amount (03/05/2014) 225,237.71 Monday, 3 March 2014 145 Date Ref. No. Transaction Particulars Amount Monday, 3 March 2014 54657 BUY 174,000 VMC shares 671,659.95 Monday, 3 March 2014 54658 BUY 326,000 VMC shares 1,262,316.82 Net Payable Amount (03/06/2014) 1,933,976.77 Friday, 7 March 2014 146 Date Ref. No. Transaction Particulars Amount Friday, 7 March 2014 54873 BUY 10,000 SCC shares 4,023,000.00 Friday, 7 March 2014 61748 SELL 150,000,000 MA shares -2,522,587.50 Net Payable Amount (03/12/2014) 1,500,412.50 Monday, 10 March 2014 147 Date Ref. No. Transaction Particulars Amount Monday, 10 March 2014 54889 BUY 15,000,000 BHI shares 2,358,483.76 Net Payable Amount (03/13/2014) 2,358,483.76 Friday, 14 March 2014 148 Date Ref. No. Transaction Particulars Amount Friday, 14 March 2014 54997 BUY 226,000 GERI shares 475,055.95 Net Payable Amount (03/19/2014) 475,055.95 Friday, 21 March 2014 149 Date Ref. No. Transaction Particulars Amount Friday, 21 March 2014 49987 C/V Payment of Net Credit Balance 400,000.00 Friday, 21 March 2014 55215 BUY 500,000 MARC shares 2,036,643.75 Due Clearing (03/26/2014) 2,436,643.75 Cr. as of Settlement Date (03/26/2014) -290,920.81 Net Payable Amount (03/26/2014) 2,145,722.94 Tuesday, 1 April 2014 150 Date Ref. No. Transaction Particulars Amount Tuesday, 1 April 2014 55397 BUY 1,190,000 LRW shares 1,615,737.38 Tuesday, 1 April 2014 62239 SELL 137,000 VMC shares -575,990.81 Net Payable Amount (04/04/2014) 1,039,746.57 Wednesday, 2 April 2014 151 Date Ref. No. Transaction Particulars Amount Wednesday, 2 April 2014 55508 BUY 810,000 LRW shares 1,059,054.75 Net Payable Amount (04/07/2014) 1,059,054.75 Thursday, 3 April 2014 152 Date Ref. No. Transaction Particulars Amount Thursday, 3 April 2014 55558 BUY 500,000 VMC shares 2,360,374.56 Thursday, 3 April 2014 55564 BUY 2,000,000 SLI shares 1,462,400.73 Net Payable Amount (04/08/2014) 3,822,775.29 Friday, 4 April 2014 153 Date Ref. No. Transaction Particulars Amount Friday, 4 April 2014 55608 BUY 500,000 LRW shares 658,766.25 Net Payable Amount (04/10/2014) 658,766.25 Tuesday, 8 April 2014 154 Date Ref. No. Transaction Particulars Amount Tuesday, 8 April 2014 55680 BUY 999,000 DD shares 3,928,550.02 Tuesday, 8 April 2014 55712 BUY 1,001,000 DD shares 4,126,511.80 Tuesday, 8 April 2014 62626 SELL 2,000,000 SLI shares -1,478,780.36 Net Payable Amount (04/14/2014) 6,576,281.46 Monday, 14 April 2014 155 Date Ref. No. Transaction Particulars Amount Monday, 14 April 2014 55851 BUY 600,000 MB shares 1,031,899.51 Monday, 14 April 2014 55852 BUY 400,000 MB shares 772,416.00 Net Payable Amount (04/21/2014) 1,804,315.51 Tuesday, 15 April 2014 156 Date Ref. No. Transaction Particulars Amount Tuesday, 15 April 2014 55995 BUY 483,000 SGI shares 823,809.83 Tuesday, 15 April 2014 56024 BUY 17,000 SGI shares 28,895.19 Net Payable Amount (04/22/2014) 852,705.02 Monday, 21 April 2014 157 Date Ref. No. Transaction Particulars Amount Monday, 21 April 2014 56012 BUY 118,000 MB shares 174,236.12 Monday, 21 April 2014 56013 BUY 382,000 MB shares 576,174.07 Net Payable Amount (04/24/2014) 750,410.19 Wednesday, 30 April 2014 158 Date Ref. No. Transaction Particulars Amount Wednesday, 30 April 2014 56334 BUY 516,000 MARC shares 2,262,696.13 Net Payable Amount (05/06/2014) 2,262,696.13 Monday, 5 May 2014 159 Date Ref. No. Transaction Particulars Amount Monday, 5 May 2014 56413 BUY 200,000 NI shares 629,599.50 Net Payable Amount (05/08/2014) 629,599.50 Tuesday, 6 May 2014 160 Date Ref. No. Transaction Particulars Amount Tuesday, 6 May 2014 56443 BUY 500,000 CNPF shares 7,794,562.50 Tuesday, 6 May 2014 63525 SELL 250,000 CNPF shares -3,759,150.00 Net Payable Amount (05/09/2014) 4,035,412.50 Wednesday, 7 May 2014 161 Date Ref. No. Transaction Particulars Amount Wednesday, 7 May 2014 56516 BUY 2,000,000 TA shares 4,847,151.77 Wednesday, 7 May 2014 63771 SELL 250,000 CNPF shares 3,635,576.84 Net Payable Amount (05/12/2014) 1,211,574.93 Tuesday, 13 May 2014 162 Date Ref. No. Transaction Particulars Amount Tuesday, 13 May 2014 56839 BUY 223,000 BKD shares 657,358.20 Tuesday, 13 May 2014 56840 BUY 682,000 BKD shares 2,051,227.12 Tuesday, 13 May 2014 56841 BUY 66,000 BKD shares 210,905.78 Tuesday, 13 May 2014 56842 BUY 29,000 BKD shares 99,901.14 Tuesday, 13 May 2014 56843 BUY 2,000,000 CPM shares 1,981,327.50 Tuesday, 13 May 2014 56847 BUY 5,000,000 CYBR shares 4,805,775.23 Tuesday, 13 May 2014 63828 SELL 2,500,000 CEI shares -227,527.50 Tuesday, 13 May 2014 63851 SELL 5,000 GTCAP shares -4,377,431.24 Tuesday, 13 May 2014 63854 SELL 205,000 MARC shares -1,011,953.28 Net Payable Amount (05/16/2014) 3,560,419.95 Thursday, 15 May 2014 163 Date Ref. No. Transaction Particulars Amount Thursday, 15 May 2014 56941 BUY 195,000 BKR shares 549,048.99 Thursday, 15 May 2014 56942 BUY 151,000 BKR shares 432,824.52 Net Payable Amount (05/20/2014) 981,873.51 Wednesday, 21 May 2014 164 Date Ref. No. Transaction Particulars Amount Wednesday, 21 May 2014 57238 BUY 5,354,000 PHA shares 2,881,795.58 Wednesday, 21 May 2014 57265 BUY 2,646,000 PHA shares 1,516,892.26 Wednesday, 21 May 2014 64241 SELL 5,000,000 CYBR shares -3,594,370.64 Net Payable Amount (05/26/2014) 804,317.20 Thursday, 22 May 2014 165 Date Ref. No. Transaction Particulars Amount Thursday, 22 May 2014 57305 BUY 1,000,000 PHA shares 482,760.00 Net Payable Amount (05/27/2014) 482,760.00 Thursday, 29 May 2014 166 Date Ref. No. Transaction Particulars Amount Thursday, 29 May 2014 57579 BUY 500,000 HOUSE shares 4,123,575.00 Thursday, 29 May 2014 57587 BUY 500,000 LRW shares 593,392.50 Thursday, 29 May 2014 64546 SELL 250,000 BKR shares -650,431.88 Thursday, 29 May 2014 64561 SELL 361,400 DD shares -3,432,143.52 Net Payable Amount (06/03/2014) 634,392.10 Friday, 30 May 2014 167 Date Ref. No. Transaction Particulars Amount Friday, 30 May 2014 57617 BUY 105,300 DD shares 975,192.31 Friday, 30 May 2014 57618 BUY 394,700 DD shares 3,731,513.54 Friday, 30 May 2014 64634 SELL 500,000 DD shares -4,550,550.00 Net Payable Amount (06/04/2014) 156,155.85 Monday, 2 June 2014 168 Date Ref. No. Transaction Particulars Amount Monday, 2 June 2014 57664 BUY 400,000 DD shares 4,012,318.94 Monday, 2 June 2014 64687 SELL 200,000 HOUSE shares -1,561,036.50 Net Payable Amount (06/05/2014) 2,451,282.44 Thursday, 5 June 2014 169 Date Ref. No. Transaction Particulars Amount Thursday, 5 June 2014 57961 BUY 1,000,000 PHA shares 481,854.93 Thursday, 5 June 2014 57985 BUY 1,465,000 SUN shares 2,333,863.00 Thursday, 5 June 2014 57986 BUY 535,000 SUN shares 897,782.73 Due Clearing (06/10/2014) 3,713,500.56 Cr. as of Settlement Date (06/10/2014) -599,513.73 Net Payable Amount (06/10/2014) 3,113,986.83 Friday, 6 June 2014 170 Date Ref. No. Transaction Particulars Amount Friday, 6 June 2014 58064 BUY 4,130,000 SINO shares 6,415,156.27 Friday, 6 June 2014 58065 BUY 870,000 SINO shares 1,431,976.80 Net Payable Amount (06/11/2014) 7,847,133.07 Tuesday, 10 June 2014 171 Date Ref. No. Transaction Particulars Amount Tuesday, 10 June 2014 58225 BUY 2,000,000 SINO shares 2,655,180.00 Tuesday, 10 June 2014 58239 BUY 2,000,000 VITA shares 1,857,740.94 Tuesday, 10 June 2014 65174 SELL 2,000,000 SINO shares -2,403,877.50 Tuesday, 10 June 2014 65189 SELL 2,000,000 VITA shares -1,685,108.23 Net Payable Amount (06/16/2014) 423,935.21 Tuesday, 17 June 2014 172 Date Ref. No. Transaction Particulars Amount Tuesday, 17 June 2014 58464 BUY 15,500 IMI shares 84,628.85 Tuesday, 17 June 2014 58465 BUY 198,900 IMI shares 1,091,133.16 Tuesday, 17 June 2014 58466 BUY 103,400 IMI shares 585,849.36 Tuesday, 17 June 2014 58467 BUY 88,000 IMI shares 504,413.79 Net Payable Amount (06/20/2014) 2,266,025.16 Tuesday, 24 June 2014 173 Date Ref. No. Transaction Particulars Amount Tuesday, 24 June 2014 58776 BUY 300,000 IMI shares 1,810,153.88 Tuesday, 24 June 2014 58804 BUY 2,000,000 NOW shares 1,609,200.00 Due Clearing (06/27/2014) 3,419,353.88 Cr. as of Settlement Date (06/27/2014) -443,920.29 Net Payable Amount (06/27/2014) 2,975,433.59 Wednesday, 25 June 2014 174 Date Ref. No. Transaction Particulars Amount Wednesday, 25 June 2014 58824 BUY 1,100,000 COAL shares 1,766,469.13 Net Payable Amount (06/30/2014) 1,766,469.13 Thursday, 26 June 2014 175 Date Ref. No. Transaction Particulars Amount Thursday, 26 June 2014 58907 BUY 3,000,000 SINO shares 4,525,875.00 Net Payable Amount (07/01/2014) 4,525,875.00 Thursday, 3 July 2014 176 Date Ref. No. Transaction Particulars Amount Thursday, 3 July 2014 59134 BUY 800,000 APX shares 4,125,586.50 Thursday, 3 July 2014 59145 BUY 129,000 BRN shares 214,777.92 Thursday, 3 July 2014 59146 BUY 233,000 BRN shares 396,305.73 Thursday, 3 July 2014 59147 BUY 138,000 BRN shares 238,543.78 Thursday, 3 July 2014 66038 SELL 200,000 APX shares -920,002.50 Thursday, 3 July 2014 66069 SELL 74,000 DAVIN shares -256,947.80 Net Payable Amount (07/08/2014) 3,798,263.63 Monday, 7 July 2014 177 Date Ref. No. Transaction Particulars Amount Monday, 7 July 2014 59207 BUY 51,000 ATN shares 110,350.90 Monday, 7 July 2014 59208 BUY 48,000 ATN shares 112,402.62 Monday, 7 July 2014 59209 BUY 501,000 ATN shares 1,189,158.57 Due Clearing (07/10/2014) 1,411,912.09 Cr. as of Settlement Date (07/10/2014) -460,686.33 Net Payable Amount (07/10/2014) 951,225.76 Tuesday, 8 July 2014 178 Date Ref. No. Transaction Particulars Amount Tuesday, 8 July 2014 59264 BUY 1,000,000 OM shares 704,025.00 Net Payable Amount (07/11/2014) 704,025.00 Wednesday, 9 July 2014 179 Date Ref. No. Transaction Particulars Amount Wednesday, 9 July 2014 59326 BUY 3,313,000 ION shares 2,954,410.74 Wednesday, 9 July 2014 59327 BUY 861,000 ION shares 805,334.20 Wednesday, 9 July 2014 59365 BUY 2,000,000 VITA shares 2,505,715.50 Wednesday, 9 July 2014 66247 SELL 100,000 ATN shares -198,008.27 Wednesday, 9 July 2014 66259 SELL 1,824,000 ION shares -1,647,378.24 Wednesday, 9 July 2014 66282 SELL 2,000,000 VITA shares -2,092,797.96 Net Payable Amount (07/14/2014) 2,327,275.97 Tuesday, 15 July 2014 180 Date Ref. No. Transaction Particulars Amount Tuesday, 15 July 2014 59489 BUY 2,000,000 PHA shares 979,349.06 Net Payable Amount (07/18/2014) 979,349.06 Monday, 21 July 2014 181 Date Ref. No. Transaction Particulars Amount Monday, 21 July 2014 59535 BUY 19,000 APX shares 85,418.33 Monday, 21 July 2014 59536 BUY 31,000 APX shares 140,251.84 Monday, 21 July 2014 59541 BUY 330,000 PX shares 4,055,787.45 Net Payable Amount (07/24/2014) 4,281,457.62 Wednesday, 23 July 2014 182 Date Ref. No. Transaction Particulars Amount Wednesday, 23 July 2014 29952 CM Cash Dividend -173.25 Wednesday, 23 July 2014 59603 BUY 201,100 PXP shares 1,638,132.42 Wednesday, 23 July 2014 59604 BUY 31,300 PXP shares 256,359.65 Wednesday, 23 July 2014 59605 BUY 17,600 PXP shares 144,624.85 Wednesday, 23 July 2014 66534 SELL 3,000,000 PHA shares -1,399,788.74 Net Payable Amount (07/28/2014) 639,154.93 Monday, 28 July 2014 183 Date Ref. No. Transaction Particulars Amount Monday, 28 July 2014 59679 BUY 20,000 SCC shares 7,040,250.00 Monday, 28 July 2014 66577 SELL 100,000 ATN shares -267,097.50 Net Payable Amount (07/31/2014) 6,773,152.50 Tuesday, 5 August 2014 184 Date Ref. No. Transaction Particulars Amount Tuesday, 5 August 2014 59858 BUY 5,000,000 APC shares 4,727,025.00 Tuesday, 5 August 2014 59860 BUY 70,000 ATN shares 200,647.13 Due Clearing (08/08/2014) 4,927,672.13 Cr. as of Settlement Date (08/08/2014) -736,010.34 Net Payable Amount (08/08/2014) 4,191,661.79 Wednesday, 6 August 2014 185 Date Ref. No. Transaction Particulars Amount Wednesday, 6 August 2014 59904 BUY 103,100 PERC shares 740,463.33 Wednesday, 6 August 2014 59914 BUY 600,000 SUN shares 813,098.59 Net Payable Amount (08/11/2014) 1,553,561.92 Monday, 11 August 2014 186 Date Ref. No. Transaction Particulars Amount Monday, 11 August 2014 60024 BUY 531,000 COAL shares 677,342.46 Monday, 11 August 2014 60025 BUY 969000 COAL shares 1,289,019.50 Due Clearing (08/14/2014) 1,966,361,96 Cr. as of Settlement Date (08/14/2014) -851,895.78 Net Payable Amount (08/14/2014) 1,114,466.18 Tuesday, 12 August 2014 187 Date Ref. No. Transaction Particulars Amount Tuesday, 12 August 2014 60074 BUY 9,470,000 CEI shares 1,536,454.11 Tuesday, 12 August 2014 60112 BUY 1,000,000 VUL shares 1,910,925.00 Net Payable Amount (08/15/2014) 3,447,379.11 Wednesday, 13 August 2014 188 Date Ref. No. Transaction Particulars Amount Wednesday, 13 August 2014 60138 BUY 20,000,000 CEI shares 3,356,238.04 Wednesday, 13 August 2014 60164 BUY 2,000,000 VUL shares 4,204,035.00 Wednesday, 13 August 2014 67118 SELL 1,000,000 VUL shares -1,929,314.49 Net Payable Amount (08/18/2014) 5,630,958.55 Tuesday, 19 August 2014 189 Date Ref. No. Transaction Particulars Amount Tuesday, 19 August 2014 60305 BUY 2,960,000 CEI shares 419,588.83 Tuesday, 19 August 2014 60306 BUY 3,750,000 CEI shares 546,876.56 Net Payable Amount (08/26/2014) 966,465.39 Wednesday, 20 August 2014 190 Date Ref. No. Transaction Particulars Amount Wednesday, 20 August 2014 60353 BUY 13,290,000 CEI shares 1,967,860.52 Wednesday, 20 August 2014 60384 BUY 569,000 VUL shares 1,054,901.00 Wednesday, 20 August 2014 60385 BUY 182,000 VUL shares 343,745.23 Wednesday, 20 August 2014 60386 BUY 249,000 VUL shares 475,518.60 Wednesday, 20 August 2014 67348 SELL 1,000,000 COAL shares -1,184,963.22 Net Payable Amount (08/27/2014) 2,657,062.13 Tuesday, 26 August 2014 191 Date Ref. No. Transaction Particulars Amount Tuesday, 26 August 2014 60434 BUY 5,000,000 CEI shares 704,025.00 Net Payable Amount (08/29/2014) 704,025.00 Tuesday, 2 September 2014 192 Date Ref. No. Transaction Particulars Amount Tuesday, 2 September 2014 60689 BUY 9,490,000 CEI shares 1,547,296.10 Tuesday, 2 September 2014 60690 BUY 10,510,000 CEI shares 1,733,550.92 Tuesday, 2 September 2014 60714 BUY 18,000,000 IS shares 4,495,199.62 Due Clearing (09/05/2014) 7,776,046.64 Cr. as of Settlement Date (09/05/2014) -404,931.49 Net Payable Amount (09/05/2014) 7,371,115.15 Wednesday, 3 September 2014 193 Date Ref. No. Transaction Particulars Amount Wednesday, 3 September 2014 60808 BUY 20,000,000 MRC shares 3,459,780.00 Wednesday, 3 September 2014 67804 SELL 3,000,000 IS shares -644,001.75 Net Payable Amount (09/08/2014) 2,815,778.25 Thursday, 11 September 2014 194 Date Ref. No. Transaction Particulars Amount Thursday, 11 September 2014 61128 BUY 1,000,000 CMT shares 2,987,077.50 Thursday, 11 September 2014 61138 BUY 1,000,000 MED shares 784,485.00 Thursday, 11 September 2014 68142 SELL 100,000 MED shares -79,140.00 Net Payable Amount (09/16/2014) 3,692,422.50 Friday, 12 September 2014 195 Date Ref. No. Transaction Particulars Amount Friday, 12 September 2014 61185 BUY 2,700,000 EG shares 38,017.35 Friday, 12 September 2014 61210 BUY 218,000 MAC shares 602,927.01 Friday, 12 September 2014 61211 BUY 39,000 MAC shares 108,912.66 Friday, 12 September 2014 61212 BUY 483,000 MAC shares 1,387,130.41 Friday, 12 September 2014 61213 BUY 300,000 MAC shares 908,423.58 Friday, 12 September 2014 61214 BUY 264,000 MAC shares 823,105.80 Friday, 12 September 2014 61230 BUY 2,000,000 PHES shares 833,766.76 Friday, 12 September 2014 61296 BUY 100,000 MED shares 74,425.50 Friday, 12 September 2014 68199 SELL 535,000 LRW shares -561,003.67 Net Payable Amount (09/17/2014) 4,215,705.40 Tuesday, 16 September 2014 196 Date Ref. No. Transaction Particulars Amount Tuesday, 16 September 2014 61317 BUY 11,150,000 CEI shares 1,937,406.40 Tuesday, 16 September 2014 61318 BUY 3,850,000 CEI shares 677,624.07 Tuesday, 16 September 2014 61357 BUY 26,000 TAPET shares 152,572.28 Tuesday, 16 September 2014 61358 BUY 174,000 TAPET shares 1,030,270.18 Tuesday, 16 September 2014 68300 SELL 10,050,000 IS shares -1,992,606.68 Tuesday, 16 September 2014 68301 SELL 1,450,000 IS shares -291,433.04 Tuesday, 16 September 2014 68307 SELL 266,000 LRW shares -372,017.35 Tuesday, 16 September 2014 68308 SELL 594,000 LRW shares -856,245.34 Tuesday, 16 September 2014 68309 SELL 40,000 LRW shares -60,146.40 Net Payable Amount (09/19/2014) 225,424.12 Thursday, 18 September 2014 197 Date Ref. No. Transaction Particulars Amount Thursday, 18 September 2014 61434 BUY 2,000,000 CPM shares 2,102,017.51 Thursday, 18 September 2014 61453 BUY 2,000,000 PHES shares 772,617.15 Thursday, 18 September 2014 68419 SELL 3,290,000 PHES shares -1,176,613.96 Net Payable Amount (09/23/2014) 1,698,020.70 Tuesday, 23 September 2014 198 Date Ref. No. Transaction Particulars Amount Tuesday, 23 September 2014 61540 BUY 10,000,000 CEI shares 1,887,651.96 Net Payable Amount (09/26/2014) 1,887,651.96 Wednesday, 24 September 2014 199 Date Ref. No. Transaction Particulars Amount Wednesday, 24 September 2014 61639 BUY 1,680,000 CEI shares 332,863.03 Wednesday, 24 September 2014 61641 BUY 300,000 RWM shares 2,926,646.01 Wednesday, 24 September 2014 68591 SELL 1,680,000 CEI shares -322,416.36 Wednesday, 24 September 2014 68594 SELL 300,000 RWM shares -2,816,394.75 Net Payable Amount (09/29/2014) 120,697.93 Thursday, 25 September 2014 200 Date Ref. No. Transaction Particulars Amount Thursday, 25 September 2014 61679 BUY 2,000,000 MED shares 1,601,968.66 Thursday, 25 September 2014 61701 BUY 44,100 IMI shares 377,528.37 Thursday, 25 September 2014 61702 BUY 19,000 IMI shares 165,234.65 Thursday, 25 September 2014 61703 BUY 254,000 IMI shares 2,222,858.36 Thursday, 25 September 2014 61704 BUY 182,900 IMI shares 1,618,759.66 Thursday, 25 September 2014 68610 SELL 10,000,000 CEI shares 1,856,129.76 Thursday, 25 September 2014 68613 SELL 2,000,000 CPM shares -1,951,790.23 Thursday, 25 September 2014 68663 SELL 2,000,000 MED shares -1,426,547.96 Net Payable Amount (09/30/2014) 751,881.75 Thursday, 2 October 2014 201 Date Ref. No. Transaction Particulars Amount Thursday, 2 October 2014 61904 BUY 400,000,000 AR shares 3,293,026.65 Net Payable Amount (10/07/2014) 3,293,026.65 Wednesday, 8 October 2014 202 Date Ref. No. Transaction Particulars Amount Wednesday, 8 October 2014 62071 BUY 273,000 LRW shares 721,806.67 Wednesday, 8 October 2014 62120 BUY 5,000,000 IS shares 1,408,050.00 Net Payable Amount (10/13/2014) 2,129,856.67 Thursday, 9 October 2014 203 Date Ref. No. Transaction Particulars Amount Thursday, 9 October 2014 62122 BUY 150,000 ATNB shares 447,659.33 Thursday, 9 October 2014 69022 SELL 50,000 LRW shares -129,097.12 Net Payable Amount (10/14/2014) 318,562.21 Tuesday, 14 October 2014 204 Date Ref. No. Transaction Particulars Amount Tuesday, 14 October 2014 62228 BUY 300,000,000 AR shares 2,202,592.50 Tuesday, 14 October 2014 62238 BUY 100,000 LRW shares 231,322.50 Tuesday, 14 October 2014 69124 SELL 2,000,000 AR shares -14,810.75 Net Payable Amount (10/17/2014) 2,419,104.25 Thursday, 16 October 2014 205 Date Ref. No. Transaction Particulars Amount Thursday, 16 October 2014 62309 BUY 70,000 FPI shares 25,998.64 Thursday, 16 October 2014 62310 BUY 1,000,000 FPI shares 412,357.50 Thursday, 16 October 2014 69190 SELL 760,000 FPI shares -304,491.15 Net Payable Amount (10/21/2014) 133,864.99 Friday, 17 October 2014 206 Date Ref. No. Transaction Particulars Amount Friday, 17 October 2014 62339 BUY 2,945,000 CEI shares 490,806.01 Friday, 17 October 2014 62340 BUY 1,920,000 CEI shares 327,431.98 Friday, 17 October 2014 69206 SELL 1,505,000 FPI shares -625,354.39 Net Payable Amount (10/22/2014) 192,883.60 Monday, 20 October 2014 207 Date Ref. No. Transaction Particulars Amount Monday, 20 October 2014 62366 BUY 400,000 IS shares 149,605.31 Monday, 20 October 2014 62367 BUY 100,000 IS shares 40,230.00 Monday, 20 October 2014 62390 BUY 1,270,000 WIN shares 330,238.02 Monday, 20 October 2014 69245 SELL 500,000 IS shares -207,742.50 Monday, 20 October 2014 69266 SELL 100,000 WIN shares -27,699.00 Net Payable Amount (10/23/2014) 284,631.83 Tuesday, 21 October 2014 208 Date Ref. No. Transaction Particulars Amount Tuesday, 21 October 2014 62430 BUY 7,500,000 CEI shares 1,312,503.75 Tuesday, 21 October 2014 62434 BUY 1,130,000 FPI shares 486,003.56 Tuesday, 21 October 2014 62435 BUY 2,370,000 FPI shares 1,048,796.10 Tuesday, 21 October 2014 62440 BUY 7,500,000 IS shares 3,216,639.95 Tuesday, 21 October 2014 62450 BUY 5,000,000 WIN shares 1,858,374.57 Tuesday, 21 October 2014 69275 SELL 256,000,000 AR shares -1,722,086.40 Tuesday, 21 October 2014 69317 SELL 1,000,000 CEI shares -170,151.00 Tuesday, 21 October 2014 69329 SELL 6,170,000 WIN shares -2,239,414.69 Tuesday, 21 October 2014 69331 SELL 3,575,000 CEI shares -600,038.44 Net Payable Amount (10/24/2014) 3,190,627.40 Thursday, 23 October 2014 209 Date Ref. No. Transaction Particulars Amount Thursday, 23 October 2014 62543 BUY 5,000,000 MRC shares 741,237.75 Thursday, 23 October 2014 69392 SELL 2,500,000 CEI shares -405,602.39 Thursday, 23 October 2014 69420 SELL 200,000 UNI shares -71,226.00 Thursday, 23 October 2014 69433 SELL 100,000 WIN shares -33,139.87 Net Payable Amount (10/28/2014) 231,269.49 Monday, 27 October 2014 210 Date Ref. No. Transaction Particulars Amount Monday, 27 October 2014 62623 BUY 300,000 IS shares 156,897.00 Monday, 27 October 2014 62638 BUY 100,000,000 AR shares 905,175.00 Monday, 27 October 2014 69525 SELL 300,000 IS shares -166,194.00 Net Payable Amount (10/30/2014) 895,878.00 Thursday, 30 October 2014 211 Date Ref. No. Transaction Particulars Amount Thursday, 30 October 2014 62809 BUY 600,000 FPI shares 341,955.00 Thursday, 30 October 2014 62821 BUY 450,000 SFI shares 95,797.69 Thursday, 30 October 2014 62822 BUY 600,000 SFI shares 148,046.41 Thursday, 30 October 2014 62823 BUY 5,000,000 SFI shares 1,257,187.50 Thursday, 30 October 2014 62829 BUY 150,000 UNI shares 90,517.50 Thursday, 30 October 2014 69716 SELL 60,000 UNI shares -34,425.90 Thursday, 30 October 2014 69730 SELL 100,000 IS shares -66,279.75 Thursday, 30 October 2014 69736 SELL 1,050,000 SFI shares -264,871.69 Thursday, 30 October 2014 69740 SELL 150,000 UNI shares -100,903.51 Net Payable Amount (11/04/2014) 1,467,023.25 Friday, 31 October 2014 212 Date Ref. No. Transaction Particulars Amount Friday, 31 October 2014 62891 BUY 300,000 MRC shares 49,784.63 Friday, 31 October 2014 62892 BUY 100,000 MRC shares 17,314.58 Friday, 31 October 2014 62900 BUY 20,000,000 SFI shares 5,833,350.00 Friday, 31 October 2014 69753 SELL 100,000,000 AR shares -939,787.50 Friday, 31 October 2014 69773 SELL 2,960,000 MRC shares -483,149.70 Friday, 31 October 2014 69794 SELL 400,000 MRC shares -69,247.50 Friday, 31 October 2014 69803 SELL 5,000,000 SFI shares -1,483,875.00 Net Payable Amount (11/05/2014) 2,924,389.51 Wednesday, 5 November 2014 213 Date Ref. No. Transaction Particulars Amount Wednesday, 5 November 2014 63068 BUY 43,385,000 IS shares 31,696,824.76 Wednesday, 5 November 2014 63082 BUY 483,000,000 AR shares 4,265,989.20 Wednesday, 5 November 2014 63084 BUY 29,000,000 BHI shares 2,597,047.65 Wednesday, 5 November 2014 63086 BUY 1,300,000 FPI shares 644,685.75 Wednesday, 5 November 2014 69956 SELL 41,104,000 IS shares 28,402,702.99 Due Clearing (11/10/2014) 10,801,844.37 Cr. as of Settlement Date (11/10/2014) -1,009,382.77 Net Payable Amount (11/10/2014) 9,792,461.60 Thursday, 6 November 2014 214 Date Ref. No. Transaction Particulars Amount Thursday, 6 November 2014 63132 BUY 18,000,000 BHI shares 1,692,677.25 Thursday, 6 November 2014 63149 BUY 4,700,000 MRC shares 712,996.29 Thursday, 6 November 2014 63154 BUY 4,800,000 SFI shares 1,013,735.65 Thursday, 6 November 2014 63160 BUY 80,000 LRW shares 442,530.00 Thursday, 6 November 2014 63161 BUY 766,000 LRW shares 4,314,265.20 Thursday, 6 November 2014 63162 BUY 195,000 LRW shares 1,096,317.79 Thursday, 6 November 2014 69975 SELL 20,000,000 BHI shares -1,683,189.09 Thursday, 6 November 2014 70012 SELL 27,000,000 BHI shares -2,243,619.00 Net Payable Amount (11/11/2014) 5,345,714.09 Tuesday, 11 November 2014 215 Date Ref. No. Transaction Particulars Amount Tuesday, 11 November 2014 31354 CM Cash Dividend -173.25 Tuesday, 11 November 2014 63277 BUY 2,900,000 FPI shares 1,370,837.25 Tuesday, 11 November 2014 63281 BUY 30,000 LRW shares 170,072.33 Tuesday, 11 November 2014 63282 BUY 10,180,000 SFI shares 2,161,759.05 Tuesday, 11 November 2014 63283 BUY 3,140,000 SFI shares 688,285.02 Tuesday, 11 November 2014 63284 BUY 1,580,000 SFI shares 349,598.70 Tuesday, 11 November 2014 63286 BUY 300,000 UNI shares 162,931.50 Tuesday, 11 November 2014 70166 SELL 250,000 UNI shares -136,021.87 Net Payable Amount (11/14/2014) 4,767,288.73 Friday, 14 November 2014 216 Date Ref. No. Transaction Particulars Amount Friday, 14 November 2014 51821 C/V Partial Payment of Net Credit Balance 400,000.00 Friday, 14 November 2014 63419 BUY 150,000 IRC shares 254,957.61 Friday, 14 November 2014 63420 BUY 50,000 IRC shares 85,991.63 Friday, 14 November 2014 63423 BUY 1,900,000 PLC shares 4,107,563.46 Due Clearing (11/19/2014) 4,848,512.70 Cr. as of Settlement Date (11/19/2014) -1,316,116.52 Net Payable Amount (11/19/2014) 3,532,396.18 Monday, 17 November 2014 217 Date Ref. No. Transaction Particulars Amount Monday, 17 November 2014 63437 BUY 4,800,000 FPI shares 2,100,006.00 Monday, 17 November 2014 63439 BUY 100,000 IRC shares 175,000.50 Monday, 17 November 2014 63455 BUY 5,000,000 SFI shares 975,577.50 Monday, 17 November 2014 63477 BUY 52,300 LRW shares 342,084.76 Monday, 17 November 2014 63478 BUY 32,700 LRW shares 215,386.40 Monday, 17 November 2014 63479 BUY 84,000 LRW shares 556,240.11 Monday, 17 November 2014 63480 BUY 281,000 LRW shares 1,865,263.94 Monday, 17 November 2014 70326 SELL 300,000 IRC shares -521,829.37 Net Payable Amount (11/20/2014) 5,707,729.84 Tuesday, 18 November 2014 218 Date Ref. No. Transaction Particulars Amount Tuesday, 18 November 2014 63499 BUY 5,000,000 FPI shares 2,187,506.25 Tuesday, 18 November 2014 63517 BUY 1,940,000 UNI shares 857,200.73 Tuesday, 18 November 2014 63526 BUY 900,000 SUN shares 1,261,994.98 Net Payable Amount (11/21/2014) 4,306,701.96 Wednesday, 19 November 2014 219 Date Ref. No. Transaction Particulars Amount Wednesday, 19 November 2014 63565 BUY 9,000,000 IS shares 7,241,400.00 Wednesday, 19 November 2014 63569 BUY 5,900,000 SFI shares 1,290,528.12 Wednesday, 19 November 2014 63574 BUY 34,000 SUN shares 45,138.06 Wednesday, 19 November 2014 70433 SELL 2,000,000 PLC shares -4,115,280.00 Net Payable Amount (11/24/2014) 4,461,786.18 Monday, 24 November 2014 220 Date Ref. No. Transaction Particulars Amount Monday, 24 November 2014 63745 BUY 63,600 2GO shares 243,069.66 Monday, 24 November 2014 63748 BUY 690,000 LRW shares 4,654,026.67 Monday, 24 November 2014 70597 SELL 979,000 TUGS shares -1,665,778.29 Monday, 24 November 2014 70606 SELL 963,000 TUGS shares -1,648,080.62 Net Payable Amount (11/27/2014) 1,583,237.42 Friday, 28 November 2014 221 Date Ref. No. Transaction Particulars Amount Friday, 28 November 2014 51916 C/V Payment of Net Credit Balance 400,000.00 Friday, 28 November 2014 51943 C/V Payment of Net Credit Balance 400,000.00 Friday, 28 November 2014 63959 BUY 20,898,000 IS shares 13,298,469.02 Due Clearing (12/03/2014) 14,098,469.02 Cr. as of Settlement Date (12/03/2014) -1,856,904.40 Net Payable Amount (12/03/2014) 12,241,564.62 Tuesday, 2 December 2014 222 Date Ref. No. Transaction Particulars Amount Tuesday, 2 December 2014 64023 BUY 15,920,000 CEI shares 2,364,819.99 Tuesday, 2 December 2014 64024 BUY 3,980,000 CEI shares 600,432.75 Tuesday, 2 December 2014 64026 BUY 56,700 LRW shares 326,413.15 Tuesday, 2 December 2014 64027 BUY 31,700 LRW shares 190,111.91 Tuesday, 2 December 2014 64028 BUY 151,000 LRW shares 916,187.96 Tuesday, 2 December 2014 64029 BUY 411,000 LRW shares 2,519,735.65 Net Payable Amount (12/05/2014) 6,917,701.41 Wednesday, 3 December 2014 223 Date Ref. No. Transaction Particulars Amount Wednesday, 3 December 2014 64085 BUY 1,190,000 X shares 10,456,782.75 Wednesday, 3 December 2014 70870 SELL 2,642,000 IS shares -1,515,887.12 Wednesday, 3 December 2014 70872 SELL 145,400 LRW shares -848,637.99 Net Payable Amount (12/08/2014) 8,092,257.64 Friday, 5 December 2014 224 Date Ref. No. Transaction Particulars Amount Friday, 5 December 2014 64143 BUY 1,073,000 CMT shares 3,001,489.89 Friday, 5 December 2014 64144 BUY 466,000 CMT shares 1,380,532.67 Friday, 5 December 2014 64145 BUY 131,000 CMT shares 393,379.00 Friday, 5 December 2014 64146 BUY 320,000 CMT shares 965,520.00 Friday, 5 December 2014 64148 BUY 500,000 X shares 3,952,597.50 Friday, 5 December 2014 71001 SELL 190,000 CMT shares -526,281.00 Friday, 5 December 2014 71003 SELL 838,500 X shares -6,640,323.80 Friday, 5 December 2014 71004 SELL 258,900 X shares -2,058,907.21 Net Payable Amount (12/10/2014) 468,007.05 Wednesday, 10 December 2014 225 Date Ref. No. Transaction Particulars Amount Wednesday, 10 December 2014 64192 BUY 119,200 LRW shares 650,233.47 Wednesday, 10 December 2014 64193 BUY 252,300 LRW shares 1,395,367.48 Wednesday, 10 December 2014 64195 BUY 522,700 X shares 4,745,469.45 Wednesday, 10 December 2014 64196 BUY 467,300 X shares 4,248,682.26 Wednesday, 10 December 2014 71032 SELL 1,338,000 CMT shares -3,592,817.49 Wednesday, 10 December 2014 71033 SELL 462,000 CMT shares -1,252,271.79 Net Payable Amount (12/15/2014) 6,194,663.38 Thursday, 11 December 2014 226 Date Ref. No. Transaction Particulars Amount Thursday, 11 December 2014 64225 BUY 2,950,000 IS shares 1,482,038.00 Thursday, 11 December 2014 64230 BUY 391,000 X shares 3,460,454.87 Thursday, 11 December 2014 64231 BUY 122,100 X shares 1,087,399.82 Thursday, 11 December 2014 64232 BUY 396,900 X shares 3,552,695.20 Thursday, 11 December 2014 64236 BUY 7,900,000 IS shares 4,048,445.47 Thursday, 11 December 2014 71105 SELL 725,100 X shares -6,242,924.25 Thursday, 11 December 2014 71106 SELL 169,900 X shares -1,467,303.08 Thursday, 11 December 2014 71108 SELL 798,000 IS shares -378,922.33 Thursday, 11 December 2014 71110 SELL 2,152,000 IS shares -1,043,144.34 Net Payable Amount (12/16/2014) 4,498,739.36 Wednesday, 17 December 2014 227 Date Ref. No. Transaction Particulars Amount Wednesday, 17 December 2014 64374 BUY 100,000,000 UPM shares 1,307,475.00 Wednesday, 17 December 2014 64375 BUY 495,000 X shares 4,575,758.19 Wednesday, 17 December 2014 71244 SELL 2,990,000 IS shares -1,168,353.70 Wednesday, 17 December 2014 71246 SELL 885,700 LRW shares -4,221,238.56 Wednesday, 17 December 2014 71247 SELL 5,200 LRW shares -24,948.88 Net Payable Amount (12/22/2014) 468,692.05 Friday, 19 December 2014 228 Date Ref. No. Transaction Particulars Amount Friday, 19 December 2014 64454 BUY 100,000 X shares 915,232.51 Friday, 19 December 2014 64465 BUY 553,000 PSPC shares 1,582,557.69 Friday, 19 December 2014 64466 BUY 47,000 PSPC shares 136,611.02 Due Clearing (12/29/2014) 2,634,401.22 Cr. as of Settlement Date (12/29/2014) -1,412,814.04 Net Payable Amount (12/29/2014) 1,221,587.18 Monday, 22 December 2014 229 Date Ref. No. Transaction Particulars Amount Monday, 22 December 2014 64504 BUY 173,800 MAXS shares 4,149,548.49 Monday, 22 December 2014 64506 BUY 950,000 PSPC shares 2,904,606.00 Monday, 22 December 2014 71342 SELL 600,000 PSPC shares -1,762,843.50 Net Payable Amount (12/29/2014) 5,291,310.99 Monday, 29 December 2014 230 Date Ref. No. Transaction Particulars Amount Monday, 29 December 2014 64570 BUY 56,300 MAXS shares 1,391,057.87 Monday, 29 December 2014 64571 BUY 274,600 MAXS shares 6,904,473.75 Monday, 29 December 2014 71401 SELL 10,000 CHIPS shares -187,957.50 Net Payable Amount (01/07/2015) 8,107,574.12 2015 Wednesday, 7 January 2015 231 Date Ref. No. Transaction Particulars Amount Wednesday, 7 January 2015 64676 BUY 9,900,000 LC shares 2,688,369.75 Wednesday, 7 January 2015 64685 BUY 77,000 LRW shares 325,259.55 Wednesday, 7 January 2015 71535 SELL 500,000 IS shares -230,000.62 Net Payable Amount (01/12/2015) 2,783,628.68 Thursday, 8 January 2015 232 Date Ref. No. Transaction Particulars Amount Thursday, 8 January 2015 64717 BUY 20,140,000 IS shares 8,605,800.46 Thursday, 8 January 2015 64720 BUY 418,000 LRW shares 2,148,855.27 Thursday, 8 January 2015 64721 BUY 372,000 LRW shares 1,944,285.72 Thursday, 8 January 2015 71551 SELL 18,900 CHIPS shares -351,692.21 Thursday, 8 January 2015 71564 SELL 329,400 MAXS shares -8,296,725.96 Thursday, 8 January 2015 71565 SELL 1,500 MAXS shares -38,061.37 Net Payable Amount (01/13/2015) 4,012,461.91 Wednesday, 14 January 2015 233 Date Ref. No. Transaction Particulars Amount Wednesday, 14 January 2015 64888 BUY 1,454,000 FNI shares 5,103,175.50 Wednesday, 14 January 2015 64889 BUY 1,446,000 FNI shares 5,284,673.17 Wednesday, 14 January 2015 64891 BUY 1,950,000 MED shares 1,104,816.38 Wednesday, 14 January 2015 64893 BUY 3,100,000 UNI shares 1,128,451.51 Wednesday, 14 January 2015 64895 BUY 8,000 X shares 92,689.92 Wednesday, 14 January 2015 71743 SELL 17,270,000 IS shares -6,536,518.83 Wednesday, 14 January 2015 71747 SELL 950,000 PSPC shares -2,448,186.01 Net Payable Amount (01/19/2015) 3,729,101.64 Monday, 19 January 2015 234 Date Ref. No. Transaction Particulars Amount Monday, 19 January 2015 64931 BUY 10,530,000 IS shares 4,130,313.53 Net Payable Amount (01/22/2015) 4,130,313.53 Tuesday, 20 January 2015 235 Date Ref. No. Transaction Particulars Amount Tuesday, 20 January 2015 64952 BUY 1,900,000 IS shares 764,370.00 Tuesday, 20 January 2015 64959 BUY 279,000 ISM shares 532,866.45 Tuesday, 20 January 2015 64960 BUY 721,000 ISM shares 1,411,278.46 Tuesday, 20 January 2015 64961 BUY 1,400,000 ISM shares 2,876,445.00 Tuesday, 20 January 2015 71785 SELL 117,900 CHIPS shares -2,157,702.64 Tuesday, 20 January 2015 71804 SELL 100,000 IS shares -38,333.44 Net Payable Amount (01/23/2015) 3,388,923.83 Thursday, 22 January 2015 236 Date Ref. No. Transaction Particulars Amount Thursday, 22 January 2015 65032 BUY 5,300,000 UNI shares 2,130,178.50 Net Payable Amount (01/27/2015) 2,130,178.50 Tuesday, 27 January 2015 237 Date Ref. No. Transaction Particulars Amount Tuesday, 27 January 2015 65138 BUY 300,000 CAL shares 1,309,486.51 Net Payable Amount (01/30/2015) 1,309,486.51 Wednesday, 28 January 2015 238 Date Ref. No. Transaction Particulars Amount Wednesday, 28 January 2015 65169 BUY 20,000,000 IS shares 7,844,850.01 Wednesday, 28 January 2015 72043 SELL 8,690,000 IS shares -3,266,701.35 Wednesday, 28 January 2015 72045 SELL 198,000 X shares -2,390,572.08 Net Payable Amount (02/02/2015) 2,187,576.58 Monday, 2 February 2015 239 Date Ref. No. Transaction Particulars Amount Monday, 2 February 2015 65282 BUY 4,000 2GO shares 18,154.71 Monday, 2 February 2015 65301 BUY 44,800 LRI shares 517,788.26 Monday, 2 February 2015 65302 BUY 81,500 LRI shares 952,662.48 Monday, 2 February 2015 65303 BUY 103,700 LRI shares 1,220,564.11 Monday, 2 February 2015 65304 BUY 186,000 LRI shares 2,207,420.10 Monday, 2 February 2015 72167 SELL 400 MAXS shares -13,398.06 Net Payable Amount (02/05/2015) 4,903,191.60 Wednesday, 4 February 2015 240 Date Ref. No. Transaction Particulars Amount Wednesday, 4 February 2015 65377 BUY 35,680,000 IS shares 10,215,503.32 Wednesday, 4 February 2015 65379 BUY 7,990,000 SFI shares 1,324,773.89 Wednesday, 4 February 2015 72236 SELL 67,000 2GO shares -268,432.99 Wednesday, 4 February 2015 72238 SELL 200,000 CAL shares -870,619.13 Wednesday, 4 February 2015 72268 SELL 201,000 CAL shares -874,892.70 Wednesday, 4 February 2015 72271 SELL 390,000 LRI shares -3,936,981.54 Net Payable Amount (02/09/2015) 5,589,350.85 Thursday, 12 February 2015 241 Date Ref. No. Transaction Particulars Amount Thursday, 12 February 2015 65633 BUY 1,900,000 IS shares 464,354.77 Thursday, 12 February 2015 65643 BUY 20,000,000 IS shares 5,028,750.01 Thursday, 12 February 2015 72529 SELL 8,060,000 UNI shares -2,927,190.74 Thursday, 12 February 2015 72543 SELL 1,900,000 IS shares -405,988.20 Due Clearing (02/17/2015) 2,159,925.84 Cr. as of Settlement Date (02/17/2015) -651,492.09 Net Payable Amount (02/17/2015) 1,508,433.75 Friday, 13 February 2015 242 Date Ref. No. Transaction Particulars Amount Friday, 13 February 2015 65682 BUY 1,525,000 CPM shares 1,712,389.95 Friday, 13 February 2015 65683 BUY 455,000 CPM shares 521,682.53 Friday, 13 February 2015 65689 BUY 490,000 NI shares 1,621,973.03 Net Payable Amount (02/18/2015) 3,856,045.51 Tuesday, 17 February 2015 243 Date Ref. No. Transaction Particulars Amount Tuesday, 17 February 2015 65764 BUY 1,990,000 FNI shares 5,433,866.10 Net Payable Amount (02/20/2015) 5,433,866.10 Wednesday, 18 February 2015 244 Date Ref. No. Transaction Particulars Amount Wednesday, 18 February 2015 65800 BUY 990,000 FNI shares 2,628,628.20 Wednesday, 18 February 2015 65806 BUY 2,950,000 SFI shares 498,449.71 Wednesday, 18 February 2015 65816 BUY 50,000 UNI shares 22,126.50 Wednesday, 18 February 2015 65822 BUY 1,000,000 FPI shares 344,871.68 Wednesday, 18 February 2015 65823 BUY 4,940,000 FPI shares 1,930,537.13 Wednesday, 18 February 2015 65825 BUY 238,000 LRW shares 1,096,247.38 Wednesday, 18 February 2015 65826 BUY 309,000 LRW shares 1,429,985,39 Wednesday, 18 February 2015 65827 BUY 127,000 LRW shares 593,452.83 Wednesday, 18 February 2015 65828 BUY 48,000 LRW shares 225,680.24 Wednesday, 18 February 2015 65829 BUY 268,000 LRW shares 1,266,641.55 Wednesday, 18 February 2015 65831 BUY 1,900,000 OM shares 1,566,958.50 Wednesday, 18 February 2015 65833 BUY 4,900,000 SFI shares 835,526.81 Wednesday, 18 February 2015 72685 SELL 62,000 LRW shares -274,774.07 Wednesday, 18 February 2015 72711 SELL 564,000 FNI shares -1,472,953.67 Wednesday, 18 February 2015 72715 SELL 920,000 MED shares -527,863.80 Wednesday, 18 February 2015 72719 SELL 2,950,000 SFI shares -496,108.87 Wednesday, 18 February 2015 72726 SELL 50,000 UNI shares -27,204.37 Wednesday, 18 February 2015 72729 SELL 3,580,000 UNI shares -1,376,145.67 Net Payable Amount (02/23/2015) 8,264,055.47 Monday, 23 February 2015 245 Date Ref. No. Transaction Particulars Amount Monday, 23 February 2015 65926 BUY 11,379,000 UNI shares 7,286,809.62 Monday, 23 February 2015 72817 SELL 426,000 FNI shares -1,070,408.07 Monday, 23 February 2015 72829 SELL 477,000 OM shares -363,341.63 Monday, 23 February 2015 72840 SELL 188,000 UNI shares -104,148.24 Monday, 23 February 2015 72862 SELL 3,268,000 UNI shares -1,972,050.09 Net Payable Amount (02/27/2015) 3,776,861.59 Thursday, 26 February 2015 246 Date Ref. No. Transaction Particulars Amount Thursday, 26 February 2015 66059 BUY 54,410,000 IS shares 17,100,163.83 Thursday, 26 February 2015 72991 SELL 52,400,000 IS shares -15,619,466.08 Net Payable Amount (03/03/2015) 1,480,697.75 Tuesday, 3 March 2015 247 Date Ref. No. Transaction Particulars Amount Tuesday, 3 March 2015 66143 BUY 1,150,000 IS shares 323,851.51 Tuesday, 3 March 2015 66152 BUY 2,000,000 IS shares 563,220.00 Tuesday, 3 March 2015 66166 BUY 3,020,000 SFI shares 591,039.02 Tuesday, 3 March 2015 66167 BUY 8,160,000 SFI shares 1,666,045.00 Tuesday, 3 March 2015 66168 BUY 4,940,000 SFI shares 1,039,663.87 Tuesday, 3 March 2015 73093 SELL 660,00 LRW shares -261,844.57 Tuesday, 3 March 2015 73096 SELL 220,400 MARC shares -1,295,143.91 Due Clearing (03/06/2015) 2,626,830.92 Cr. as of Settlement Date (03/06/2015) -1,592,542.85 Net Payable Amount (03/06/2015) 1,034,288.07 Thursday, 5 March 2015 248 Date Ref. No. Transaction Particulars Amount Thursday, 5 March 2015 66250 BUY 76,900 2GO shares 618,618.73 Thursday, 5 March 2015 66251 BUY 248,100 2GO shares 2,038,107.12 Due Clearing (03/10/2015) 2,656,725.85 Cr. as of Settlement Date (03/10/2015) -184,649.23 Net Payable Amount (03/10/2015) 2,472,076.62 Friday, 6 March 2015 249 Date Ref. No. Transaction Particulars Amount Friday, 6 March 2015 66298 BUY 10,000,000 IS shares 3,168,112.51 Net Payable Amount (03/11/2015) 3,168,112.51 Monday, 9 March 2015 250 Date Ref. No. Transaction Particulars Amount Monday, 9 March 2015 66333 BUY 100,000 H2O shares 603,450.00 Monday, 9 March 2015 66336 BUY 18,740,000 IS shares 5,928,292.80 Monday, 9 March 2015 73209 SELL 313,000 2GO shares -2,895,470.44 Monday, 9 March 2015 73229 SELL 12,600 2GO shares -118,535.89 Net Payable Amount (03/12/2015) 3,517,736.47 Tuesday, 10 March 2015 251 Date Ref. No. Transaction Particulars Amount Tuesday, 10 March 2015 66383 BUY 124,000 H2O shares 663,573.73 Tuesday, 10 March 2015 66384 BUY 3,000 H2O shares 18,024.70 Tuesday, 10 March 2015 66385 BUY 3,000 H2O shares 18,094.69 Tuesday, 10 March 2015 66391 BUY 2,490,000 UNI shares 1,517,576.17 Net Payable Amount (03/13/2015) 2,217,269.29 Monday, 16 March 2015 252 Date Ref. No. Transaction Particulars Amount Monday, 16 March 2015 66545 BUY 10,000 GTCAP shares 13,474,168.56 Monday, 16 March 2015 66577 BUY 534,000 NI shares 1,995,729.83 Monday, 16 March 2015 66578 BUY 384,000 NI shares 1,540,617.93 Monday, 16 March 2015 66579 BUY 572,000 NI shares 2,301,156.00 Monday, 16 March 2015 73483 SELL 200,000 NIKL shares -5,372,413.95 Monday, 16 March 2015 73484 SELL 192,500 NIKL shares -5,217,561.69 Monday, 16 March 2015 73485 SELL 7,500 NIKL shares -205,264.40 Monday, 16 March 2015 73501 SELL 200,000 NIKL shares -5,381,520.00 Net Payable Amount (03/19/2015) 3,134,912.28 Tuesday, 17 March 2015 253 Date Ref. No. Transaction Particulars Amount Tuesday, 17 March 2015 66604 BUY 14,590,000 IS shares 4,740,904.35 Tuesday, 17 March 2015 66615 BUY 825,000 FNI shares 1,930,869.02 Tuesday, 17 March 2015 66616 BUY 665,000 FNI shares 1,571,735.82 Tuesday, 17 March 2015 66620 BUY 1,410,000 IS shares 453,794.40 Tuesday, 17 March 2015 73521 SELL 1,100,000 NI shares -4,144,245.23 Tuesday, 17 March 2015 73545 SELL 90,000 NI shares -338,630.17 Net Payable Amount (03/20/2015) 4,214,428.19 Thursday, 19 March 2015 254 Date Ref. No. Transaction Particulars Amount Thursday, 19 March 2015 66698 BUY 300,000 2GO shares 2,171,780.34 Thursday, 19 March 2015 66699 BUY 305,000 2GO shares 2,292,607.14 Thursday, 19 March 2015 66707 BUY 13,260,000 IS shares 3,851,067.05 Net Payable Amount (03/27/2015) 8,315,454.53 Monday, 23 March 2015 255 Date Ref. No. Transaction Particulars Amount Monday, 23 March 2015 66754 BUY 201,900 2GO shares 1,469,881.48 Monday, 23 March 2015 66804 BUY 20,000 PPC shares 50,538.94 Monday, 23 March 2015 73650 SELL 11,000 2GO shares -78,783.87 Monday, 23 March 2015 73690 SELL 20,000 PPC shares -56,387.23 Net Payable Amount (03/31/2015) 1,385,249.32 Tuesday, 24 March 2015 256 Date Ref. No. Transaction Particulars Amount Tuesday, 24 March 2015 66816 BUY 1,660,000 GEO shares 692,861.17 Tuesday, 24 March 2015 66645 BUY 20,000 PPC shares 76,638.15 Tuesday, 24 March 2015 66846 BUY 498,000 PPC shares 2,036,110.70 Tuesday, 24 March 2015 73738 SELL 25,000 PPC shares -98,281.96 Net Payable Amount (03/31/2015) 2,707,328.06 Thursday, 26 March 2015 257 Date Ref. No. Transaction Particulars Amount Thursday, 26 March 2015 66923 BUY 7,600 AGF shares 59,558.50 Thursday, 26 March 2015 66925 BUY 67,200 AGF shares 512,148.02 Thursday, 26 March 2015 66926 BUY 64,200 AGF shares 474,744.17 Thursday, 26 March 2015 66927 BUY 115,000 AGF shares 818,811.25 Thursday, 26 March 2015 66928 BUY 73,500 AGF shares 511,195.57 Due Clearing (03/31/2015) 2,376,457.51 Cr. as of Settlement Date (03/31/2015) - 1,028,192.91 Net Payable Amount (03/31/2015) 1,348,264.60 Friday, 27 March 2015 258 Date Ref. No. Transaction Particulars Amount Friday, 27 March 2015 66977 BUY 1,168,000 ACR shares 2,660,329.45 Friday, 27 March 2015 66978 BUY 5,384,000 ACR shares 12,451,476.66 Friday, 27 March 2015 66980 BUY 29,000,000 BHI shares 3,500,010.00 Friday, 27 March 2015 66988 BUY 195,000 PRMX shares 1,568,970.00 Friday, 27 March 2015 73846 SELL 5,510,000 ACR shares -12,355,158.72 Friday, 27 March 2015 73847 SELL 42,000 ACR shares -95,146.07 Friday, 27 March 2015 73849 SELL 4,000,000 BHI shares -474,840.00 Friday, 27 March 2015 73854 SELL 95,000 PRMX shares -752,769.78 Friday, 27 March 2015 73856 SELL 250,000 SFI shares -42,537.75 Net Payable Amount (04/01/2015) 6,460,333.79 Tuesday, 31 March 2015 259 Date Ref. No. Transaction Particulars Amount Tuesday, 31 March 2015 67092 BUY 18,000 2GO shares 125,065.02 Tuesday, 31 March 2015 67093 BUY 11,000 2GO shares 76,980.11 Tuesday, 31 March 2015 67094 BUY 49,200 2GO shares 346,289.77 Tuesday, 31 March 2015 67103 BUY 148,000 PPC shares 538,619.34 Tuesday, 31 March 2015 67104 BUY 99,000 PPC shares 371,624.63 Tuesday, 31 March 2015 67105 BUY 95,000 PPC shares 378,363.14 Tuesday, 31 March 2015 73924 SELL 145,000 ACR shares -308,398.68 Tuesday, 31 March 2015 73968 SELL 7,000 PPC shares -27,975.99 Net Payable Amount (04/03/2015) 1,500,567.34 Tuesday, 7 April 2015 260 Date Ref. No. Transaction Particulars Amount Tuesday, 7 April 2015 67203 BUY 1,593,000 FNI shares 3,641,187.13 Tuesday, 7 April 2015 67205 BUY 995,000 NI shares 4,032,876.48 Tuesday, 7 April 2015 67207 BUY 352,400 NIKL shares 8,546,043,82 Tuesday, 7 April 2015 67208 BUY 247,600 NIKL shares 6,049,309.67 Tuesday, 7 April 2015 74039 SELL 15,000 GTCAP shares -20,033,044.54 Net Payable Amount (04/13/2015) 2,236,372.56 Friday, 10 April 2015 261 Date Ref. No. Transaction Particulars Amount Friday, 10 April 2015 67276 BUY 195,000 MEG shares 1,151,146.25 Net Payable Amount (04/15/2015) 1,151,146.25 Monday, 13 April 2015 262 Date Ref. No. Transaction Particulars Amount Monday, 13 April 2015 67304 BUY 2,195,000 GERI shares 3,527,145.14 Monday, 13 April 2015 67306 BUY 1,000,000 MEG shares 5,853,465.00 Monday, 13 April 2015 67307 BUY 7,000,000 GEO shares 3,102,738.75 Monday, 13 April 2015 67308 BUY 2,990,000 GEO shares 1,383,308.55 Monday, 13 April 2015 74149 SELL 1,652,000 GERI shares -2,455,808.22 Monday, 13 April 2015 74150 SELL 400,000 GERI shares -605,421.00 Monday, 13 April 2015 74167 SELL 143,000 GERI shares -217,852.62 Monday, 13 April 2015 74169 SELL 1,195,000 MEG shares -6,738,276.37 Net Payable Amount (04/16/2015) 3,849,304.23 Thursday, 16 April 2015 263 Date Ref. No. Transaction Particulars Amount Thursday, 16 April 2015 67404 BUY 232,200 NIKL shares 4,578,668.84 Thursday, 16 April 2015 67405 BUY 107,500 NIKL shares 2,156,490.93 Thursday, 16 April 2015 67406 BUY 305,300 NIKL shares 6,138,890.82 Thursday, 16 April 2015 67408 BUY 495,000 MEG shares 2,663,477.45 Thursday, 16 April 2015 74254 SELL 2,040,000 GEO shares -787,047,30 Thursday, 16 April 2015 74265 SELL 270,000 UNI shares -102,832.53 Thursday, 16 April 2015 74269 SELL 495,000 MEG shares -2,585,503.80 Net Payable Amount (04/21/2015) 12,062,144.41 Tuesday, 21 April 2015 264 Date Ref. No. Transaction Particulars Amount Tuesday, 21 April 2015 67474 BUY 95,000 2GO shares 668,803.63 Tuesday, 21 April 2015 67476 BUY 2,000,000 POPI shares 1,831,571.33 Tuesday, 21 April 2015 67477 BUY 2,900,000 POPI shares 2,750,726.25 Tuesday, 21 April 2015 74351 SELL 65,000 2GO shares -444,218.77 Tuesday, 21 April 2015 74352 SELL 1,700 2GO shares -11,608.32 Due Clearing (04/24/2015) 4,795,274.12 Cr. as of Settlement Date (04/24/2015) -609,851.68 Net Payable Amount (04/24/2015) 4,185,422.44 Friday, 24 April 2015 265 Date Ref. No. Transaction Particulars Amount Friday, 24 April 2015 67551 BUY 68,000 AGF shares 565,028.33 Friday, 24 April 2015 67560 BUY 300,000 IS shares 75,481.25 Net Payable Amount (04/29/2015) 640,459.58 Monday, 27 April 2015 266 Date Ref. No. Transaction Particulars Amount Monday, 27 April 2015 67574 BUY 6,200,000 IS shares 1,682,770.61 Monday, 27 April 2015 67603 BUY 670,000 CAL shares 3,219,204.60 Net Payable Amount (04/30/2015) 4,901,975.21 Tuesday, 28 April 2015 267 Date Ref. No. Transaction Particulars Amount Tuesday, 28 April 2015 67628 BUY 990,000 CROWN shares 2,787,939.00 Net Payable Amount (05/04/2015) 2,787,939.00 Monday, 4 May 2015 268 Date Ref. No. Transaction Particulars Amount Monday, 4 May 2015 67714 BUY 1,443,500 POPI shares 1,649,083.03 Monday, 4 May 2015 67715 BUY 806,500 POPI shares 932,808.00 Net Payable Amount (05/07/2015) 2,581,891.03 Tuesday, 5 May 2015 269 Date Ref. No. Transaction Particulars Amount Tuesday, 5 May 2015 67737 BUY 1,480,000 POPI shares 1,741,104.11 Tuesday, 5 May 2015 67743 BUY 109,000 TA shares 269,641.58 Tuesday, 5 May 2015 67744 BUY 1,881,000 TA shares 4,714,583.88 Tuesday, 5 May 2015 67752 BUY 5,000 TAPET shares 27,658.13 Tuesday, 5 May 2015 74641 SELL 485,000 POPI shares -542,156.45 Tuesday, 5 May 2015 74647 SELL 75,000 AGF shares -593,550.00 Tuesday, 5 May 2015 74653 SELL 1,450,000 POPI shares -1,633,330.89 Net Payable Amount (05/08/2015) 3,983,948.36 Friday, 8 May 2015 270 Date Ref. No. Transaction Particulars Amount Friday, 8 May 2015 67814 BUY 195,000 TAPET shares 1,113,968.70 Friday, 8 May 2015 67817 BUY 398,700 MAXS shares 11,578,400.20 Friday, 8 May 2015 67818 BUY 91,300 MAXS shares 2,662,069.39 Friday, 8 May 2015 74741 SELL 350,300 NIKL shares -9,195,553.59 Friday, 8 May 2015 74742 SELL 49,700 NIKL shares -1,312,724.86 Due Clearing (05/13/2015) 4,846,159.84 Cr. as of Settlement Date (05/13/2015) - 2,056,850.97 Net Payable Amount (05/13/2015) 2,789,308.87 Monday, 11 May 2015 271 Date Ref. No. Transaction Particulars Amount Monday, 11 May 2015 67861 BUY 250,000 LRW shares 1,156,612.50 Monday, 11 May 2015 67863 BUY 1,130,000 TA shares 2,606,853.71 Monday, 11 May 2015 74772 SELL 195,000 TAPET shares -1,504,649.25 Net Payable Amount (05/14/2015) 2,258,816.96 Tuesday, 12 May 2015 272 Date Ref. No. Transaction Particulars Amount Tuesday, 12 May 2015 67890 BUY 3,000,000 BRN shares 2,413,800.00 Tuesday, 12 May 2015 74818 SELL 301,000 BRN shares -252,288.41 Net Payable Amount (05/15/2015) 2,161,511.59 Thursday, 14 May 2015 273 Date Ref. No. Transaction Particulars Amount Thursday, 14 May 2015 67966 BUY 400,000 IS shares 94,540.50 Thursday, 14 May 2015 67985 BUY 1,059,000 POPI shares 1,251,776.56 Net Payable Amount (05/19/2015) 1,346,317.06 Tuesday, 19 May 2015 274 Date Ref. No. Transaction Particulars Amount Tuesday, 19 May 2015 68043 BUY 2,990,000 APC shares 2,335,975.08 Tuesday, 19 May 2015 68045 BUY 114,000 CAL shares 482,076.11 Tuesday, 19 May 2015 68046 BUY 130,000 CAL shares 556,330.62 Tuesday, 19 May 2015 68047 BUY 346,000 CAL shares 1,494,946.80 Net Payable Amount (05/22/2015) 4,869,328.61 Friday, 22 May 2015 275 Date Ref. No. Transaction Particulars Amount Friday, 22 May 2015 68122 BUY 193,000 CAL shares 898,748.27 Friday, 22 May 2015 68123 BUY 175,000 CAL shares 822,150.34 Friday, 22 May 2015 68124 BUY 115,000 CAL shares 542,954.14 Friday, 22 May 2015 68126 BUY 990,000 PXP shares 2,156,730.29 Net Payable Amount (05/27/2015) 4,420,583.04 Monday, 25 May 2015 276 Date Ref. No. Transaction Particulars Amount Monday, 25 May 2015 68140 BUY 2,000 GTCAP shares 2,866,387.50 Monday, 25 May 2015 75069 SELL 60,000 CAL shares -283,123.35 Net Payable Amount (05/28/2015) 2,583,264.15 Friday, 29 May 2015 277 Date Ref. No. Transaction Particulars Amount Friday, 29 May 2015 68228 BUY 7,262,000 FNI shares 12,193,783.42 Friday, 29 May 2015 68230 BUY 2,990,000 MHC shares 2,100,508.87 Friday, 29 May 2015 68233 BUY 990,000 PXP shares 2,079,780.38 Friday, 29 May 2015 75153 SELL 970,000 FNI shares -1,535,316.00 Friday, 29 May 2015 75155 SELL 990,000 MHC shares -616,995.23 Friday, 29 May 2015 75157 SELL 570,000 PXP shares -1,133,304.56 Due Clearing (06/03/2015) 13,088,456.88 Cr. as of Settlement Date (06/03/2015) -1,262,101.25 Net Payable Amount (06/03/2015) 11,826,355.63 Monday, 1 June 2015 278 Date Ref. No. Transaction Particulars Amount Monday, 1 June 2015 68255 BUY 3,617,000 PNI shares 5,527,954.01 Monday, 1 June 2015 75168 SELL 266,000 FNI shares -386,816.53 Monday, 1 June 2015 75175 SELL 1,121,000 MHC shares -698,638.03 Monday, 1 June 2015 75177 SELL 800,000 PXP shares -1,583,581.50 Monday, 1 June 2015 75180 SELL 1,995,000 FNI shares -2,851,523.01 Net Payable Amount (06/04/2015) 7,394.94 Wednesday, 3 June 2015 279 Date Ref. No. Transaction Particulars Amount Wednesday, 3 June 2015 68295 BUY 2,776,000 CROWN shares 6,011,347.63 Wednesday, 3 June 2015 68297 BUY 990,000 VITA shares 834,249.52 Due Clearing (06/08/2015) 6,845,597.15 Cr. as of Settlement Date (06/08/2015) - 1,410,219.54 Net Payable Amount (06/08/2015) 5,435,377.61 Thursday, 4 June 2015 280 Date Ref. No. Transaction Particulars Amount Thursday, 4 June 2015 68312 BUY 5,800,000 PHA shares 4,339,016.72 Thursday, 4 June 2015 75244 SELL 300,000 PXP shares -617,390.93 Thursday, 4 June 2015 75245 SELL 571,000 PXP shares -1,259,641.70 Net Payable Amount (06/09/2015) 2,461,984.09 Monday, 8 June 2015 281 Date Ref. No. Transaction Particulars Amount Monday, 8 June 2015 68341 BUY 2,990,000 FNI shares 5,190,283.51 Net Payable Amount (06/11/2015) 5,190,283.51 Thursday, 11 June 2015 282 Date Ref. No. Transaction Particulars Amount Thursday, 11 June 2015 68384 BUY 10,000 POPI shares 12,813.91 Net Payable Amount (06/17/2015) 12,813.91 Wednesday, 17 June 2015 283 Date Ref. No. Transaction Particulars Amount Wednesday, 17 June 2015 68441 BUY 3,524,000 POPI shares 5,204,434.41 Wednesday, 17 June 2015 68445 BUY 90,000 TAPET shares 1,071,053.34 Due Clearing (06/22/2015) 6,275,487.75 Cr. as of Settlement Date (06/22/2015) -1,070,916.93 Net Payable Amount (06/22/2015) 5,204,570.82 Thursday, 25 June 2015 284 Date Ref. No. Transaction Particulars Amount Thursday, 25 June 2015 68537 BUY 1,000,000 POPI shares 1,780,177.50 Due Clearing (06/30/2015) 1,780,177.50 Cr. as of Settlement Date (06/30/2015) -231,829.91 Net Payable Amount (06/30/2015) 1,548,347.59 Friday, 26 June 2015 285 Date Ref. No. Transaction Particulars Amount Friday, 26 June 2015 68554 BUY 100,000 PPC shares 315,694.87 Net Payable Amount (07/01/2015) 315,694.87 Tuesday, 30 June 2015 286 Date Ref. No. Transaction Particulars Amount Tuesday, 30 June 2015 68595 BUY 2,500,000 POPI shares 5,016,057.44 Net Payable Amount (07/03/2015) 5,016,057.44 Thursday, 2 July 2015 287 Date Ref. No. Transaction Particulars Amount Thursday, 2 July 2015 68618 BUY 15,000 ICT shares 1,697,203.13 Net Payable Amount (07/07/2015) 1,697,203.13 Friday, 3 July 2015 288 Date Ref. No. Transaction Particulars Amount Friday, 3 July 2015 68643 BUY 11,900,000 IS shares 2,661,888.35 Net Payable Amount (07/08/2015) 2,661,888.35 Wednesday, 8 July 2015 289 Date Ref. No. Transaction Particulars Amount Wednesday, 8 July 2015 68689 BUY 520,000,000 AR shares 3,500,010.00 Wednesday, 8 July 2015 68692 BUY 590,000 POPI shares 1,102,483.04 Due Clearing (07/13/2015) 4,602,493.04 Cr. as of Settlement Date (07/13/2015) -2,970,222.06 Net Payable Amount (07/13/2015) 1,632,270.98 Thursday, 9 July 2015 290 Date Ref. No. Transaction Particulars Amount Thursday, 9 July 2015 68718 BUY 298,000,000 AR shares 1,828,252.35 Thursday, 9 July 2015 75628 SELL 420,000 POPI shares -814,350.60 Net Payable Amount (07/14/2015) 1,013,901.75 Tuesday, 14 July 2015 291 Date Ref. No. Transaction Particulars Amount Tuesday, 14 July 2015 68773 BUY 498,000,000 AR shares 3,255,612.75 Due Clearing (07/17/2015) Cr. as of Settlement Date (07/17/2015) -967,412.14 Net Payable Amount (07/17/2015) 2,288,200.61 Wednesday, 15 July 2015 292 Date Ref. No. Transaction Particulars Amount Wednesday, 15 July 2015 68794 BUY 990,000 LIB shares 3,082,834.98 Net Payable Amount (07/20/2015) 3,082,834.98 Thursday, 16 July 2015 293 Date Ref. No. Transaction Particulars Amount Thursday, 16 July 2015 68807 BUY 1,990,000 PLC shares 3,042,192.60 Thursday, 16 July 2015 75712 SELL 252,000 LIB shares -718,057.00 Thursday, 16 July 2015 75719 SELL 35,000,000 AR shares -218,129.63 Net Payable Amount (07/21/2015) 2,106,005.97 Wednesday, 22 July 2015 294 Date Ref. No. Transaction Particulars Amount Wednesday, 22 July 2015 68873 BUY 495,000 MCP shares 3,584,493.00 Due Clearing (07/27/2015) 3,584,493.00 Cr. as of Settlement Date (07/27/2015) -1,758,284.28 Net Payable Amount (07/27/2015) 1,826,208.72 Monday, 27 July 2015 295 Date Ref. No. Transaction Particulars Amount Monday, 27 July 2015 68938 BUY 559,000 PPC shares 2,154,457.30 Monday, 27 July 2015 68939 BUY 441,000 PPC shares 1,764,326.90 Monday, 27 July 2015 75895 SELL 20,000 2GO shares -164,729.91 Net Payable Amount (07/30/2015) 3,754,054.29 Tuesday, 28 July 2015 296 Date Ref. No. Transaction Particulars Amount Tuesday, 28 July 2015 68959 BUY 800,000 PPC shares 2,865,240.95 Net Payable Amount (07/31/2015) 2,865,240.95 Wednesday, 29 July 2015 297 Date Ref. No. Transaction Particulars Amount Wednesday, 29 July 2015 68987 BUY 2,000,000 TA shares 4,623,261.77 Net Payable Amount (08/03/2015) 4,623,261.77 Tuesday, 4 August 2015 298 Date Ref. No. Transaction Particulars Amount Tuesday, 4 August 2015 69070 BUY 1,500,000,000 AR shares 9,252,900.00 Due Clearing (08/07/2015) 9,252,900.00 Cr. as of Settlement Date (08/07/2015) -1,213,040.53 Net Payable Amount (08/07/2015) 8,039,859.47 Friday, 7 August 2015 299 Date Ref. No. Transaction Particulars Amount Friday, 7 August 2015 69107 BUY 500,000 CAL shares 1,867,496.72 Friday, 7 August 2015 69108 BUY 300,000,000 AR shares 1,750,005.00 Net Payable Amount (08/12/2015) 3,617,501.72 Tuesday, 11 August 2015 300 Date Ref. No. Transaction Particulars Amount Tuesday, 11 August 2015 69136 BUY 917,000 SBS shares 5,256,954.68 Tuesday, 11 August 2015 69142 BUY 100,000 POPI shares 231,322.50 Tuesday, 11 August 2015 76106 SELL 130,000 CAL shares -537,479.29 Tuesday, 11 August 2015 76152 SELL 521,000 SBS shares -2,886,235.80 Net Payable Amount (08/14/2015) 2,064,562.09 Friday, 14 August 2015 301 Date Ref. No. Transaction Particulars Amount Friday, 14 August 2015 69210 BUY 2,305,000 POPI shares 5,762,323.95 Friday, 14 August 2015 76187 SELL 500,000,000 AR shares -2,868,825.00 Net Payable Amount (08/19/2015) 2,893,498.95 Thursday, 20 August 2015 302 Date Ref. No. Transaction Particulars Amount Thursday, 20 August 2015 69290 BUY 20,000,000 PA shares 1,119,429.93 Net Payable Amount (08/26/2015) 1,119,429.93 Monday, 24 August 2015 303 Date Ref. No. Transaction Particulars Amount Monday, 24 August 2015 69315 BUY 40,000,000 PA shares 2,031,615.00 Net Payable Amount (08/27/2015) 2,031,615.00 Friday, 28 August 2015 304 Date Ref. No. Transaction Particulars Amount Friday, 28 August 2015 69379 BUY 1,000,000 LIB shares 2,524,211.24 Net Payable Amount (09/02/2015) 2,524,211.24 Monday, 7 September 2015 305 Date Ref. No. Transaction Particulars Amount Monday, 7 September 2015 69444 BUY 500,000 SBS shares 2,604,892.51 Monday, 7 September 2015 69446 BUY 500,000 SBS shares 2,675,677.21 Monday, 7 September 2015 76400 SELL 222,000 LIB shares -549,142.54 Monday, 7 September 2015 76403 SELL 500,000 SBS shares -2,522,587.50 Net Payable Amount (09/10/2015) 2,208,839.68 Tuesday, 22 September 2015 306 Date Ref. No. Transaction Particulars Amount Tuesday, 22 September 2015 69730 BUY 4,000,000 UNI shares 1,568,970.00 Due Clearing (09/25/2015) 1,568,970.00 Cr. as of Settlement Date (09/25/2015) -811,568.76 Net Payable Amount (09/25/2015) 757,401.24 Wednesday, 23 September 2015 307 Date Ref. No. Transaction Particulars Amount Wednesday, 23 September 2015 69758 BUY 1,588,000 ION shares 4,884,143.27 Wednesday, 23 September 2015 69759 BUY 1,212,000 ION shares 3,802,740.75 Wednesday, 23 September 2015 69765 BUY 1,050,000 UNI shares 416,430.78 Net Payable Amount (09/28/2015) 9,103,314.80 Tuesday, 29 September 2015 308 Date Ref. No. Transaction Particulars Amount Tuesday, 29 September 2015 69849 BUY 149,000 DAVIN shares 290,722.10 Tuesday, 29 September 2015 69872 BUY 5,000,000 MED shares 4,002,885.00 Tuesday, 29 September 2015 76737 SELL 280,000 ION shares -1,039,444.53 Tuesday, 29 September 2015 76741 SELL 690,000 UNI shares -232,226.43 Net Payable Amount (10/02/2015) 3,021,936.14 Thursday, 1 October 2015 309 Date Ref. No. Transaction Particulars Amount Thursday, 1 October 2015 69921 BUY 1,490,000 ION shares 4,743,519.30 Thursday, 1 October 2015 69927 BUY 737,000 LIB shares 3,361,880.30 Thursday, 1 October 2015 69928 BUY 563,000 LIB shares 2,607,879.57 Thursday, 1 October 2015 76807 SELL 1,490,000 ION shares -4,279,871.41 Net Payable Amount (10/06/2015) 6,433,407.76 Friday, 9 October 2015 310 Date Ref. No. Transaction Particulars Amount Friday, 9 October 2015 70087 BUY 1,980,000 GERI shares 2,560,438.35 Friday, 9 October 2015 70094 BUY 641,000 SPH shares 1,623,763.26 Friday, 9 October 2015 70095 BUY 777,000 SPH shares 2,061,546.13 Friday, 9 October 2015 76963 SELL 1,980,000 GERI shares -2,555,737.28 Friday, 9 October 2015 76970 SELL 515,000 SPH shares -1,177,603.19 Net Payable Amount (10/14/2015) 2,512,407.27 Monday, 12 October 2015 311 Date Ref. No. Transaction Particulars Amount Monday, 12 October 2015 70110 BUY 177,000 PBB shares 3,172,276.30 Monday, 12 October 2015 70127 BUY 9,000,000 NOW shares 7,241,922.99 Monday, 12 October 2015 70128 BUY 1,500,000 SUN shares 1,910,925.00 Monday, 12 October 2015 76983 SELL 8,000 GTCAP shares -10,636,416.00 Net Payable Amount (10/15/2015) 1,688,708.29 Tuesday, 13 October 2015 312 Date Ref. No. Transaction Particulars Amount Tuesday, 13 October 2015 70161 BUY 625,000 ION shares 1,759,459.06 Tuesday, 13 October 2015 70166 BUY 5,257,000 NOW shares 4,253,125.67 Tuesday, 13 October 2015 77023 SELL 116,000 NOW shares -89,507.34 Tuesday, 13 October 2015 77027 SELL 710,000 SUN shares -949,561.33 Tuesday, 13 October 2015 77036 SELL 5,000 PBB shares -88,043.25 Net Payable Amount (10/16/2015) 4,885,472.81 Friday, 16, October 2015 313 Date Ref. No. Transaction Particulars Amount Friday, 16 October 2015 70234 BUY 7,000,000 NOW shares 8,297,437.50 Friday, 16 October 2015 77098 SELL 2,000,000 NOW shares -1,998,285.00 Friday, 16 October 2015 77103 SELL 100,000 NOW shares -99,914.25 Net Payable Amount (10/21/2015) 6,199,238.25 Wednesday, 21 October 2015 314 Date Ref. No. Transaction Particulars Amount Wednesday, 21 October 2015 70303 BUY 17,930,000 SFI shares 3,447,077.39 Wednesday, 21 October 2015 70304 BUY 5,000,000 SFI shares 1,005,750.00 Due Clearing (10/26/2015) 4,452,827.39 Cr. as of Settlement Date (10/26/2015) -1,340,056.46 Net Payable Amount (10/26/2015) 3,112,770.93 Thursday, 22 October 2015 315 Date Ref. No. Transaction Particulars Amount Thursday, 22 October 2015 70319 BUY 2,300,000 NOW shares 2,124,194.29 Net Payable Amount (10/27/2015) 2,124,194.29 Friday, 23 October 2015 316 Date Ref. No. Transaction Particulars Amount Friday, 23 October 2015 70335 BUY 5,000,000 NOW shares 4,763,674.51 Net Payable Amount (10/28/2015) 4,763,674.51 Tuesday, 27 October 2015 317 Date Ref. No. Transaction Particulars Amount Tuesday, 27 October 2015 70372 BUY 1,236,000 PPC shares 3,835,669.03 Tuesday, 27 October 2015 70373 BUY 690,000 PPC shares 2,260,755.02 Tuesday, 27 October 2015 70374 BUY 891,000 PPC shares 2,957,206.72 Tuesday, 27 October 2015 77250 SELL 3,097,000 NOW shares -2,669,016.29 Net Payable Amount (10/30/2015) 6,384,614.48 Wednesday, 28 October 2015 318 Date Ref. No. Transaction Particulars Amount Wednesday, 28 October 2015 70385 BUY 450,000 BKR shares 964,011.38 Wednesday, 28 October 2015 70389 BUY 1,000,000 PXP shares 1,807,604.30 Wednesday, 28 October 2015 77254 SELL 145,000 BKR shares -279,710.44 Wednesday, 28 October 2015 77262 SELL 100,000 PBB shares -1,880,332.77 Net Payable Amount (11/02/2015) 611,572.47 Thursday, 29 October 2015 319 Date Ref. No. Transaction Particulars Amount Thursday, 29 October 2015 70403 BUY 744,000 NOW shares 676,024.92 Net Payable Amount (11/03/2015) 676,024.92 Friday, 30 October 2015 320 Date Ref. No. Transaction Particulars Amount Friday, 30 October 2015 70419 BUY 626,000 LIB shares 2,552,050.40 Friday, 30 October 2015 77285 SELL 170,000 LIB shares -655,872.75 Friday, 30 October 2015 77290 SELL 731,000 NOW shares -633,090.32 Net Payable Amount (11/04/2015) 1,263,087.33 Thursday, 5 November 2015 321 Date Ref. No. Transaction Particulars Amount Thursday, 5 November 2015 70490 BUY 1,472,000 LIB shares 6,684,858.19 Thursday, 5 November 2015 70491 BUY 897,000 LIB shares 4,322,089.92 Thursday, 5 November 2015 77465 SELL 260,000 LIB shares -1,144,562.25 Thursday, 5 November 2015 77470 SELL 100,000 PRIM shares -136,516.50 Thursday, 5 November 2015 77471 SELL 9,210,000 SFI shares -1,377,688.91 Thursday, 5 November 2015 77472 SELL 790,000 SFI shares -122,241.62 Thursday, 5 November 2015 77476 SELL 422,000 LIB shares -1,827,886.68 Thursday, 5 November 2015 77477 SELL 400,000 LIB shares -1,760,865.00 Thursday, 5 November 2015 77479 SELL 500,000 PRIM shares -682,582.50 Net Payable Amount (11/10/2015) 3,954,604.65 Tuesday, 10 November 2015 322 Date Ref. No. Transaction Particulars Amount Tuesday, 10 November 2015 70546 BUY 2,309,000 ION shares 4,819,724.98 Tuesday, 10 November 2015 70547 BUY 464,000 ION shares 992,886.44 Tuesday, 10 November 2015 77374 SELL 843,000 LIB shares -3,557,501.28 Tuesday, 10 November 2015 77375 SELL 149,000 LIB shares -641,360.47 Tuesday, 10 November 2015 77376 SELL 8,000 LIB shares -35,375.57 Tuesday, 10 November 2015 77382 SELL 8,680,000 SFI shares -1,291,357.05 Net Payable Amount (11/13/2015) 287,017.05 Wednesday, 11 November 2015 323 Date Ref. No. Transaction Particulars Amount Wednesday, 11 November 2015 70563 BUY 500,000 LTG shares 7,039,926.16 Wednesday, 11 November 2015 70566 BUY 100,000,000 PA shares 3,993,430.95 Wednesday, 11 November 2015 77396 SELL 300,000 LIB shares -1,307,857.71 Wednesday, 11 November 2015 77398 SELL 200,000 LTG shares -2,746,158.00 Wednesday, 11 November 2015 77405 SELL 200,000 LIB shares -906,153.00 Wednesday, 11 November 2015 77406 SELL 300,000 LTG shares -4,119,237.00 Net Payable Amount (11/16/2015) 1,953,951.40 Thursday, 12 November 2015 324 Date Ref. No. Transaction Particulars Amount Thursday, 12 November 2015 70592 BUY 230,500,000 PA shares 9,107,569.12 Thursday, 12 November 2015 77418 SELL 2,023,000 ION shares -4,234,791.29 Thursday, 12 November 2015 77419 SELL 50,000 ION shares -107,828.25 Thursday, 12 November 2015 77423 SELL 81,000,000 PA shares -2,773,856.99 Thursday, 12 November 2015 77435 SELL 700,000 ION shares -1,513,235.94 Net Payable Amount (11/17/2015) 477,856.65 Friday, 13 November 2015 325 Date Ref. No. Transaction Particulars Amount Friday, 13 November 2015 70617 BUY 5,000,000 NOW shares 3,438,971.02 Friday, 13 November 2015 77448 SELL 103,200,000 PA shares -3,198,542.02 Net Payable Amount (11/18/2015) 240,429.00 Tuesday, 17 November 2015 326 Date Ref. No. Transaction Particulars Amount Tuesday, 17 November 2015 70645 BUY 500,000 ION shares 1,221,091.11 Net Payable Amount (11/20/2015) 1,221,091.11 Monday, 23 November 2015 327 Date Ref. No. Transaction Particulars Amount Monday, 23 November 2015 70675 BUY 300,000 FJP shares 2,062,793.25 Monday, 23 November 2015 70676 BUY 24,900 FJP shares 188,928.15 Monday, 23 November 2015 70677 BUY 125,100 FJP shares 960,100.01 Monday, 23 November 2015 70681 BUY 200,000 YEHEY shares 895,117.50 Net Payable Amount (11/26/2015) 4,106,938.91 Thursday, 26 November 2015 328 Date Ref. No. Transaction Particulars Amount Thursday, 26 November 2015 70723 BUY 1,000,000 CROWN shares 2,603,343.65 Due Clearing (12/02/2015) 2,603,343.65 Cr. as of Settlement Date (12/02/2015) -1,943,556.97 Net Payable Amount (12/02/2015) 659,786.68 Friday, 27 November 2015 329 Date Ref. No. Transaction Particulars Amount Friday, 27 November 2015 70742 BUY 1,000,000 CROWN shares 2,534,490.00 Net Payable Amount (12/03/2015) 2,534,490.00 Wednesday, 2 December 2015 330 Date Ref. No. Transaction Particulars Amount Wednesday, 2 December 2015 70773 BUY 2,000,000 NOW shares 1,689,660.00 Net Payable Amount (12/07/2015) 1,689,660.09 Thursday, 3 December 2015 331 Date Ref. No. Transaction Particulars Amount Thursday, 3 December 2015 70804 BUY 200,000 DAVIN shares 333,909.00 Thursday, 3 December 2015 70806 BUY 2,000,000 NOW shares 1,679,602.50 Net Payable Amount (12/08/2015) 2,013,511.50 Friday, 4 December 2015 332 Date Ref. No. Transaction Particulars Amount Friday, 4 December 2015 70826 BUY 2,000,000 DAVIN shares 3,459,780.00 Friday, 4 December 2015 77750 SELL 58,000 DAVIN shares -90,654.88 Friday, 4 December 2015 77755 SELL 2,989,000 NOW shares -2,353,188.33 Net Payable Amount (12/09/2015) 1,015,936.79 Monday, 7 December 2015 333 Date Ref. No. Transaction Particulars Amount Monday, 7 December 2015 70864 BUY 1,270,000 IDC shares 5,793,693.28 Monday, 7 December 2015 77781 SELL 1,011,000 NOW shares -830,109.35 Net Payable Amount (12/10/2015) 4,963,583.93 Wednesday, 9 December 2015 334 Date Ref. No. Transaction Particulars Amount Wednesday, 9 December 2015 70898 BUY 361,700 FJP shares 2,164,794.40 Wednesday, 9 December 2015 70899 BUY 38300 FJP shares 240,733.29 Wednesday, 9 December 2015 70904 BUY 200,000 X shares 3,034,750.05 Wednesday, 9 December 2015 77818 SELL 603,000 CROWN shares -1,360,515.52 Net Payable Amount (12/14/2015) 4,079,762.22 Friday, 11 December 2015 335 Date Ref. No. Transaction Particulars Amount Friday, 11 December 2015 70934 BUY 1,346,000 NOW shares 1,197,224.68 Net Payable Amount (12/16/2015) 1,197,224.68 Friday, 18 December 2015 336 Date Ref. No. Transaction Particulars Amount Friday, 18 December 2015 71004 BUY 212,000 JAS shares 490,091.91 Friday, 18 December 2015 71005 BUY 288,000 JAS shares 707,293.70 Friday, 18 December 2015 71007 BUY 5,300,000 NOW shares 4,717,741.95 Friday, 18 December 2015 77984 SELL 5,915,000 NOW shares -4,941,580.74 Net Payable Amount (12/23/2015) 973,546.82 Wednesday, 23 December 2015 337 Date Ref. No. Transaction Particulars Amount Wednesday, 23 December 2015 71048 BUY 1,000,000 ION shares 2,514,375.00 Wednesday, 23 December 2015 71053 BUY 5,000,000 PLC shares 3,136,833.68 Wednesday, 23 December 2015 78043 SELL 31,000 CHIB shares -1,137,063.73 Net Payable Amount (01/01/2016) 4,514,144.95 Monday, 28 December 2015 338 Date Ref. No. Transaction Particulars Amount Monday, 28 December 2015 71063 BUY 300,000 IDC shares 1,028,067.57 Monday, 28 December 2015 71068 BUY 5,000,000 PLC shares 3,268,687.50 Net Payable Amount (01/04/2016) 4,296,755.07 2016 Tuesday, 5 January 2016 339 Date Ref. No. Transaction Particulars Amount Tuesday, 5 January 2016 71104 BUY 100,000,000 EG shares 1,106,325.00 Tuesday, 5 January 2016 71105 BUY 1,532,000 MCP shares 3,256,266.49 Tuesday, 5 January 2016 71106 BUY 1,968,000 MCP shares 4,309,880.12 Due Clearing (01/08/2016) 8,672,471.61 Cr. as of Settlement Date (01/08/2016) 2,459,924.22 Net Payable Amount (01/08/2016) 6,212,547.39 Tuesday, 12 January 2016 340 Date Ref. No. Transaction Particulars Amount Tuesday, 12 January 2016 71193 BUY 374,000 LIB shares 1,674,553.64 Tuesday, 12 January 2016 71194 BUY 1,740,000 PLC shares 778,752.23 Due Clearing (01/15/2016) 2,453,305.87 Cr. as of Settlement Date (01/15/2016) -1,875,718.25 Net Payable Amount (01/15/2016) 577,587.62 Wednesday, 13 January 2016 341 Date Ref. No. Transaction Particulars Amount Wednesday, 13 January 2016 71200 BUY 300,000 LIB shares 1,333,624.50 Wednesday, 13 January 2016 71202 BUY 5,000,000 PLC shares 2,358,383.17 Net Payable Amount (01/18/2016) 3,692,007.67 Monday, 18 January 2016 342 Date Ref. No. Transaction Particulars Amount Monday, 18 January 2016 71264 BUY 4,310,000 PLC shares 2,109,912.65 Net Payable Amount (01/21/2016) 2,109,912.65 Wednesday, 20 January 2016 343 Date Ref. No. Transaction Particulars Amount Wednesday, 20 January 2016 71301 BUY 2,500,000 DAVIN shares 6,761,154.38 Wednesday, 20 January 2016 78294 SELL 1,910,000 PLC shares -982,523.10 Net Payable Amount (01/25/2016) 5,778,631.28 Friday, 22 January 2016 344 Date Ref. No. Transaction Particulars Amount Friday, 22 January 2016 71349 BUY 500,000 DAVIN shares 1,408,050.00 Friday, 22 January 2016 78328 SELL 500,000 DAVIN shares -1,370,111.25 Net Payable Amount (01/27/2016) 37,938.75 Monday, 25 January 2016 345 Date Ref. No. Transaction Particulars Amount Monday, 25 January 2016 71369 BUY 5,000,000 PLC shares 3,153,116.76 Monday, 25 January 2016 71371 BUY 5,065,000 PLC shares 3,209,297.96 Monday, 25 January 2016 78348 SELL 160,000 DAVIN shares -427,356.00 Monday, 25 January 2016 78353 SELL 5,000,000 PLC shares -3,066,675.00 Net Payable Amount (01/28/2016) 2,868,383.72 Tuesday, 26 January 2016 346 Date Ref. No. Transaction Particulars Amount Tuesday, 26 January 2016 71384 BUY 50,000 LIB shares 203,392.83 Net Payable Amount (01/29/2016) 203,392.83 Thursday, 28 January 2016 347 Date Ref. No. Transaction Particulars Amount Thursday, 28 January 2016 71423 BUY 500,000 FNI shares 355,703.61 Thursday, 28 January 2016 71437 BUY 200,000 PLC shares 147,845.25 Thursday, 28 January 2016 71439 BUY 1,780,000 COAL shares 683,155.70 Thursday, 28 January 2016 71440 BUY 2,220,000 COAL shares 893,106.00 Thursday, 28 January 2016 78438 SELL 100,000 PLC shares -74,193.75 Net Payable Amount (02/02/2016) 2,005,616.81 Friday, 29 January 2016 348 Date Ref. No. Transaction Particulars Amount Friday, 29 January 2016 71459 BUY 1,160,000 COAL shares 518,564.69 Friday, 29 January 2016 71465 BUY 3,000,000 PLC shares 2,383,627.50 Friday, 29 January 2016 78443 SELL 4,000,000 COAL shares -1,636,021.65 Friday, 29 January 2016 78470 SELL 100,000 PLC shares -78,150.75 Net Payable Amount (02/03/2016) 1,188,019.79 Monday, 1 February 2016 349 Date Ref. No. Transaction Particulars Amount Monday, 1 February 2016 71481 BUY 990,000 SSI shares 3,215,885.62 Monday, 1 February 2016 71484 BUY 10,000 SSI shares 34,195.50 Monday, 1 February 2016 78500 SELL 990,000 SSI shares -3,236,776.53 Net Payable Amount (02/04/2016) 13,304.59 Tuesday, 2 February 2016 350 Date Ref. No. Transaction Particulars Amount Tuesday, 2 February 2016 71503 BUY 1,000,000 IRC shares 1,380,824.32 Tuesday, 2 February 2016 71504 BUY 1,000,000 MCP shares 2,406,709.47 Tuesday, 2 February 2016 71505 BUY 500,000 SSI shares 1,795,263.75 Tuesday, 2 February 2016 78522 SELL 10,000 SSI shares -34,524.82 Net Payable Amount (02/05/2016) 5,548,272.72 Tuesday, 9 February 2016 351 Date Ref. No. Transaction Particulars Amount Tuesday, 9 February 2016 71595 BUY 20,000,000 MA shares 2,614,950.00 Tuesday, 9 February 2016 71597 BUY 108,700,000 MAB shares 1,421,225.33 Net Payable Amount (02/12/2016) 4,036,175.33 Friday, 12 February 2016 352 Date Ref. No. Transaction Particulars Amount Friday, 12 February 2016 71673 BUY 60,000 LC shares 19,314.88 Friday, 12 February 2016 71676 BUY 50,000,000 PA shares 1,709,775.00 Friday, 12 February 2016 71678 BUY 1,000,000 PLC shares 825,499.47 Friday, 12 February 2016 78706 SELL 360,000 LC shares -116,039.03 Net Payable Amount (02/17/2016) 2,438,550.32 Monday, 15 February 2016 353 Date Ref. No. Transaction Particulars Amount Monday, 15 February 2016 71699 BUY 25,000,000 LC shares 8,272,293.74 Monday, 15 February 2016 71702 BUY 4,160,000 LCB shares 1,421,728.20 Monday, 15 February 2016 71705 BUY 4,000,000 PLC shares 3,577,261.66 Monday, 15 February 2016 78720 SELL 11,000,000 LC shares -3,423,645.85 Monday, 15 February 2016 78724 SELL 50,000,000 PA shares -1,494,954.60 Monday, 15 February 2016 78727 SELL 2,196,000 PLC shares -1,921,598.33 Net Payable Amount (02/18/2016) 6,431,084.82 Wednesday, 17 February 2016 354 Date Ref. No. Transaction Particulars Amount Wednesday, 17 February 2016 71752 BUY 15,000,000 LC shares 4,701,881.25 Wednesday, 17 February 2016 71760 BUY 3,000,000 PLC shares 2,591,948.51 Wednesday, 17 February 2016 78785 SELL 3,701,000 PLC shares -3,002,729.89 Net Payable Amount (02/22/2016) 4,291,099.87 Friday, 19 February 2016 355 Date Ref. No. Transaction Particulars Amount Friday, 19 February 2016 71797 BUY 30,000,000 LC shares 9,956,925.00 Friday, 19 February 2016 71800 BUY 11,340,000 LCB shares 3,951,893.49 Friday, 19 February 2016 78825 SELL 15,000,000 LC shares -4,674,206.25 Friday, 19 February 2016 78836 SELL 2,680,000 LC shares -835,124.85 Friday, 19 February 2016 78839 SELL 5,000,000 LCB shares -1,582,800.00 Net Payable Amount (02/24/2016) 6,816,687.39 Monday, 29 February 2016 356 Date Ref. No. Transaction Particulars Amount Monday, 29 February 2016 37433 CM Cash Dividend -246.81 Monday, 29 February 2016 37434 CM Cash Dividend -13.50 Monday, 29 February 2016 55317 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55318 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55319 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55320 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55321 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55322 C/V Payment of Net Credit Balance 400,000.00 Monday, 29 February 2016 55323 C/V Payment of Net Credit Balance 162,720.74 Monday, 29 February 2016 71874 BUY 10,000,000 IS shares 2,313,225.00 Monday, 29 February 2016 78943 SELL 30,000 IS shares -7,349.38 Due Clearing (03/03/2016) 4,868,336.05 Cr. as of Settlement Date (03/03/2016) -2,539,608.61 Net Payable Amount (03/03/2016) 2,328,727.44 Tuesday, 1 March 2016 357 Date Ref. No. Transaction Particulars Amount Tuesday, 1 March 2016 71899 BUY 1,000,000 IS shares 218,499.19 Net Payable Amount (03/04/2016) 218,499.19 Wednesday, 2 March 2016 358 Date Ref. No. Transaction Particulars Amount Wednesday, 2 March 2016 71929 BUY 5,000,000 PLC shares 4,626,450.00 Net Payable Amount (03/07/2016) 4,626,450.00 Thursday, 3 March 2016 359 Date Ref. No. Transaction Particulars Amount Thursday, 3 March 2016 71963 BUY 1,500,000 ION shares 4,140,944.32 Net Payable Amount (03/08/2016) 4,140,944.32 Tuesday, 8 March 2016 360 Date Ref. No. Transaction Particulars Amount Tuesday, 8 March 2016 72088 BUY 500,000 DAVIN shares 2,832,192.00 Tuesday, 8 March 2016 72101 BUY 4,000,000 VITA shares 3,479,895.00 Due Clearing (03/11/2016) 6,312,087.00 Cr. as of Settlement Date (03/11/2016) -2,361,850.60 Net Payable Amount (03/11/2016) 3,950,236.40 Monday, 14 March 2016 361 Date Ref. No. Transaction Particulars Amount Monday, 14 March 2016 72220 BUY 300,000 DAVIN shares 1,810,350.00 Net Payable Amount (03/17/2016) 1,810,350.00 Thursday, 17 March 2016 362 Date Ref. No. Transaction Particulars Amount Thursday, 17 March 2016 72319 BUY 5,000,000 IS shares 1,433,193.75 Thursday, 17 March 2016 72322 BUY 100,000,000 OV shares 1,307,475.00 Thursday, 17 March 2016 79416 SELL 350,000 DAVIN shares -2,205,681.25 Net Payable Amount (03/22/2016) 534,987.50 Monday, 21 March 2016 363 Date Ref. No. Transaction Particulars Amount Monday, 21 March 2016 72369 BUY 940,000 PXP shares 2,453,396.40 Monday, 21 March 2016 72370 BUY 560,000 PXP shares 1,520,694.00 Net Payable Amount (03/28/2016) 3,974,090.40 Monday, 28 March 2016 364 Date Ref. No. Transaction Particulars Amount Monday, 28 March 2016 72446 BUY 2,000,000 BRN shares 2,151,832.29 Monday, 28 March 2016 72447 BUY 1,000,000 IS shares 286,638.75 Due Clearing (03/31/2016) 2,438,471.04 Cr. as of Settlement Date (03/31/2016) -1,135,540.09 Net Payable Amount (03/31/2016) 1,302,930.95 Tuesday, 29 March 2016 365 Date Ref. No. Transaction Particulars Amount Tuesday, 29 March 2016 72453 BUY 2,214,000 APC shares 1,358,305.59 Tuesday, 29 March 2016 72484 BUY 36,600 BCB shares 403,040.22 Tuesday, 29 March 2016 72485 BUY 53,300 BCB shares 609,808.36 Tuesday, 29 March 2016 72491 BUY 23,000,000 IS shares 6,664,652.66 Net Payable Amount (04/01/2016) 9,035,806.83 Monday, 4 April 2016 366 Date Ref. No. Transaction Particulars Amount Monday, 4 April 2016 72624 BUY 4,362,000 STI shares 2,845,488.00 Net Payable Amount (04/07/2016) 2,845,488.00 Tuesday, 5 April 2016 367 Date Ref. No. Transaction Particulars Amount Tuesday, 5 April 2016 72646 BUY 2,000,000 ISM shares 3,086,988.71 Tuesday, 5 April 2016 72651 BUY 5,000,000 NOW shares 9,271,164.40 Tuesday, 5 April 2016 79790 SELL 5,000,000 IS shares -1,568,752.66 Tuesday, 5 April 2016 79814 SELL 3,000,000 NOW shares -4,901,743.62 Net Payable Amount (04/08/2016) 5,887,656.83 Thursday, 7 April 2016 368 Date Ref. No. Transaction Particulars Amount Thursday, 7 April 2016 72701 BUY 3,000,000 NOW shares 6,487,087.50 Thursday, 7 April 2016 79841 SELL 3,000,000 IS shares -920,002.50 Thursday, 7 April 2016 79842 SELL 1,334,000 ISM shares -1,901,823.25 Thursday, 7 April 2016 79859 SELL 537,000 NOW shares -956,209.05 Thursday, 7 April 2016 79875 SELL 463,000 NOW shares -826,419.44 Net Payable Amount (04/12/2016) 1,882,633.26 Monday, 11 April 2016 369 Date Ref. No. Transaction Particulars Amount Monday, 11 April 2016 72740 BUY 2,480,000 ATN shares 2,889,771.18 Monday, 11 April 2016 72745 BUY 1,000,000 BRN shares 1,653,764.80 Monday, 11 April 2016 72751 BUY 2,000,000 VITA shares 2,413,800.00 Monday, 11 April 2016 79916 SELL 666,000 ISM shares -1,080,498.43 Monday, 11 April 2016 79924 SELL 639,000 NOW shares -1,218,568.03 Monday, 11 April 2016 79932 SELL 1,308,000 STI shares -802,242.18 Net Payable Amount (04/14/2016) 3,856,027.34 Thursday, 14 April 2016 370 Date Ref. No. Transaction Particulars Amount Thursday, 14 April 2016 72808 BUY 4,000,000 VITA shares 4,827,600.00 Thursday, 14 April 2016 80029 SELL 1,000,000 NOW shares -2,277,481.03 Net Payable Amount (04/19/2016) 2,550,118.97 Wednesday, 20 April 2016 371 Date Ref. No. Transaction Particulars Amount Wednesday, 20 April 2016 72891 BUY 1,110,000 IS shares 351,660.49 Net Payable Amount (04/25/2016) 351,660.49 Friday, 22 April 2016 372 Date Ref. No. Transaction Particulars Amount Friday, 22 April 2016 72948 BUY 2,298,000 NOW shares 7,968,758.42 Friday, 22 April 2016 72955 BUY 500,000 NOW shares 1,755,777.99 Friday, 22 April 2016 80203 SELL 1,298,000 NOW Shares -4,383,564.60 Friday, 22 April 2016 80209 SELL 1,577,000 VITA shares -1,700,451.50 Net Payable Amount (04/27/2016) 3,640,520.31 Monday, 25 April 2016 373 Date Ref. No. Transaction Particulars Amount Monday, 25 April 2016 73000 BUY 1,100,000 ARA shares 3,384,811.40 Monday, 25 April 2016 73001 BUY 7,000,000 SLI shares 7,195,849.58 Monday, 25 April 2016 80243 SELL 1,000,000 NOW shares -3,363,450.00 Monday, 25 April 2016 80274 SELL 375,000 NOW shares -1,264,261.50 Net Payable Amount (04/28/2016) 5,952,949,48 Wednesday, 27 April 2016 374 Date Ref. No. Transaction Particulars Amount Wednesday, 27 April 2016 73059 BUY 20,000,000 IS shares 7,593,412.51 Wednesday, 27 April 2016 80322 SELL 755,000 NOW shares -2,509,529.40 Wednesday, 27 April 2016 80329 SELL 13,810,000 IS shares -4,832,041.08 Net Payable Amount (05/02/2016) 251,842.03 Thursday, 28 April 2016 375 Date Ref. No. Transaction Particulars Amount Thursday, 28 April 2016 73081 BUY 5,000,000 ATN shares 1,985,199.64 Thursday, 28 April 2016 73090 BUY 30,000,000 IS shares 11,968,425.01 Thursday, 28 April 2016 80347 SELL 5,130,000 IS shares -2,004,566.73 Thursday, 28 April 2016 80355 SELL 238,000 NOW shares -753,412.80 Thursday, 28 April 2016 80362 SELL 10,000,000 IS shares -3,957,000.00 Net Payable Amount (05/03/2016) 7,238,645.12 Wednesday, 4 May 2016 376 Date Ref. No. Transaction Particulars Amount Wednesday, 4 May 2016 73169 BUY 12,620,000 ATN shares 6,317,216.32 Net Payable Amount (05/10/2016) 6,317,216.32 Thursday, 5 May 2016 377 Date Ref. No. Transaction Particulars Amount Thursday, 5 May 2016 73198 BUY 3,040,000 IS shares 1,131,267.60 Thursday, 5 May 2016 73201 BUY 6,960,000 IS shares 2,590,007.40 Thursday, 5 May 2016 73205 BUY 3,000,000 ATN shares 1,448,280.00 Thursday, 5 May 2016 80469 SELL 6,000,000 ATN shares -2,730,963.12 Thursday, 5 May 2016 80471 SELL 3,040,000 IS shares -1,112,708.40 Net Payable Amount (05/11/2016) 1,325,883.48 Tuesday, 10 May 2016 378 Date Ref. No. Transaction Particulars Amount Tuesday, 10 May 2016 73226 BUY 20,000 PGOLD shares 826,726.50 Tuesday, 10 May 2016 73234 BUY 3,560,000 IS shares 1,271,066.85 Tuesday, 10 May 2016 80512 SELL 4,330,000 IS shares -1,524,434,24 Net Payable Amount (05/13/2016) 573,359.11 Wednesday, 11 May 2016 379 Date Ref. No. Transaction Particulars Amount Wednesday, 11 May 2016 73253 BUY 2,000,000 ACR shares 3,379,320.00 Wednesday, 11 May 2016 73255 BUY 30,000,000 IS shares 11,566,125.00 Wednesday, 11 May 2016 80526 SELL 452,000 ACR shares -737,782.66 Wednesday, 11 May 2016 80537 SELL 25,000,000 IS shares -9,190,132.50 Wednesday, 11 May 2016 80553 SELL 1,548,000 ACR shares -2,526,742.35 Net Payable Amount (05/16/2016) 2,490,787.49 Thursday, 12 May 2016 380 Date Ref. No. Transaction Particulars Amount Thursday, 12 May 2016 73290 BUY 14,060,000 ATN shares 7,356,357.22 Thursday, 12 May 2016 80563 SELL 12,010,000 ATN shares -6,237,518.03 Thursday, 12 May 2016 80565 SELL 900,000 ATNB shares -445,162.50 Net Payable Amount (05/17/2016) 673,676.69 Tuesday, 17 May 2016 381 Date Ref. No. Transaction Particulars Amount Tuesday, 17 May 2016 73346 BUY 30,000 PGOLD shares 1,267,245.00 Tuesday, 17 May 2016 73377 BUY 500,000 PXP shares 2,459,370.54 Due Clearing (05/20/2016) 3,726,615.54 Cr. as of Settlement Date (05/20/2016) 2,263,613.35 Net Payable Amount (05/20/2016) 1,463,002.19 Wednesday, 18 May 2016 382 Date Ref. No. Transaction Particulars Amount Wednesday, 18 May 2016 39018 CM Cash Dividend -130,787.72 Wednesday, 18 May 2016 73419 BUY 30,000,000 LC shares 9,328,331.25 Wednesday, 18 May 2016 73425 BUY 1,225,000 T shares 3,741,379.96 Net Payable Amount (05/23/2016) 12,938,923.49 Friday, 20 May 2016 383 Date Ref. No. Transaction Particulars Amount Friday, 20 May 2016 73470 BUY 40,900 ALT shares 266,520.51 Friday, 20 May 2016 73480 BUY 1,961,400 ALT shares 10,284,306.70 Friday, 20 May 2016 73481 BUY 38,600 ALT shares 258,165.97 Friday, 20 May 2016 80821 SELL 1,000,000 ALT shares -3,862,763.03 Net Payable Amount (05/25/2016) 6,946,230.15 Tuesday, 24 May 2016 384 Date Ref. No. Transaction Particulars Amount Tuesday, 24 May 2016 73509 BUY 2,000,000 ACR shares 3,967,723.98 Net Payable Amount (05/27/2016) 3,967,723.98 Thursday, 26 May 2016 385 Date Ref. No. Transaction Particulars Amount Thursday, 26 May 2016 73553 BUY 600,000 ALT shares 2,625,007.50 Thursday, 26 May 2016 73555 BUY 4,000,000 ATN shares 1,543,323.37 Net Payable Amount (05/31/2016) 4,168,330.87 Thursday, 2 June 2016 386 Date Ref. No. Transaction Particulars Amount Thursday, 2 June 2016 73643 BUY 11,000,000 PHA shares 5,642,659.80 Net Payable Amount (06/07/2016) 5,642,659.80 Monday, 6 June 2016 387 Date Ref. No. Transaction Particulars Amount Monday, 6 June 2016 73659 BUY 3,000,000 PLC shares 3,318,975.00 Monday, 6 June 2016 81068 SELL 4,190,000 PHA shares -1,818,439.36 Monday, 6 June 2016 81076 SELL 480,000 PHA shares -213,678.00 Net Payable Amount (06/09/2016) 1,286,857.64 Thursday, 9 June 2016 388 Date Ref. No. Transaction Particulars Amount Thursday, 9 June 2016 73712 BUY 300,000 DD shares 22,467,635.34 Thursday, 9 June 2016 81146 SELL 197,000 DD shares -13,972,916.35 Thursday, 9 June 2016 81147 SELL 53,000 DD shares -3,976,456.07 Net Payable Amount (06/14/2016) 4,518,262.92 Friday, 10 June 2016 389 Date Ref. No. Transaction Particulars Amount Friday, 10 June 2016 73732 BUY 100,000 DD shares 6,939,675.00 Friday, 10 June 2016 81161 SELL 100,000 DD shares -6,702,168.74 Net Payable Amount (06/15/2016) 237,506.26 Monday, 13 June 2016 390 Date Ref. No. Transaction Particulars Amount Monday, 13 June 2016 73746 BUY 50,000 DD shares 3,294,229.54 Monday, 13 June 2016 73749 BUY 565,000 NOW shares 1,675,318.00 Monday, 13 June 2016 73750 BUY 766,000 NOW shares 2,309,081.32 Monday, 13 June 2016 73751 BUY 1,000,000 NOW shares 3,017,250.00 Monday, 13 June 2016 81167 SELL 36,950 DD shares -2,147,169.57 Monday, 13 June 2016 81174 SELL 1,300,000 NOW shares -3,748,367.18 Monday, 13 June 2016 81183 SELL 31,000 NOW shares -89,546.92 Net Payable Amount (06/16/2016) 4,310,795.19 Wednesday, 15 June 2016 391 Date Ref. No. Transaction Particulars Amount Wednesday, 15 June 2016 73777 BUY 130,000 IS shares 42,492.95 Wednesday, 15 June 2016 73784 BUY 25,000,000 CYBR shares 16,015,261.28 Wednesday, 15 June 2016 81215 SELL 450,000 APC shares -271,549.13 Wednesday, 15 June 2016 81220 SELL 2,000,000 CYBR shares -1,206,885.00 Wednesday, 15 June 2016 81227 SELL 180,600 PXP shares -893,292.75 Wednesday, 15 June 2016 81231 SELL 130,000 IS shares -41,795.80 Wednesday, 15 June 2016 81233 SELL 5,000,000 CYBR shares -2,967,750.00 Net Payable Amount (06/20/2016) 10,676,481.55 Tuesday, 21 June 2016 392 Date Ref. No. Transaction Particulars Amount Tuesday, 21 June 2016 73860 BUY 816,000 ALT shares 3,380,104.51 Tuesday, 21 June 2016 73861 BUY 129,000 ALT shares 550,547.57 Net Payable Amount (06/24/2016) 3,930,652.08 Thursday, 23 June 2016 393 Date Ref. No. Transaction Particulars Amount Thursday, 23 June 2016 73909 BUY 11,550,000 ATN shares 4,594,517.44 Thursday, 23 June 2016 81376 SELL 270,000 ALT shares -1,041,779.17 Net Payable Amount (06/28/2016) 3,552,738.27 Tuesday, 28 June 2016 394 Date Ref. No. Transaction Particulars Amount Tuesday, 28 June 2016 73982 BUY 1,162,000 APX shares 4,634,274.73 Tuesday, 28 June 2016 73983 BUY 136,000 APX shares 582,480.12 Tuesday, 28 June 2016 73984 BUY 1,507,000 T shares 3,183,701.65 Tuesday, 28 June 2016 73985 BUY 873,000 T shares 1,886,515.46 Due Clearing (07/01/2016) 10,286,971.96 Cr. as of Settlement Date (07/01/2016) -1,867,578.22 Net Payable Amount (07/01/2016) 8,419,393.74 Thursday, 30 June 2016 395 Date Ref. No. Transaction Particulars Amount Thursday, 30 June 2016 74026 BUY 286,400 HVN shares 6,335,420.40 Net Payable Amount (07/05/2016) 6,335,420.40 Tuesday, 5 July 2016 396 Date Ref. No. Transaction Particulars Amount Tuesday, 5 July 2016 74085 BUY 1,000,000 NOW shares 3,942,540.00 Tuesday, 5 July 2016 81635 SELL 1,000,000 NOW shares -3,562,813.54 Net Payable Amount (07/11/2016) 379,726.46 Friday, 8 July 2016 397 Date Ref. No. Transaction Particulars Amount Friday, 8 July 2016 74114 BUY 184,000 APO shares 268,655.94 Friday, 8 July 2016 74115 BUY 816,000 APO shares 1,229,046.61 Friday, 8 July 2016 74121 BUY 8,000,000 VITA shares 8,317,552.50 Friday, 8 July 2016 74124 BUY 1,931,000 VUL shares 2,819,620.12 Friday, 8 July 2016 74125 BUY 1,069,000 VUL shares 1,607,540.52 Friday, 8 July 2016 81692 SELL 5,000,000 VITA shares -4,946,249.99 Net Payable Amount (07/13/2016) 9,296,165.70 Wednesday, 13 July 2016 398 Date Ref. No. Transaction Particulars Amount Wednesday, 13 July 2016 74197 BUY 779,000 PXP shares 4,377,526.90 Wednesday, 13 July 2016 74198 BUY 888,000 PXP shares 5,089,265.98 Due Clearing (07/18/2016) 9,466,792.88 Cr. as of Settlement Date (07/18/2016) -2,191,714.05 Net Payable Amount (07/18/2016) 7,275,078.83 Thursday, 14 July 2016 399 Date Ref. No. Transaction Particulars Amount Thursday, 14 July 2016 74215 BUY 1,000,000 ALT shares 6,135,075.00 Thursday, 14 July 2016 74229 BUY 300,000 PXP shares 1,581,835.57 Thursday, 14 July 2016 81807 SELL 500,000 ALT shares -2,819,907.57 Thursday, 14 July 2016 81843 SELL 300,000 PXP shares -1,391,704.61 Net Payable Amount (07/19/2016) 3,505,298.39 Wednesday, 20 July 2016 400 Date Ref. No. Transaction Particulars Amount Wednesday, 20 July 2016 74302 BUY 910,700 ALT shares 7,327,492.20 Wednesday, 20 July 2016 81978 SELL 910,700 ALT shares -7,279,973.85 Net Payable Amount (07/25/2016) 47,518.35 Thursday, 28 July 2016 401 Date Ref. No. Transaction Particulars Amount Thursday, 28 July 2016 74492 BUY 700,000 IDC shares 4,021,042.83 Due Clearing (08/02/2016) 4,021,042.83 Cr. as of Settlement Date (08/02/2016) -2,307,477.37 Net Payable Amount (08/02/2016) 4,021,042.83 Friday, 29 July 2016 402 Date Ref. No. Transaction Particulars Amount Friday, 29 July 2016 74526 BUY 50,000,000 BHI shares 5,971,650.69 Net Payable Amount (08/03/2016) 5,971,650.69 Tuesday, 2 August 2016 403 Date Ref. No. Transaction Particulars Amount Tuesday, 2 August 2016 74558 BUY 20,000,000 BHI shares 2,359,871.67 Tuesday, 2 August 2016 74559 BUY 20,000,000 MRC shares 2,816,100.00 Tuesday, 2 August 2016 82230 SELL 5,000,000 MRC shares -677,111.94 Tuesday, 2 August 2016 82240 SELL 3,250,000 BHI shares -347,226.75 Tuesday, 2 August 2016 82241 SELL 5,000,000 MRC shares 672,690.00 Net Payable Amount (08/05/2016) 3,478,942.98 Friday, 5 August 2016 404 Date Ref. No. Transaction Particulars Amount Friday, 5 August 2016 74611 BUY 20,000,000 BHI shares 2,112,075.00 Friday, 5 August 2016 74619 BUY 3,000,000 VITA shares 4,978,462.50 Friday, 5 August 2016 82286 SELL 6,190,000 BHI shares -630,716.12 Friday, 5 August 2016 82292 SELL 7,350,000 MRC shares -1,013,387.70 Net Payable Amount (08/10/2016) 5,446,433.68 Monday, 15 August 2016 405 Date Ref. No. Transaction Particulars Amount Monday, 15 August 2016 56883 C/V Payment of Net Credit Balance 400,000.00 Monday, 15 August 2016 56884 C/V Payment of Net Credit Balance 400,000.00 Monday, 15 August 2016 56885 C/V Payment of Net Credit Balance 400,000.00 Monday, 15 August 2016 56886 C/V Payment of Net Credit Balance 400,000.00 Monday, 15 August 2016 56887 C/V Payment of Net Credit Balance 229,549.80 Monday, 15 August 2016 74745 BUY 5,000 FPH shares 356,890.39 Monday, 15 August 2016 74759 BUY 3,000,000 VITA shares 5,943,982.50 Due Clearing (08/18/2016) 8,130,422.69 Cr. as of Settlement Date (08/18/2016) -918,340.30 Net Payable Amount (08/18/2016) 7,212,082.39 Tuesday, 16 August 2016 406 Date Ref. No. Transaction Particulars Amount Tuesday, 16 August 2016 74775 BUY 363,000 NOW shares 1,450,291.51 Tuesday, 16 August 2016 74776 BUY 637,000 NOW shares 2,564,883.76 Tuesday, 16 August 2016 82465 SELL 1,000,000 NOW shares -3,810,788.86 Net Payable Amount (08/19/2016) 204,386.41 Thursday, 18 August 2016 407 Date Ref. No. Transaction Particulars Amount Thursday, 18 August 2016 74825 BUY 500,000 IMI shares 4,019,221.40 Thursday, 18 August 2016 82528 SELL 1,787,000 VITA shares -3,641,646.89 Net Payable Amount (08/23/2016) 377,574.51 Monday, 22 August 2016 408 Date Ref. No. Transaction Particulars Amount Monday, 22 August 2016 74856 BUY 5,000 FPH shares 370,116.00 Net Payable Amount (08/25/2016) 370,116.00 Tuesday, 23 August 2016 409 Date Ref. No. Transaction Particulars Amount Tuesday, 23 August 2016 74904 BUY 1,000,000 TUGS shares 1,709,775.00 Net Payable Amount (08/26/2016) 1,709,775.00 Wednesday, 24 August 2016 410 Date Ref. No. Transaction Particulars Amount Wednesday, 24 August 2016 74912 BUY 200,000 LR shares 719,111.25 Wednesday, 24 August 2016 74926 BUY 800,000 CAL shares 3,186,065.15 Wednesday, 24 August 2016 82640 SELL 113,000 TUGS shares -178,856.40 Net Payable Amount (08/30/2016) 3,726,320.00 Thursday, 25 August 2016 411 Date Ref. No. Transaction Particulars Amount Thursday, 25 August 2016 74968 BUY 750,000 LR shares 3,899,795.62 Thursday, 25 August 2016 82660 SELL 800,000 CAL shares -2,525,822.34 Thursday, 25 August 2016 82669 SELL 396,000 TUGS shares -627,886.85 Net Payable Amount (08/31/2016) 746,086.43 Tuesday, 30 August 2016 412 Date Ref. No. Transaction Particulars Amount Tuesday, 30 August 2016 75016 BUY 4,000,000 VITA shares 12,277,431.64 Tuesday, 30 August 2016 82721 SELL 400,000 IMI shares -2,621,887.40 Tuesday, 30 August 2016 82729 SELL 3,000,000 VITA shares -8,814,217.50 Net Payable Amount (09/02/2016) 841,326.74 Wednesday, 31 August 2016 413 Date Ref. No. Transaction Particulars Amount Wednesday, 31 August 2016 9288 DM Interest 226,966.70 Wednesday, 31 August 2016 75040 BUY 1,000,000 NOW shares 3,867,108.75 Wednesday, 31 August 2016 82765 SELL 75,000 NOW shares -284,904.00 Net Payable Amount (09/05/2016) 3,809,171.45 Friday, 2 September 2016 414 Date Ref. No. Transaction Particulars Amount Friday, 2 September 2016 75103 BUY 5,000,000 MED shares 6,798,870.00 Net Payable Amount (09/07/2016) 6,798,870.00 Monday, 5 September 2016 415 Date Ref. No. Transaction Particulars Amount Monday, 5 September 2016 75122 BUY 50,000 NOW shares 187,069.50 Monday, 5 September 2016 75130 BUY 500,000 CAL shares 2,110,898.28 Net Payable Amount (09/08/2016) 2,297,967.78 Thursday, 15 September 2016 416 Date Ref. No. Transaction Particulars Amount Thursday, 15 September 2016 75218 BUY 12,000,000 MRC shares 2,268,972.00 Thursday, 15 September 2016 75220 BUY 1,096,000 PXP shares 3,687,954.51 Due Clearing (09/20/2016) 5,956,926.51 Cr. as of Settlement Date (09/20/2016) -2,691,976.82 Net Payable Amount (09/20/2016) 3,264,949.69 Thursday, 22 September 2016 417 Date Ref. No. Transaction Particulars Amount Thursday, 22 September 2016 75291 BUY 20,000,000 MRC shares 4,958,347.51 Net Payable Amount (09/27/2016) 4,958,347.51 Friday, 23 September 2016 418 Date Ref. No. Transaction Particulars Amount Friday, 23 September 2016 75306 BUY 15,000,000 MRC shares 3,590,497.33 Friday, 23 September 2016 83113 SELL 1,096,000 PXP shares -3,566,839.81 Net Payable Amount (09/28/2016) 23,657.52 Tuesday, 27 September 2016 419 Date Ref. No. Transaction Particulars Amount Tuesday, 27 September 2016 75333 BUY 6,000,000 FNI shares 5,642,257.50 Tuesday, 27 September 2016 75342 BUY 20,000,000 MRC shares 4,405,637.59 Due Clearing (09/30/2016) 10,047,895.09 Cr. as of Settlement Date (09/30/2016) -1,199,604.94 Net Payable Amount (09/30/2016) 8,848,290.15 Friday, 30 September 2016 420 Date Ref. No. Transaction Particulars Amount Friday, 30 September 2016 75378 BUY 20,000,000 MRC shares 4,716,967.50 Friday, 30 September 2016 83226 SELL 10,000,000 MRC shares -2,252,274.93 Net Payable Amount (10/05/2016) 2,464,692.57 Monday, 3 October 2016 421 Date Ref. No. Transaction Particulars Amount Monday, 3 October 2016 75397 BUY 5,000,000 FNI shares 5,516,096.23 Monday, 3 October 2016 75399 BUY 1,000,000 PXP shares 3,969,675.16 Monday, 3 October 2016 83236 SELL 5,000,000 FNI shares -5,356,699.73 Monday, 3 October 2016 83240 SELL 10,000,000 MRC shares -2,157,702.62 Net Payable Amount (10/06/2016) 1,971,369.04 Wednesday, 5 October 2016 422 Date Ref. No. Transaction Particulars Amount Wednesday, 5 October 2016 75428 BUY 6,000,000 MRC shares 1,265,474.88 Wednesday, 5 October 2016 83270 SELL 293,000 PXP shares -1,101,628.81 Net Payable Amount (10/10/2016) 163,846.07 Monday, 17 October 2016 423 Date Ref. No. Transaction Particulars Amount Monday, 17 October 2016 75546 BUY 8,773,000 MED shares 8,245,440.24 Due Clearing (10/20/2016) 8,245,440.24 Cr. as of Settlement Date (10/20/2016) -2,751,994.58 Net Payable Amount (10/20/2016) 5,493,445.66 Thursday, 27 October 2016 424 Date Ref. No. Transaction Particulars Amount Thursday, 27 October 2016 75655 BUY 5,000,000 LIHC shares 5,159,145.51 Net Payable Amount (11/03/2016) 5,159,145.51 Wednesday, 9 November 2016 425 Date Ref. No. Transaction Particulars Amount Wednesday, 9 November 2016 75751 BUY 21,593,000 CPG shares 15,051,451.05 Wednesday, 9 November 2016 75754 BUY 7,000,000 FNI shares 9,594,855.00 Wednesday, 9 November 2016 83731 SELL 200,000 SHLPH shares -13,850,637.62 Due Clearing (11/14/2016) 10,795,668.43 Cr. as of Settlement Date (11/14/2016) -4,280,468.75 Net Payable Amount (11/14/2016) 6,515,199.68 Thursday, 10 November 2016 426 Date Ref. No. Transaction Particulars Amount Thursday, 10 November 2016 75778 BUY 8,407,000 CPG shares 5,495,971.16 Net Payable Amount (11/15/2016) 5,495,971.16 Tuesday, 15 November 2016 427 Date Ref. No. Transaction Particulars Amount Tuesday, 15 November 2016 75828 BUY 4,513,000 LIHC shares 5,798,148.77 Tuesday, 15 November 2016 83798 SELL 5,000,000 CPG shares -2,819,362.50 Net Payable Amount (11/18/2016) 2,978,786.27 Friday, 18 November 2016 428 Date Ref. No. Transaction Particulars Amount Friday, 18 November 2016 75878 BUY 5,000,000 ALCO shares 1,753,726.28 Net Payable Amount (11/23/2016) 1,753,726.28 Monday, 28 November 2016 429 Date Ref. No. Transaction Particulars Amount Monday, 28 November 2016 76022 BUY 2,000,000 LIHC shares 3,414,752.59 Monday, 28 November 2016 76023 BUY 300,000 WEB shares 4,520,836.19 Monday, 28 November 2016 84029 SELL 2,033,000 LIHC shares -3,379,050.47 Net Payable Amount (12/02/2016) 4,556,538.31 Friday, 2 December 2016 430 Date Ref. No. Transaction Particulars Amount Friday, 2 December 2016 76092 BUY 2,000,000 LIHC shares 2,926,732.50 Friday, 2 December 2016 76102 BUY 444,900 WEB shares 6,164,931.69 Friday, 2 December 2016 84136 SELL 100,000 SHLPH shares -6,727,138.89 Due Clearing (12/07/2016) 2,364,525.30 Cr. as of Settlement Date (12/07/2016) -4,092,151.10 Net Payable Amount (12/07/2016) -1,727,625.80 Tuesday, 6 December 2016 431 Date Ref. No. Transaction Particulars Amount Tuesday, 6 December 2016 57929 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57930 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57931 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57932 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57933 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57934 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57935 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57936 C/V Payment of Net Credit Balance 450,000.00 Tuesday, 6 December 2016 57937 C/V Payment of Net Credit Balance 492,151.10 Tuesday, 6 December 2016 76136 BUY 250,000 EW shares 4,777,312.50 Tuesday, 6 December 2016 76139 BUY 656,000 LIHC shares 956,669.40 Due Clearing (12/09/2016) 9,826,133.00 Cr. as of Settlement Date (12/09/2016) -2,174,151.21 Net Payable Amount (12/09/2016) 7,651,981.79 Thursday, 8 December 2016 432 Date Ref. No. Transaction Particulars Amount Thursday, 8 December 2016 76183 BUY 30,000,000 ALCO shares 13,275,900.00 Thursday, 8 December 2016 84247 SELL 82,360 SHLPH shares -5,519,906.19 Thursday, 8 December 2016 84262 SELL 100,000 SHLPH shares -6,677,437.50 Net Payable Amount (12/13/2016) 1,078,556.31 Monday, 12 December 2016 433 Date Ref. No. Transaction Particulars Amount Monday, 12 December 2016 76229 BUY 610,000,000 APL shares 33,345,641.25 Monday, 12 December 2016 76235 BUY 500,000 LIHC shares 683,940.19 Monday, 12 December 2016 84299 SELL 500,000 SHLPH shares -33,694,659.24 Net Payable Amount (12/15/2016) 334,922.20 Thursday, 15 December 2016 434 Date Ref. No. Transaction Particulars Amount Thursday, 15 December 2016 76293 BUY 1,000,000 PIZZA shares 12,267,697.97 Thursday, 15 December 2016 84356 SELL 4,500,000 ALCO shares -2,199,795.21 Thursday, 15 December 2016 84366 SELL 750,000 PIZZA shares -8,977,443.74 Net Payable Amount (12/20/2016) 1,090,459.02 Wednesday, 21 December 2016 435 Date Ref. No. Transaction Particulars Amount Wednesday, 21 December 2016 58064 C/V Payment of Net Credit Balance 475,000.00 Wednesday, 21 December 2016 58065 C/V Payment of Net Credit Balance 475,000.00 Wednesday, 21 December 2016 58066 C/V Payment of Net Credit Balance 475,000.00 Wednesday, 21 December 2016 58067 C/V Payment of Net Credit Balance 489,549.24 Wednesday, 21 December 2016 76393 BUY 2,000,000 LIHC shares 2,398,713.75 Wednesday, 21 December 2016 76396 BUY 210,000 WEB shares 2,471,127.75 Due Clearing (12/27/2016) 6,784,390.74 Cr. as of Settlement Date (12/27/2016) -5,314,090.04 Net Payable Amount (12/27/2016) 1,470,300.70 Tuesday, 27 December 2016 436 Date Ref. No. Transaction Particulars Amount Tuesday, 27 December 2016 76459 BUY 2,000,000 TUGS shares 5,613,342.19 Due Clearing (01/03/2017) 5,613,342.19 Cr. as of Settlement Date (01/03/2017) -526,832.32 Net Payable Amount (01/03/2017) 5,086,509.87 Wednesday, 28 December 2016 437 Date Ref. No. Transaction Particulars Amount Wednesday, 28 December 2016 76477 BUY 2,102,000 LIHC shares 2,486,455.37 Net Payable Amount (01/04/2017) 2,486,455.37 Thursday, 29 December 2016 438 Date Ref. No. Transaction Particulars Amount Thursday, 29 December 2016 76486 BUY 1,000,000 LIHC shares 1,146,555.00 Net Payable Amount (01/05/2017) 1,146,555.00 2017 Tuesday, 3 January 2017 439 Date Ref. No. Transaction Particulars Amount Tuesday, 3 January 2017 76511 BUY 4,950,000 ALCO shares 2,330,222.18 Net Payable Amount (01/06/2017) 1,146,555.00 Thursday, 5 January 2017 440 Date Ref. No. Transaction Particulars Amount Thursday, 5 January 2017 76574 BUY 2,000,000 NOW shares 5,723,683.04 Thursday, 5 January 2017 84648 SELL 3,960,000 ALCO shares -1,828,678.09 Thursday, 5 January 2017 84655 SELL 841,000 LIHC shares -973,392.32 Net Payable Amount (01/10/2017) 2,921,612.63 Monday, 9 January 2017 441 Date Ref. No. Transaction Particulars Amount Monday, 9 January 2017 76654 BUY 150,000,000 PA shares 8,096,287.50 Monday, 9 January 2017 76661 BUY 500,000 WEB shares 5,547,767.30 Monday, 9 January 2017 76662 BUY 200,000 WEB shares 2,309,650.56 Monday, 9 January 2017 84736 SELL 10,000,000 ALCO shares -4,797,862.50 Monday, 9 January 2017 84753 SELL 2,896,000 LIHC shares -3,705,186.40 Monday, 9 January 2017 84765 SELL 1,000,000 NOW shares -2,711,741.99 Due Clearing (01/12/2017) 4,738,914.47 Cr. as of Settlement Date (01/12/2017) -888,782.05 Net Payable Amount (01/12/2017) 3,850,132.42 Tuesday, 17 January 2017 442 Date Ref. No. Transaction Particulars Amount Tuesday, 17 January 2017 76797 BUY 10,000,000 ALCO shares 7,844,850.01 Tuesday, 17 January 2017 76802 BUY 10,000,000 STI shares 10,912,387.50 Tuesday, 17 January 2017 84954 SELL 100,000 SHLPH shares -7,369,912.50 Net Payable Amount (01/20/2017) 11,387,325.01 Thursday, 19 January 2017 443 Date Ref. No. Transaction Particulars Amount Thursday, 19 January 2017 76841 BUY 5,000,000 STI shares 5,530,729.89 Thursday, 19 January 2017 84996 SELL 5,000,000 ALC shares -4,303,237.50 Thursday, 19 January 2017 85000 SELL 4,530,000 APL shares -246,471.64 Net Payable Amount (01/24/2017) 981,020.75 Friday, 27 January 2017 444 Date Ref. No. Transaction Particulars Amount Friday, 27 January 2017 58365 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58366 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58367 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58368 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58369 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58370 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58371 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58372 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58373 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 58374 C/V Payment of Net Credit Balance 475,000.00 Friday, 27 January 2017 76968 BUY 800,000 LMG shares 3,620,700.00 Due Clearing (02/01/2017) 8,370,700.00 Cr. as of Settlement Date (02/01/2017) -3,416,553.73 Net Payable Amount (02/01/2017) 4,954,146.27 Monday, 30 January 2017 445 Date Ref. No. Transaction Particulars Amount Monday, 30 January 2017 76986 BUY 600,000 LMG shares 2,579,748.75 Net Payable Amount (02/02/2017) 2,579,748.75 Tuesday, 31 January 2017 446 Date Ref. No. Transaction Particulars Amount Tuesday, 31 January 2017 76998 BUY 300,000 LMG shares 1,267,245.00 Tuesday, 31 January 2017 77005 BUY 50,000,000 APL shares 3,117,825.00 Tuesday, 31 January 2017 85189 SELL 96,000 STI shares -100,666.08 Net Payable Amount (02/03/2017) 4,284,403.92 Monday, 6 February 2017 447 Date Ref. No. Transaction Particulars Amount Monday, 6 February 2017 77142 BUY 9,399,000 RLT shares 8,202,997.57 Net Payable Amount (02/09/2017) 8,202,997.57 Tuesday, 7 February 2017 448 Date Ref. No. Transaction Particulars Amount Tuesday, 7 February 2017 77158 BUY 9,900,000 CPG shares 5,675,447.25 Tuesday, 7 February 2017 85363 SELL 2,000,000 RLT shares -1,786,268.93 Net Payable Amount (02/10/2017) 3,889,178.32 Friday, 10 February 2017 449 Date Ref. No. Transaction Particulars Amount Friday, 10 February 2017 77243 BUY 20,000 PGOLD shares 890,088.75 Friday, 10 February 2017 77245 BUY 5,000,000 ALCO shares 8,111,373.75 Friday, 10 February 2017 77252 BUY 50,000,000 PA shares 3,369,262.50 Friday, 10 February 2017 85427 SELL 3,640,000 APL shares -216,052.20 Friday, 10 February 2017 85430 SELL 358,000 LIHC shares -364,776.05 Net Payable Amount (02/15/2017) 11,789,896.75 Tuesday, 14 February 2017 450 Date Ref. No. Transaction Particulars Amount Tuesday, 14 February 2017 77288 BUY 50,000,000 APL shares 3,369,262.50 Tuesday, 14 February 2017 77297 BUY 29,980,000 APL shares 1,839,295.49 Tuesday, 14 February 2017 85490 SELL 9,370,000 APL shares -565,425.62 Tuesday, 14 February 2017 88518 SELL 29,980,000 APL shares -1,828,885.83 Net Payable Amount (02/17/2017) 2,814,246.54 Thursday, 16 February 2017 451 Date Ref. No. Transaction Particulars Amount Thursday, 16 February 2017 77335 BUY 300,000 LMG shares 2,039,661.00 Thursday, 16 February 2017 77350 BUY 171,300 LMG shares 1,360,664.09 Thursday, 16 February 2017 77351 BUY 328,700 LMG shares 2,643,352.37 Thursday, 16 February 2017 85548 SELL 32,370,000 APL shares -1,997,602.42 Thursday, 16 February 2017 85552 SELL 3,766,000 LIHC shares -3,811,966,06 Net Payable Amount (02/21/2017) 234,108.98 Friday, 17 February 2017 452 Date Ref. No. Transaction Particulars Amount Friday, 17 February 2017 77364 BUY 700,000 LMG shares 5,109,332.70 Friday, 17 February 2017 85585 SELL 4,000,000 LIHC shares -3,959,027.96 Net Payable Amount (02/22/2017) 1,150,304.74 Monday, 20 February 2017 453 Date Ref. No. Transaction Particulars Amount Monday, 20 February 2017 77382 BUY 451,000 PSPC shares 976,804.52 Monday, 20 February 2017 77383 BUY 549,000 PSPC shares 1,214,744.85 Net Payable Amount (02/23/2017) 2,191,549.37 Friday, 24 February 2017 454 Date Ref. No. Transaction Particulars Amount Friday, 24 February 2017 58598 C/V Payment of Net Credit Balance 485,000.00 Friday, 24 February 2017 58599 C/V Payment of Net Credit Balance 485,000.00 Friday, 24 February 2017 58600 C/V Payment of Net Credit Balance 485,000.00 Friday, 24 February 2017 58601 C/V Payment of Net Credit Balance 485,000.00 Friday, 24 February 2017 58602 C/V Payment of Net Credit Balance 471,140.45 Friday, 24 February 2017 77460 BUY 795,000 APX shares 1,851,756.73 Friday, 24 February 2017 77469 BUY 3,000,000 RLT shares 2,021,557.50 Friday, 24 February 2017 77470 BUY 2,205,000 APX shares 5,040,617.83 Friday, 24 February 2017 85691 SELL 4,964,000 LIHC shares -4,840,331.00 Due Clearing (03/01/2017) 6,484,741.51 Cr. as of Settlement Date (03/01/2017) -5,484,145.46 Net Payable Amount (03/01/2017) 1,000,596.05 Thursday, 2 March 2017 455 Date Ref. No. Transaction Particulars Amount Thursday, 2 March 2017 77525 BUY 228,900 DFNN shares 1,956,837.49 Thursday, 2 March 2017 77534 BUY 200,000,000 APL shares 14,734,237.50 Thursday, 2 March 2017 85771 SELL 7,000,000 LIHC shares -7,599,527.33 Due Clearing (03/07/2017) 9,091,547.66 Cr. as of Settlement Date (03/07/2017) -8,635,405.82 Net Payable Amount (03/07/2017) 456,141.84 Monday, 6 March 2017 456 Date Ref. No. Transaction Particulars Amount Monday, 6 March 2017 58669 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58670 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58671 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58672 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58673 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58674 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58675 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58676 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58677 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 58678 C/V Payment of Net Credit Balance 480,000.00 Monday, 6 March 2017 77567 BUY 182,000 LMG shares 1,451,459.17 Monday, 6 March 2017 77568 BUY 818,000 LMG shares 6,581,502.30 Due Clearing (03/09/2017) 12,832,961.47 Cr. as of Settlement Date (03/09/2017) -908,034.71 Net Payable Amount (03/09/2017) 11,924,926.76 Tuesday, 7 March 2017 457 Date Ref. No. Transaction Particulars Amount Tuesday, 7 March 2017 77589 BUY 5,000 ALCO shares 8,063.19 Tuesday, 7 March 2017 77590 BUY 100,000,000 APL shares 5,783,062.50 Net Payable Amount (03/10/2017) 5,791,125.69 Monday, 20 March 2017 458 Date Ref. No. Transaction Particulars Amount Monday, 20 March 2017 58772 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58773 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58774 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58775 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58776 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58777 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58778 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58779 C/V Payment of Net Credit Balance 485,000.00 Monday, 20 March 2017 58780 C/V Payment of Net Credit Balance 480,662.47 Monday, 20 March 2017 77728 BUY 700,000 LMG shares 3,787,654.51 Due Clearing (03/23/2017) 8,148,316.98 Cr. as of Settlement Date (03/23/2017) -2,273,690.99 Net Payable Amount (03/23/2017) 5,874,625.99 Tuesday, 21 March 2017 459 Date Ref. No. Transaction Particulars Amount Tuesday, 21 March 2017 77750 BUY 30,000,000 MRC shares 6,416,926.39 Net Payable Amount (03/24/2017) 6,416,926.39 Wednesday, 22 March 2017 460 Date Ref. No. Transaction Particulars Amount Wednesday, 22 March 2017 77758 BUY 268,100 DFNN shares 2,291,953.39 Wednesday, 22 March 2017 77766 BUY 14,650,000 MG shares 4,657,628.25 Wednesday, 22 March 2017 86040 SELL 3,000,000 RLT shares -1,929,037.50 Net Payable Amount (03/27/2017) 5,020,544.14 Friday, 24 March 2017 461 Date Ref. No. Transaction Particulars Amount Friday, 24 March 2017 77789 BUY 3,000 DFNN shares 25,646.63 Net Payable Amount (03/29/2017) 25,646.63 Monday, 3 April 2017 462 Date Ref. No. Transaction Particulars Amount Monday, 3 April 2017 77872 BUY 71,200 CHIB shares 2,917,167.82 Monday, 3 April 2017 77879 BUY 400,000 2GO shares 5,229,900.00 Monday, 3 April 2017 86169 SELL 100,000 LMG shares -524,302.50 Monday, 3 April 2017 86171 SELL 15,000,000 MRC shares -3,333,287.75 Due Clearing (04/06/2017) 4,289,477.57 Cr. as of Settlement Date (04/06/2017) -4,570,293.66 Net Payable Amount (04/06/2017) -280,816.09 Tuesday, 4 April 2017 463 Date Ref. No. Transaction Particulars Amount Tuesday, 4 April 2017 77891 BUY 160,000 CHIB shares 6,557,349.21 Tuesday, 4 April 2017 77899 BUY 287,000 2GO shares -3,624,093.42 Tuesday, 4 April 2017 77900 BUY 355,500 2GO shares 4,820,678.45 Tuesday, 4 April 2017 86194 SELL 283,500,000 APL shares -12,225,349.35 Net Payable Amount (04/07/2017) 2,776,771.73 Wednesday, 19 April 2017 464 Date Ref. No. Transaction Particulars Amount Wednesday, 19 April 2017 78064 BUY 139,000 LMG shares 806,873.00 Wednesday, 19 April 2017 78065 BUY 1,161,000 LMG shares 6,984,491.23 Due Clearing (04/24/2017) 7,791,364.23 Cr. as of Settlement Date (04/24/2017) -2,939,290.81 Net Payable Amount (04/24/2017) 4,852,073.42 Wednesday, 10 May 2017 465 Date Ref. No. Transaction Particulars Amount Wednesday, 10 May 2017 78352 BUY 15,000,000 RLT shares 12,257,497.68 Wednesday, 10 May 2017 86815 SELL 196,500 2GO shares -3,212,955.39 Wednesday, 10 May 2017 86816 SELL 15,700 2GO shares -259,331.88 Net Payable Amount (05/15/2017) 8,785,210.41 Friday, 12 May 2017 466 Date Ref. No. Transaction Particulars Amount Friday, 12 May 2017 78389 BUY 6,000,000 WPI shares 4,586,220.01 Net Payable Amount (05/17/2017) 4,586,220.01 Tuesday, 30 May 2017 467 Date Ref. No. Transaction Particulars Amount Tuesday, 30 May 2017 78581 BUY 2,000,000 RLT shares 1,649,430.00 Tuesday, 30 May 2017 87137 SELL 2,000,000 RLT shares -1,563,015.00 Net Payable Amount (06/02/2017) 86,415.00 Thursday, 1 June 2017 468 Date Ref. No. Transaction Particulars Amount Thursday, 1 June 2017 78656 BUY 2,000,000 ACR shares 3,800,910.29 Due Clearing (06/06/2017) 3,800,910.29 Cr. as of Settlement Date (06/06/2017) -2,303,883.39 Net Payable Amount (06/06/2017) 1,497,026.90 Friday, 2 June 2017 469 Date Ref. No. Transaction Particulars Amount Friday, 2 June 2017 78663 BUY 30,000 PGOLD shares 1,369,831.50 Friday, 2 June 2017 78682 BUY 1,121,900 CLI shares 6,066,280.69 Friday, 2 June 2017 87244 SELL 44,690 SHLPH shares -3,054,820.33 Friday, 2 June 2017 87245 SELL 55,310 SHLPH shares -3,801,375.64 Net Payable Amount (06/07/2017) 579,916.22 Wednesday, 28 June 2017 470 Date Ref. No. Transaction Particulars Amount Wednesday, 28 June 2017 79003 BUY 6,000,000 OM shares 5,233,420.13 Due Clearing (07/03/2017) 5,233,420.13 Cr. as of Settlement Date (07/03/2017) -2,518,432.66 Net Payable Amount (07/03/2017) 2,714,987.47 Friday, 22 September 2017 471 Date Ref. No. Transaction Particulars Amount Friday, 22 September 2017 46017 CM Cash Dividend -562.27 Friday, 22 September 2017 79886 BUY 3,000,000 BKR shares 7,337,187.62 Due Clearing (09/27/2017) 7,336,625.35 Cr. as of Settlement Date (09/27/2017) -81.00 Net Payable Amount (09/27/2017) 7,336,544.35 Wednesday, 4 October 2017 472 Date Ref. No. Transaction Particulars Amount Wednesday, 4 October 2017 60666 C/V Payment of Net Credit Balance 3,264,525.00 Wednesday, 4 October 2017 80090 BUY 551,700 PXP shares 4,634,618.71 Wednesday, 4 October 2017 80091 BUY 236,800 PXP shares 2,011,583.47 Wednesday, 4 October 2017 80092 BUY 211,500 PXP shares 1,807,435.35 Due Clearing (10/09/2017) 11,718,162.53 Cr. as of Settlement Date (10/09/2017) 3,071,159.81 Net Payable Amount (10/09/2017) 8,647,002.72 Monday, 6 November 2017 473 Date Ref. No. Transaction Particulars Amount Monday, 6 November 2017 46535 CM Cash Dividend -173.25 Monday, 6 November 2017 80438 BUY 150,000 GSMI shares 3,510,937.48 Monday, 6 November 2017 80456 BUY 300,000 IDC shares 2,712,789.37 Due Clearing (11/09/2017) 6,223,553.60 Cr. as of Settlement Date (11/09/2017) -3,688,767.86 Net Payable Amount (11/09/2017) 2,534,785.74 Wednesday, 15 November 2017 474 Date Ref. No. Transaction Particulars Amount Wednesday, 15 November 2017 80623 BUY 300,000 IDC shares 4,224,150.00 Net Payable Amount (11/20/2017) 4,224,150.00 Friday, 24 November 2017 475 Date Ref. No. Transaction Particulars Amount Friday, 24 November 2017 61102 C/V Payment of Net Credit Balance 7,035,966.74 Friday, 24 November 2017 80775 BUY 1,990,000 TUGS shares 7,005,048.75 Friday, 24 November 2017 89717 SELL 990,000 TUGS shares -3,848,874.98 Due Clearing (11/29/2017) 10,192,140.51 Cr. as of Settlement Date (11/29/2017) -7,035,966.74 Net Payable Amount (11/29/2017) 3,156,173.77 Thursday, 7 December 2017 476 Date Ref. No. Transaction Particulars Amount Thursday, 7 December 2017 80972 BUY 15,000 SHLPH shares 910,002.58 Thursday, 7 December 2017 89984 SELL 90,600 MJC shares -539,169.93 Thursday, 7 December 2017 89985 SELL 1,400 MJC shares -8,328.30 Net Payable Amount (12/12/2017) 362,504.35 Thursday, 14 December 2017 477 Date Ref. No. Transaction Particulars Amount Thursday, 14 December 2017 81053 BUY 300,000 CHIB shares 10,041,357.72 Thursday, 14 December 2017 90099 SELL 30,000 MER shares -9,585,832.50 Net Payable Amount (12/19/2017) 455,525.22 Friday, 15 December 2017 478 Date Ref. No. Transaction Particulars Amount Friday, 15 December 2017 81072 BUY 100,000 CHIB shares 3,349,147.50 Friday, 15 December 2017 81084 BUY 3,000,000 TBGI shares 11,965,085.89 Friday, 15 December 2017 90126 SELL 378,600 DNL shares -4,219,275.89 Friday, 15 December 2017 90127 SELL 21,400 DNL shares -240,490.64 Friday, 15 December 2017 90135 SELL 40,000 SMC shares -4,354,040.42 Net Payable Amount (12/20/2017) 6,500,426.44 Monday, 18 December 2017 479 Date Ref. No. Transaction Particulars Amount Monday, 18 December 2017 81095 BUY 86,000 CHIB shares 2,880,266.85 Net Payable Amount (12/21/2017) 2,880,266.85 2018 Monday, 22 January 2018 480 Date Ref. No. Transaction Particulars Amount Monday, 22 January 2018 81361 BUY 1,300,000 NOW shares 6,519,472.67 Monday, 22 January 2018 81362 BUY 200,000 NOW shares 1,064,194.12 Net Payable Amount (01/25/2018) 7,583,666.79 Friday, 9 February 2018 481 Date Ref. No. Transaction Particulars Amount Friday, 9 February 2018 81673 BUY 35,000,000 CEI shares 9,006,491.26 Friday, 9 February 2018 61596 C/V Payment of Net Credit Balance 9,956,318.49 Due Clearing (02/14/2018) 18,962,809.75 Cr. as of Settlement Date (02/14/2018) -9,956,318.49 Net Payable Amount (02/14/2018) 9,006,491.26 Monday, 12 February 2018 482 Date Ref. No. Transaction Particulars Amount Monday, 12 February 2018 81694 BUY 700,000 NOW shares 5,278,342.97 Monday, 12 February 2018 81698 BUY 1,500,000 POPI shares 5,619,034.74 Monday, 12 February 2018 99881 SELL 18,000,000 CEI shares -4,331,272.44 Monday, 12 February 2018 90896 SELL 2,000,000 CEI shares -478,312.99 Net Payable Amount (02/15/2018) 6,087,792.28 Wednesday, 14 February 2018 483 Date Ref. No. Transaction Particulars Amount Wednesday, 14 February 2018 81760 BUY 1,000,000 NOW shares 15,387,975.00 Wednesday, 14 February 2018 81764 BUY 688,000 SSP shares 1,707,240.49 Wednesday, 14 February 2018 81765 BUY 1,312,000 SSP shares 3,296,124.37 Net Payable Amount (02/20/2018) 20,391,339.86 Wednesday, 21 February 2018 484 Date Ref. No. Transaction Particulars Amount Wednesday, 21 February 2018 81942 BUY 840,000 PXP shares 14,784,525.00 Net Payable Amount (02/26/2018) 14,784,525.00 Thursday, 22 February 2018 485 Date Ref. No. Transaction Particulars Amount Thursday, 22 February 2018 81971 BUY 500,000 PXP shares 9,502,945.54 Thursday, 22 February 2018 91153 SELL 32,200 CHIB shares -1,126,486.40 Thursday, 22 February 2018 91161 SELL 526,900 PXP -8,354,517.26 Net Payable Amount (02/27/2018) 21,941.88 Wednesday, 28 February 2018 486 Date Ref. No. Transaction Particulars Amount Wednesday, 28 February 2018 82134 BUY 22,418,000 TBGI shares 13,314,088.32 Due Clearing (03/05/2018) 13,314,088.32 Cr. as of Settlement Date (03/05/2018) -9,365,119.36 Net Payable Amount (03/05/2018) 3,948,968.96 Thursday, 1 March 2018 487 Date Ref. No. Transaction Particulars Amount Thursday, 1 March 2018 82150 BUY 12,000,000 MRC shares 10,620,720.00 Net Payable Amount (03/06/2018) 10,620,720.00 Friday, 9 March 2018 488 Date Ref. No. Transaction Particulars Amount Friday, 9 March 2018 82330 BUY 300,000 DAVIN shares 2,051,488.62 Friday, 9 March 2018 82336 BUY 1,178,000 PRIM shares 1,960,548.70 Friday, 9 March 2018 82337 BUY 822,000 PRIM shares 1,388,900.53 Friday, 9 March 2018 91550 SELL 1,000,000 ION shares -2,776,982.50 Net Payable Amount (03/14/2018) 2,623,955.35 Tuesday, 20 March 2018 489 Date Ref. No. Transaction Particulars Amount Tuesday, 20 March 2018 82510 BUY 11,790,000 MRC shares 7,351,831.35 Tuesday, 20 March 2018 61801 CV Payment of Net Credit Balance 5,819,483.79 Due Clearing (03/23/2018) 13,171,315.14 Cr. as of Settlement Date (03/23/2018) -8,107,900.24 Net Payable Amount (03/23/2018) 5,063,414.90 Wednesday, 4 April 2018 490 Date Ref. No. Transaction Particulars Amount Wednesday, 4 April 2018 82637 BUY 15,000,000 MRC shares 10,107,787.50 Net Payable Amount (04/10/2018) 10,107,787.50 Thursday, 5 April 2018 491 Date Ref. No. Transaction Particulars Amount Thursday, 5 April 2018 82648 BUY 9,000,000 VUL shares 9,578,712.73 Thursday, 5 April 2018 82649 BUY 1,000,000 VUL shares 1,056,037.51 Net Payable Amount (04/11/2018) 10,634,750.24 Wednesday, 2 May 2018 492 Date Ref. No. Transaction Particulars Amount Wednesday, 2 May 2018 82821 BUY 24,600 CHIB shares 863,476.60 Wednesday, 2 May 2018 62189 CV Payment of Net Credit Balance 4,601,123.16 Due Clearing (05/07/2018) 5,464,599.76 Cr. as of Settlement Date (05/07/2018) -3,079,696.50 Net Payable Amount (05/07/2018) 2,384,903.26 Tuesday, 29 May 2018 493 Date Ref. No. Transaction Particulars Amount Tuesday, 29 May 2018 83051 BUY 1,000,000 NOW shares 11,817,562.50 Tuesday, 29 May 2018 92375 SELL 391,700 NOW shares -3,721,122.94 Tuesday, 29 May 2018 92376 SELL 8,300 NOW shares -79,468.13 Due Clearing (06/01/2018) 8,016,971.43 Cr. as of Settlement Date (06/01/2018) -3,921,349.71 Net Payable Amount (06/01/2018) 4,095,621.72 Tuesday, 5 June 2018 494 Date Ref. No. Transaction Particulars Amount Tuesday, 5 June 2018 83119 BUY 10,000,000 ABA shares 3,017,250.00 Tuesday, 5 June 2018 83128 BUY 500,000 NOW shares 5,219,023.81 Tuesday, 5 June 2018 92465 SELL 79,500 NOW shares -801,371.93 Net Payable Amount (06/08/2018) 7,434,901.88 Tuesday, 19 June 2018 495 Date Ref. No. Transaction Particulars Amount Tuesday, 19 June 2018 83262 BUY 1,531,000 ISM shares 3,048,810.44 Net Payable Amount (06/22/2018) 3,048,810.44 Thursday, 21 June 2018 496 Date Ref. No. Transaction Particulars Amount Thursday, 21 June 2018 83299 BUY 50,000 EAGLE shares 789,513.74 Net Payable Amount (06/26/2018) 789,513.74 Monday, 25 June 2018 497 Date Ref. No. Transaction Particulars Amount Monday, 25 June 2018 83355 BUY 894,000 ISM shares 2,543,400.97 Monday, 25 June 2018 83356 BUY 606,000 ISM shares 1,767,505.06 Net Payable Amount (06/28/2018) 4,310,906.03 Monday, 2 July 2018 498 Date Ref. No. Transaction Particulars Amount Monday, 2 July 2018 83433 BUY 2,000,000 ISM shares 6,663,093.75 Due Clearing (07/05/2018) 6,663,093.75 Cr. as of Settlement Date (07/05/2018) -2,618,434.74 Net Payable Amount (07/05/2018) 4,044,659.01 Thursday, 5 July 2018 499 Date Ref. No. Transaction Particulars Amount Thursday, 5 July 2018 83474 BUY 2,000,000 IRC shares 3,510,308.87 Thursday, 5 July 2018 83475 BUY 1,000,000 ISM shares 2,946.063.03 Net Payable Amount (07/10/2018) 6,456,371.90 Tuesday, 10 July 2018 500 Date Ref. No. Transaction Particulars Amount Tuesday, 10 July 2018 83532 BUY 5,000 MER shares 1,777,771.75 Net Payable Amount (07/13/2018) 1,777,771.75 Friday, 13 July 2018 501 Date Ref. No. Transaction Particulars Amount Friday, 13 July 2018 83593 BUY 6,000 BPI shares 580,217.17 Friday, 13 July 2018 83608 BUY 8,000,000 TBGI shares 4,586,220.00 Due Clearing (07/18/2018) 5,166,437.17 Cr. as of Settlement Date (07/18/2018) -4,960,729.73 Net Payable Amount (07/18/2018) 205,707.44 Wednesday, 1 August 2018 502 Date Ref. No. Transaction Particulars Amount Wednesday, 1 August 2018 83771 BUY 2,000 MER shares 784,082.70 Wednesday, 1 August 2018 83779 BUY 500,000 PXP shares 6,529,526.15 Wednesday, 1 August 2018 93231 SELL 2,080 TFHI shares -532,518.51 Due Clearing (08/06/2018) 6,781,090.34 Cr. as of Settlement Date (08/06/2018) -4,812,203.37 Net Payable Amount (08/06/2018) 1,968,886.97 Monday, 6 August 2018 503 Date Ref. No. Transaction Particulars Amount Monday, 6 August 2018 83834 BUY 7,000,000 ATN shares 10,336,726.36 Monday, 6 August 2018 93294 SELL 20,000 MBT shares -1,518,940.25 Due Clearing (08/09/2018) 8,817,786.11 Cr. as of Settlement Date (08/09/2018) -985,721.57 Net Payable Amount (08/09/2018) 7,832,064.54 Wednesday, 8 August 2018 504 Date Ref. No. Transaction Particulars Amount Wednesday, 8 August 2018 83885 BUY 600,000 PXP shares 9,622,448.77 Wednesday, 8 August 2018 93348 SELL 5,000,000 ATN shares -7,757,762.49 Net Payable Amount (08/13/2018) 1,864,686.28 Friday, 24 August 2018 505 Date Ref. No. Transaction Particulars Amount Friday, 24 August 2018 84050 BUY 41,000 SMC shares 7,092,046.13 Friday, 24 August 2018 84053 BUY 2,000 TFHI shares 603,450.00 Friday, 24 August 2018 93542 SELL 40,000 CHIB shares -1,233,731.30 Friday, 24 August 2018 93554 SELL 100,000 PXP shares -1,600,965.00 Due Clearing (08/30/2018) 4,860,799.83 Cr. as of Settlement Date (08/30/2018) -2,204,805.49 Net Payable Amount (08/30/2018) 2,655,994.34 Friday, 31 August 2018 506 Date Ref. No. Transaction Particulars Amount Friday, 31 August 2018 84094 BUY 2,000 SMC shares 338,736.60 Friday, 31 August 2018 84097 BUY 100,000 TUGS shares 393,248.26 Friday, 31 August 2018 63012 CV Payment of Net Credit Balance 5,092,124.86 Due Clearing (09/05/2018) 5,824,109.72 Cr. as of Settlement Date (09/05/2018) -5,092,124.86 Net Payable Amount (09/05/2018) 731,984.86 Tuesday, 13 November 2018 507 Date Ref. No. Transaction Particulars Amount Tuesday, 13 November 2018 84713 BUY 605,900 ISM shares 4,851,079.24 Tuesday, 13 November 2018 84714 BUY 394,100 ISM shares 3,169,483.35 Due Clearing (11/16/2018) 8,020,562.59 Cr. as of Settlement Date (11/16/2018) -6,144,257.03 Net Payable Amount (11/16/2018) 1,876,305.56 Wednesday, 21 November 2018 508 Date Ref. No. Transaction Particulars Amount Wednesday, 21 November 2018 84830 BUY 1,000,000 ISM shares 6,788,812.50 Due Clearing (11/26/2018) 6,788,812.50 Cr. as of Settlement Date (11/26/2018) -3,826,506.19 Net Payable Amount (11/26/2018) 2,962,306.31 Tuesday, 27 November 2018 509 Date Ref. No. Transaction Particulars Amount Tuesday, 27 November 2018 84886 BUY 173,000 NOW shares 675,290.72 Tuesday, 27 November 2018 84887 BUY 400,000 NOW shares 1,583,724.37 Tuesday, 27 November 2018 84888 BUY 702,000 NOW shares 2,820,505.19 Due Clearing (12/03/2018) 5,079,520.28 Cr. as of Settlement Date (12/03/2018) -4,722,413.43 Net Payable Amount (12/03/2018) 357,106.85 Wednesday, 28 November 2018 510 Date Ref. No. Transaction Particulars Amount Wednesday, 28 November 2018 84912 BUY 27,000 NOW shares 103,843.68 Wednesday, 28 November 2018 84913 BUY 173,000 NOW shares 669,879.79 Net Payable Amount (12/04/2018) 773,723.47 Monday, 3 December 2018 511 Date Ref. No. Transaction Particulars Amount Monday, 3 December 2018 84955 BUY 5,000 MBT shares 385,705.12 Net Payable Amount (12/06/2018) 385,705.12 Thursday, 20 December 2018 512 Date Ref. No. Transaction Particulars Amount Thursday, 20 December 2018 85142 BUY 3,000 BPI shares 283,621.50 Thursday, 20 December 2018 63808 CV Payment of Net Credit Balance 3,658,687.11 Due Clearing (12/27/2018) 3,942,308.61 Cr. as of Settlement Date (12/27/2018) -3,262,170.17 Net Payable Amount (12/27/2018) 680,139.44 2019 Friday, 4 January 2019 Date Ref. No. Transaction Particulars Amount Friday, 4 January 2019 63884 C/V Payment of Credit Balance 848,258.25 Friday, 4 January 2019 85201 BUY 500,000 ABA shares 357,041.25 Friday, 4 January 2019 85207 BUY 2,000 MER shares 792,531.00 Friday, 4 January 2019 85209 BUY 5,000 PGOLD shares 240,042.36 Due Clearing (01/09/2019) 2,237,872.86 Cr. as of Settlement Date (01/09/2019) -2,123,407.80 Net Payable (01/09/2019) 114,465.06 Friday, 25 January 2019 514 Date Ref. No. Transaction Particulars Amount Friday, 25 January 2019 85435 BUY 6,000,000 PHA shares 6,215,535.00 Due Clearing (01/30/2019) 6,215,535.00 Cr. as of Settlement Date (01/30/2019) -2,882,625.72 Net Payable (01/30/2019) 3,332,909.28 Monday, 28 January 2019 515 Date Ref. No. Transaction Particulars Amount Monday, 28 January 2019 85453 BUY 10,000,000 PHA shares 12,958,334.44 Monday, 28 January 2019 95197 SELL 9,000,000 PHA shares -10,673,100.00 Net Payable (01/31/2019) 2,285,234.44 Wednesday, 30 January 2019 516 Date Ref. No. Transaction Particulars Amount Wednesday, 30 January 2019 51968 CM Cash Dividend -2,430.00 Wednesday, 30 January 2019 85498 BUY 2,000,000 PHA shares 3,337,219.29 Due Clearing (02/04/2019) 3,334,789.29 Cr. as of Settlement Date (02/04/2019) -1,592,415.59 Net Payable (02/04/2019) 1,742,373.70 Thursday, 31 January 2019 517 Date Ref. No. Transaction Particulars Amount Thursday, 31 January 2019 85517 BUY 3,000,000 PHA shares 4,672,302.15 Net Payable (02/06/2019) 4,672,302.15 Monday, 4 February 2019 518 Date Ref. No. Transaction Particulars Amount Monday, 4 February 2019 85546 BUY 5,000,000 GEO shares 1,627,504.65 Monday, 4 February 2019 85553 BUY 2,000,000 PHA shares 2,775,870.00 Net Payable (02/07/2019) 4,403,374.65 Thursday, 7 February 2019 519 Date Ref. No. Transaction Particulars Amount Thursday, 7 February 2019 85595 BUY 2,000,000 PHA shares 2,755,755.00 Net Payable (02/12/2019) 2,755,755.00 Friday, 8 February 2019 520 Date Ref. No. Transaction Particulars Amount Friday, 8 February 2019 85617 BUY 2,000,000 PHA shares 2,517,150.88 Net Payable (02/13/2019) 2,517,150.88 Friday, 1 March 2019 521 Date Ref. No. Transaction Particulars Amount Friday, 1 March 2019 85873 BUY 4,014,000 PHA shares 5,242,602.62 Friday, 1 March 2019 95596 SELL 3,000,000 X shares -4,173,191.98 Net Payable (03/06/2019) 1,069,410.64 Friday, 8 March 2019 522 Date Ref. No. Transaction Particulars Amount Friday, 8 March 2019 64276 C/V Payment of Net Credit Balance 2,965,571.87 Friday, 8 March 2019 85935 BUY 10,000 PNB shares 603,450.00 Due Clearing (03/13/2019) 3,569,021.87 Cr. as of Settlement Date (03/13/2019) -2,965,571.87 Net Payable (03/13/2019) 603,450.00 Thursday, 14 March 2019 523 Date Ref. No. Transaction Particulars Amount Thursday, 14 March 2019 85961 BUY 2,000,000 GREEN shares 5,218,293.65 Due Clearing (03/19/2019) 5,218,293.65 Cr. as of Settlement Date (03/19/2019) -2,606,934.98 Net Payable (03/19/2019) 2,611,358.67 Friday, 22 March 2019 524 Date Ref. No. Transaction Particulars Amount Friday, 22 March 2019 64361 C/V Payment of Net Credit Balance 2,076,761.75 Friday, 22 March 2019 86007 BUY 10,000 BPI shares 893,106.00 Friday, 22 March 2019 95760 SELL 12,000 COL shares -226,506.90 Due Clearing (03/27/2019) 2,743,360.85 Cr. as of Settlement Date (03/27/2019) -2,142,583.14 Net Payable (03/27/2019) 600,777.71 Tuesday, 26 March 2019 525 Date Ref. No. Transaction Particulars Amount Tuesday, 26 March 2019 86028 BUY 2,124,000 SOC shares 3,195,227.54 Tuesday, 26 March 2019 86029 BUY 779,000 SOC shares 1,242,785.15 Tuesday, 26 March 2019 86033 BUY 400,000 SOC shares 643,680.00 Net Payable (03/29/2019) 5,081,692.69 Thursday, 28 March 2019 526 Date Ref. No. Transaction Particulars Amount Thursday, 28 March 2019 86046 BUY 5,000 GSMI shares 145,471.68 Net Payable (04/02/2019) 145,471.68 Wednesday, 24 April 2019 527 Date Ref. No. Transaction Particulars Amount Wednesday, 24 April 2019 85995 BUY 700,000 PXP shares 6,329,399.98 Due Clearing (04/29/2019) 6,329,399.98 Due Clearing (04/29/2019) -423,414.49 Net Payable (04/29/2019) 5,905,985.49 Tuesday, 14 May 2019 528 Date Ref. No. Transaction Particulars Amount Tuesday, 14 May 2019 86218 BUY 7,000,000 PHA shares 6,969,847.51 Net Payable (05/17/2019) 6,969,847.51 Thursday, 23 May 2019 529 Date Ref. No. Transaction Particulars Amount Thursday, 23 May 2019 64856 C/V Payment of Net Credit Balance 997,500.00 Thursday, 23 May 2019 86250 BUY 1,500,000 T shares 1,876,065.70 Due Clearing (05/28/2019) 2,873,565.70 Cr. as of Settlement Date (05/28/2019) -898,534.20 Net Payable (05/28/2019) 1,975,031.50 Monday, 3 June 2019 530 Date Ref. No. Transaction Particulars Amount Monday, 3 June 2019 64915 C/V Payment of Net Credit Balance 2,681,468.14 Monday, 3 June 2019 86300 BUY 3,000 PNB shares 175,603.94 Due Clearing (06/07/2019) 2,857,072.08 Cr. as of Settlement Date (06/07/2019) -2,681,468.14 Net Payable (06/07/2019) 175,603.94 Tuesday, 4 June 2019 531 Date Ref. No. Transaction Particulars Amount Tuesday, 4 June 2019 86305 BUY 1,000 MER shares 392,644.80 Tuesday, 4 June 2019 86306 BUY 3,000 SMC shares 558,492.97 Net Payable (06/10/2019) 951,137.77 Thursday, 13 June 2019 532 Date Ref. No. Transaction Particulars Amount Thursday, 13 June 2019 86329 BUY 50,000 CPM shares 143,319.37 Thursday, 13 June 2019 86333 BUY 70,000 PNB shares 3,881,189.25 Net Payable (06/18/2019) 4,024,508.62 Friday, 14 June 2019 533 Date Ref. No. Transaction Particulars Amount Friday, 14 June 2019 86353 BUY 12,000 CPM shares 34,034.57 Friday, 14 June 2019 86358 BUY 12,000 PNB shares 660,174.30 Friday, 14 June 2019 96204 SELL 1,000 MER shares -378,697.40 Net Payable (06/19/2019) 315,511.47 Wednesday, 19 June 2019 534 Date Ref. No. Transaction Particulars Amount Wednesday, 19 June 2019 86380 BUY 2,000,000 MHC shares 1,508,625.00 Wednesday, 19 June 2019 96226 SELL 20,000 EEI shares -202,393.60 Wednesday, 19 June 2019 96234 SELL 3,000 PNB shares -151,054.01 Wednesday, 19 June 2019 96235 SELL 3,000 SMC shares -521,796.00 Net Payable (06/24/2019) 633,381.39 Friday, 21 June 2019 535 Date Ref. No. Transaction Particulars Amount Friday, 21 June 2019 86402 BUY 2,000 SMC shares 353,706.19 Net Payable (06/26/2019) 353,706.19 Wednesday, 26 June 2019 536 Date Ref. No. Transaction Particulars Amount Wednesday, 26 June 2019 86424 BUY 20,000 BPI shares 1,602,411.20 Due Clearing (07/01/2019) 1,602,411.20 Cr. as of Settlement Date (07/01/2019) -1,133,974.78 Net Payable (07/01/2019) 468,436.42 Friday, 28 June 2019 537 Date Ref. No. Transaction Particulars Amount Friday, 28 June 2019 65084 C/V Payment of Net Credit Balance 1,133,974.78 Friday, 28 June 2019 86441 BUY 5,000,000 ABA shares 5,129,325.00 Due Clearing (07/03/2019) 6,263,299.78 Cr. as of Settlement Date (07/03/2019) - 1,508,063.58 Net Payable (07/03/2019) 4,755,236.20 Thursday, 4 July 2019 538 Date Ref. No. Transaction Particulars Amount Thursday, 4 July 2019 86478 BUY 8,000 ALI shares 415,978.20 Thursday, 4 July 2019 86487 BUY 500,000 PRIM shares 734,197.50 Net Payable (07/09/2019) 1,150,175.70 Friday, 5 July 2019 539 Date Ref. No. Transaction Particulars Amount Friday, 5 July 2019 86495 BUY 1,769,000 PRIM shares 2,888,966.59 Net Payable (07/10/2019) 2,888,966.59 Wednesday, 10 July 2019 540 Date Ref. No. Transaction Particulars Amount Wednesday, 10 July 2019 86520 BUY 5,000 ALI shares 258,226.32 Wednesday, 10 July 2019 86522 BUY 10,000 CPM shares 28,261.57 Net Payable (07/15/2019) 286,487.89 Friday, 12 July 2019 541 Date Ref. No. Transaction Particulars Amount Friday, 12 July 2019 86532 BUY 5,000 ALI shares 263,506.50 Friday, 12 July 2019 86537 BUY 3,770 SMC shares 668,431.51 Friday, 12 July 2019 96428 SELL 500,000 PRIM shares -868,543.28 Net Payable (07/17/2019) 63,394.73 Wednesday, 24 July 2019 542 Date Ref. No. Transaction Particulars Amount Wednesday, 24 July 2019 86604 BUY 15,000 ALI shares 781,467.75 Wednesday, 24 July 2019 86606 BUY 20,000 EW shares 250,230.60 Wednesday, 24 July 2019 86607 BUY 7,000 GSMI shares 408,334.51 Wednesday, 24 July 2019 86616 BUY 5,000 SHLPH shares 191,343.94 Wednesday, 24 July 2019 96507 SELL 500,000 RCI shares -741,187.50 Net Payable (07/29/2019) 890,189.30 Tuesday, 6 August 2019 543 Date Ref. No. Transaction Particulars Amount Tuesday, 6 August 2019 65306 C/V Payment of Net Credit Balance 455,794.37 Tuesday, 6 August 2019 86693 BUY 1,682,000 ABA shares 1,421,004.07 Tuesday, 6 August 2019 86701 BUY 20,000 SHLPH shares 757,329.75 Tuesday, 6 August 2019 96604 SELL 626,000 ABA shares -562,966.49 Due Clearing (08/09/2019) 2,071,161.70 Cr. as of Settlement Date (08/09/2019) -1,160,370.31 Net Payable (08/09/2019) 910,791.39 Thursday, 15 August 2019 544 Date Ref. No. Transaction Particulars Amount Thursday, 15 August 2019 86745 BUY 558,000 ABA shares 477,027.22 Thursday, 15 August 2019 86751 BUY 3,000 GSMI shares 161,404.77 Thursday, 15 August 2019 86755 BUY 20,000 PXP shares 255,862.80 Net Payable (08/20/2019) 894,294.79 Monday, 19 August 2019 545 Date Ref. No. Transaction Particulars Amount Monday, 19 August 2019 86771 BUY 6,043,000 ABA shares 5,149,983.10 Monday, 19 August 2019 86778 BUY 186,500 KPPI shares 1,196,900.84 Monday, 19 August 2019 86779 BUY 181,000 KPPI shares 1,209,622.58 Monday, 19 August 2019 86780 BUY 96,600 KPPI shares 725,868.90 Monday, 19 August 2019 86781 BUY 301,300 KPPI shares 2,272,743.57 Monday, 19 August 2019 96689 SELL 714,500 KPPI shares -5,661,403.56 Monday, 19 August 2019 96690 SELL 47,800 KPPI shares -381,625.57 Monday, 19 August 2019 96691 SELL 3,100 KPPI shares -24,876.24 Net Payable (08/23/2019) 4,487,213.62 Tuesday, 20 August 2019 546 Date Ref. No. Transaction Particulars Amount Tuesday, 20 August 2019 86784 BUY 5,504,000 ABA shares 4,609,714.33 Net Payable (08/27/2019) 4,609,714.33 Thursday, 22 August 2019 547 Date Ref. No. Transaction Particulars Amount Thursday, 22 August 2019 86802 BUY 716,000 ABA shares 590,495.94 Net Payable (08/28/2019) 590,495.94 Tuesday, 27 August 2019 548 Date Ref. No. Transaction Particulars Amount Tuesday, 27 August 2019 86849 BUY 1,970,000 VUL shares 2,833,650.35 Tuesday, 27 August 2019 86850 BUY 252,000 VUL shares 377,639.01 Tuesday, 27 August 2019 96760 SELL 2,122,000 VUL shares -2,785,560.50 Net Payable (08/30/2019) 425,728.86 Monday, 2 September 2019 549 Date Ref. No. Transaction Particulars Amount Monday, 2 September 2019 86903 BUY 2,000 BDO shares 295,690.51 Net Payable (09/05/2019) 295,690.51 Tuesday, 3 September 2019 550 Date Ref. No. Transaction Particulars Amount Tuesday, 3 September 2019 86918 BUY 47,000 CHIB shares 1,228,573.92 Net Payable (09/06/2019) 1,228,573.92 Friday, 20 September 2019 551 Date Ref. No. Transaction Particulars Amount Friday, 20 September 2019 65549 C/V Payment of Net Credit Balance 1,670,163.25 Friday, 20 September 2019 87050 BUY 30,000 CHIB shares 775,433.25 Due Clearing (09/25/2019) 2,445,596.50 Cr. as of Settlement Date (09/25/2019) -1,519,703.55 Net Payable (09/25/2019) 925,892.95 Wednesday, 25 September 2019 552 Date Ref. No. Transaction Particulars Amount Wednesday, 25 September 2019 87066 BUY 2,000 BDO shares 287,242.20 Net Payable (09/30/2019) 287,242.20 Thursday, 26 September 2019 553 Date Ref. No. Transaction Particulars Amount Thursday, 26 September 2019 87074 BUY 200,000 ABA shares 195,115.50 Net Payable (10/01/2019) 195,115.50 Tuesday, 1 October 2019 554 Date Ref. No. Transaction Particulars Amount Tuesday, 1 October 2019 87097 BUY 5,000 GSMI shares 238,910.89 Net Payable (10/04/2019) 238,910.89 Monday, 21 October 2019 555 Date Ref. No. Transaction Particulars Amount Monday, 21 October 2019 87165 BUY 10,000 GSMI shares 479,239.87 Monday, 21 October 2019 87166 BUY 50,000 PHEN shares 143,822.25 Monday, 21 October 2019 87167 BUY 1,800 SECB shares 360,259.65 Monday, 21 October 2019 87168 BUY 30,000 SLI shares 81,164.02 Monday, 21 October 2019 87170 BUY 5,000 CHIB shares 125,718.75 Net Payable (10/24/2019) 1,190,204.54 Tuesday, 22 October 2019 556 Date Ref. No. Transaction Particulars Amount Tuesday, 22 October 2019 87173 BUY 3,000 BPI shares 294,483.60 Tuesday, 22 October 2019 87178 BUY 20,000 VLL shares 154,885.51 Net Payable (10/25/2019) 449,369.11 Thursday, 24 October 2019 557 Date Ref. No. Transaction Particulars Amount Thursday, 24 October 2019 87189 BUY 5,005,000 SUN shares 6,343,104.35 Thursday, 24 October 2019 87190 BUY 2,995,000 SUN shares 4,069,908.17 Net Payable (10/29/2019) 10,413,012.52 Tuesday, 29 October 2019 558 Date Ref. No. Transaction Particulars Amount Tuesday, 29 October 2019 87228 BUY 20,000 ALI shares 981,612.00 Tuesday, 29 October 2019 87231 BUY 10,000 BDO shares 1,531,757.24 Tuesday, 29 October 2019 87232 BUY 5,000 BPI shares 498,097.69 Tuesday, 29 October 2019 87233 BUY 25,000 CHIB shares 636,418.49 Tuesday, 29 October 2019 87241 BUY 20,000 PXP shares 275,575.50 Tuesday, 29 October 2019 87242 BUY 20,000 SHLPH shares 680,892.75 Tuesday, 29 October 2019 87243 BUY 100,000 NIKL shares 417,386.25 Net Payable (11/04/2019) 5,021,739.92 Thursday, 31 October 2019 559 Date Ref. No. Transaction Particulars Amount Thursday, 31 October 2019 87257 BUY 20,000 ALI shares 986,640.74 Net Payable (11/06/2019) 986,640.74 Further, the Terms and Conditions of the Agreements 53 entered into between VSI and Mr. Sulapas during the opening of accounts provide among others, thus: 3. All orders for the purchase of securities on cash basis shall be paid for by me/us within four (4) trading days from the date of execution of my/our order. If not paid within three (3) trading days, any further upward or downward fluctuation in the market price of the securities purchased for me/us shall be for me/our account and risk, until actually sold or disposed of furthermore, you are hereby authorized at your own discretion to sell all or part of my/our securities as may be necessary to cover the unpaid order or balance thereto, without prejudice to my/our liability for any deficiency remaining after the sell-out. Likewise, Item III (H) (1) (j) of VSI written Supervisory Procedures and Compliance Manual 54 provides for the procedures for payment of its clients who purchased shares of stock, thus: "Clients who purchased shares of stocks shall pay on or before T+3. They have the option to pay in cash or check. A messenger is assigned to pick up the payments. The messenger issues a provisional receipt to the client and remits the collection to the cashier. The cashier issues an official receipt and gives it to the messenger for delivery to the client. If a client is too far from the messenger to collect from, to deposit the amount due to any of the Company's bank accounts situated near the client. A copy of the deposit slip is faxed to the Cashier to serve as support to the official receipt to be issued. In case of non-payment of client within T+3, the client is reminded of his dues. If within ten trading days the client has not paid his account, he is given notice that the shares bought will be sold to cover his accountabilities. If after selling the securities the amount is not enough to offset against his debit balance the difference will be for the account of the client." Hence, the Respondents were not justified in applying the credit line and in not liquidating the shares in transactions mentioned above pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. Respondents had the clear obligation to liquidate the shares of stock on the next business day from the settlement date but not beyond ten (10) business days. The reason for the liquidation is that Respondents are forbidden from extending or arranging for the extension of credit to or for Mr. Sulapas in purchasing shares pursuant to the margin requirements under Section 48 of the SRC and Rule 48.2 of the SRC-IRR. The purpose of the margin requirements is to protect the economy from excess stock market speculations and to regulate the volume of credit flow, by way of speculative transactions, into the securities market and redirect resources into more productive uses. 55 Clearly, Respondents VSI and Mr. Racadio were well aware of the consequences of non-payment within three (3) days or T+3 and the unlawful extending of credit to Mr. Sulapas. In fact, Sections 48.2 and 50 of the SRC and SRC Rules 48.2, 48.1 and 50 are very clear and Respondents cannot claim ignorance thereof. Hence, both VSI and Mr. Racadio violated the provision of the SRC and SRC Rules on Prohibition of Extension of Credit and Purchases and Sales in Cash Account. Further, Respondents cannot raise the defense that there is no intention on the part of Mr. Racadio and the rest of the Respondents to evade the requirements for margin accounts under the SRC and the SRC-IRR for the simple reason that the SRC is a special law 56 where intent is not an essential element. Mere violation of which is punishable being a mala prohibita . E. On the Charge for Violation of Rule 34.10 of the 2015 SRC Rules (Adora Aguilar) In the Formal Charge, Complainant charged Respondent Aguilar for violation of Rule 34.10 on the following grounds: 57 1. Julieto Sulapas has a credit line with VSI since 18 August 2015, with a Php40 Million stock position evidenced by the Terms of Credit Line Agreement signed by Racadio and Sulapas. This Credit Line Agreement includes among others provisions for interests and collateral. 2. Although the document was termed as a Credit Line Agreement, it was still classified by VSI as a cash account rather than a margin account to seemingly remove the Julieto Sulapas transactions from the requirements of the SRC and its IRR for margin accounts. 3. The Associated Person has the duty to among others to check all executed trades and other transactions of the company, but Adora Aguilar was clearly remiss on this duty for her failure to properly identify the account of Julieto Sulapas as a margin account and comply with all the requirements of the SRC and its IRR. On the other hand, Respondent Aguilar argues that she cannot be held liable under Rule 34.10 of the SRC-IRR on the following reasons: 58 1. Ms. Aguilar duly supervises all the trades executed by Venture Securities. Ms. Aguilar maintains that the Sulapas Account is a cash account because the existence of a credit line agreement or the charging of interest does not immediately convert the account of Mr. Sulapas into a margin account; 2. Even assuming without conceding that the Sulapas Account is a margin account, the said account complies with all the requirements for a margin account as set forth in Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5 and 48.2.2; 3. Under the terms of the credit line agreement, Mr. Sulapas was allowed to borrow up to 40% of the current market value of his present stock holdings. The amount Mr. Sulapas was allowed to borrow was much lower compared to the limit set under Rule 48.1.1 of the SRC-IRR; 4. Mr. Sulapas was also required to maintain a margin of at least 60% of the current market value of his present stock holdings. This is much higher compared to the minimum amount set in Rule 48.1.2 of the SRC-IRR; 5. Mr. Sulapas settled all "margin calls" made by Venture Securities without any issues; 6. Mr. Sulapas always maintained sufficient collateral on securities in accordance with Rule 48.2.2 of the SRC-IRR. Venture Securities also did not encounter any problems with Mr. Sulapas; 7. Based on the foregoing, there is no intention on the part of Ms. Aguilar and the rest of the Respondents to evade the requirements for margin accounts under the SRC and the SRC-IRR. In order to resolve this issue, the panel shall refer to SRC Rule 34, which states: Rule 34 Segregation and Limitation of Functions of Members, Brokers and Dealers. Sec. 34.10. The Associated Person of a Broker Dealer shall supervise the functions of the employees and check all executed trades and other transactions of the company. As already discussed, we are not in accord with the arguments of Complainant that the Sulapas account is a Margin account and not a cash account. To repeat, the Sulapas Account is a Cash Account and not a Margin Account. Nonetheless, we find that Ms. Aguilar is still in violation of the above-mentioned Rule for her failure to supervise the functions of the employees and check all executed trades and other transactions of the company for the reason that Mr. Sulapas account despite being a Cash Account and not a Margin Account she did not stop the creation and implementation of the credit line in favor of the Sulapas account. F. On the Charge for violation of Rule 30.2.1.2.3.2.2 of the 2015 SRC Rules (VSI, Racadio, Aguilar and Balabis) Complainant alleges that: (i) based on the documents received from VSI, certain "transfer in" requests in the account of Julieto Sulapas lack the signature of Sulapas which is necessary as part of internal control to ensure that it is the client himself who indeed requested the "transfer in"; (ii) the lack of action on the part of VSI, including its Associated Person Aguilar and Salesman Balabis, revealed the lack of satisfactory internal control procedures in the "transfer in" transactions that ultimately led to the successful execution of the fraudulent schemes of Marlo Moron to the detriment of the clients of R&L; and, (iii) Mr. Racadio has failed to perform his duty to oversee the day to day operations of the company including its internal control procedures and financial operational capabilities in compliance with the provisions of the SRC and its IRR. 59 Complainant further alleged that VSI is required to maintain copies of the "Transfer In" Requests in accordance with the SRC-IRR. 60 Respondents countered that VSI, Mr. Racadio, Ms. Aguilar, and Mr. Balabis cannot be held liable under Rule 30.2.1.2.3.2.2 of the SRC-IRR based on the following reasons: 1. Proper internal control measures are present in VSI to safeguard its business and the welfare of all its stakeholders. In accordance with the SRC-IRR, its trading, settlement, accounting, and back office functions are segregated in their respective facilities. CMIC found no material inadequacies in the internal control of VSI or its capacity to safeguard securities; 2. As regards the EQ Trade Transactions, VSI always requires the written signed request of its clients, like Mr. Sulapas, for "trade out" transactions; 3. For "transfer in" transactions, VSI requires a request from the client, whether written or verbal . Additionally, VSI coordinates with its counterpart brokerage firm, such as R&L, to confirm whether the client indeed owns shares held by such counterpart brokerage firm. VSI presumed the regularity of transactions and existence of adequate internal control to comply with the requirements of the SRC-IRR as regards EQ Trade Transactions. VSI relies on CMIC as a watchdog for other brokerage firms to ensure that other brokerage firms also possess the same adequate internal controls. As regards EQ Trade Transactions, VSI presumed that other brokerage firms were only transferring shares from a specific account of a client and that CMIC verifies the completeness and movement of shares and stock positions; 4. VSI also presumed that the EQ trade protocols and authorization requirements under the PCD System, were all complied with on the side of R&L; 5. As the President of VSI, Mr. Racadio ensured that VSI and its employees employ resources and procedures to protect VSI operations and clients, and other registered persons from financial loss arising from theft, fraud and any other dishonest acts. In addition, since Mr. Racadio is not a registered person, he cannot be made liable under Rule 30.2.1.2.3.2.2 of the SRC-IRR; 61 6. Contrary to the allegation in the Formal Charge, the relevant laws and rules do not require a client's signature for "transfer in" requests for purposes of internal control. As long as there is confirmation for "transfer in," whether written or verbal, then the internal control procedures are complied with. In addition, it is "transfer out" requests which requires the signature and written authority of the client pursuant to Section 52.1.1.1.1.2 of the SRC-IRR; 62 7. VSI has its Supervisory Procedures and Compliance Manual and Risk Management Manual which is implemented and observed by all of its employees. Furthermore, VSI ensured that the persons authorized to legally and validly act on behalf of the participant do not know each other, access codes and passwords in compliance with the security requirements of the PCD Rules; 63 8. Even assuming the cited violations against Mr. Balabis and Mr. Aguilar are duly established, the complainant has failed to show in the Formal Charge how these violations are the proximate cause of the losses incurred by the clients of R&L. 64 We agree with the Complainant. SRC Rule Sec. 30.2.1.2.3, provides: Sec. 30.2.1.2.3. Capabilities . A registered person shall have and employ effectively the resources and procedures which are needed for the proper performance of his business activities. xxx xxx xxx 30.2.1.2.3.2. A registered person shall ensure that at all times, pursuant to SRC Rule 30.2.6, he has: 30.2.1.2.3.2.1. Adequate resources to diligently supervise and does diligently supervise his employees and all persons appointed by him to conduct business for or with clients or any other registered persons; and 30.2.1.2.3.2.2. Satisfactory internal control procedures and financial and operational capabilities which can be reasonably expected to protect his operations, his clients and other registered persons from financial loss arising from the theft, fraud and other dishonest acts, or professional misconduct or omissions of all company officers, employees and authorized representatives. Under the Rule, registered persons have a legal and regulatory duty to maintain satisfactory internal control procedures and financial and operational capabilities. In this case, Respondents admitted that, in "transfer in" transactions, VSI requires a request from the client, whether written or verbal allegedly since the relevant laws and rules do not require a client's signature for "transfer in" requests for purposes of internal control. The SRC Rule pertaining to "transfer in" transactions provide: 52.1.1.1. A Broker Dealer shall make, keep current and maintain in its principal office the following books and records relating to its business: xxx xxx xxx 52.1.1.1.1.2. An In/Out Receipts Book setting forth the receipt and delivery of securities to and from other Broker Dealers and securities depository in case of stock dividend distribution, including information on the date of receipt or delivery of the securities to or from Broker Dealers, the In/Out Receipt number, name of security, number of shares, and description of such receipt and delivery of securities ( e.g. , lodgment or upliftment of shares, transfer request by a customer). If the receipt and delivery of shares refer to a transfer of shares by a customer from/to his account with the Broker Dealer to/from his other account with another Broker Dealer, the Broker Dealer should obtain a written transfer request from the customer prior to executing the transfer and keep the document on file. (Emphasis ours) xxx xxx xxx In Rule 52.1.1.1.1.2, it is to be noted that the phrase "receipt and delivery of shares" used two words, namely, "receipt" and "delivery." The word "receipt" means generally accepted while "delivery" means the act or manner of delivering something (Merriam-Webster Dictionary). Also, the transfer of shares by a customer use the preposition "from"/"to" and "to"/"from." "From" is used as a function word to indicate the starting or focal point of an activity while "to" is used as a function word to indicate movement or an action or condition suggestive of movement toward a place, person, or thing reached (Merriam-Webster Dictionary). In other words, the word "receipt" simply connotes "to accept" and the word "deliver" means "to send." On the other hand, the preposition "from" means "the origin" while "to" is "the destination." Thus, the rule requiring written transfer request from the customer prior to executing the transfer covers both the "transfer in" and "transfer out" transactions. Clearly, Respondents Aguilar and Balabis failed to comply with the requirements of the above-mentioned rule when they did not get Mr. Sulapas written request for the "transfer in" transactions. Besides, in determining the Respondent's liability, it is necessary to establish whether the Respondents have complied with three factors pertaining to VSI internal control procedure, specifically the VSI's Supervisory Procedures and Compliance Manual and Risk Management Manual (Annexes 12 and 13 Respondents Position Paper), as follows: 1) Whether VSI established a "satisfactory" internal supervisory procedure 2) Whether VSI implemented and maintained this procedure 3) Whether VSI adequately acted upon and investigated the "red flags" Here, it was established by VSI that it had a reasonable supervisory control procedure in place that may adequately enforce all the SEC Rules and applicable securities laws and regulations. However, in addition to establishing an adequate supervisory control procedure, VSI, Mr. Racadio. Ms. Aguilar, Mr. Balabis and its officers and employees concerned are required to adhere, implement and maintain the provisions of their procedure. In this case, we found that Respondents failed to maintain and implement the internal supervisory procedures when they did not require written authorization of Mr. Sulapas in the execution of the "transfer in" transactions. Respondents failure to implement these policies in a reasonable manner renders them liable for the prohibited activities and in effect have allowed the suspicious activities to occur. VSI and Racadio may also be held liable under the Rule for their failure to act on the unauthorized activities. Here, the question is not whether VSI or Racadio should have known of the unauthorized activity, but rather if they attempted to intervene and investigate. Their repeated failures to thoroughly investigate their registered representatives unauthorized activities paved the way to cause to defraud investors through the unauthorized transfers of securities. Accordingly, as a result of the unauthorized act of the registered persons and upon the VSI and Racadio's failure to act upon the cumulative red flags, we found VSI and Racadio liable under the Rule for their failure to act and by not conducting an investigation on the illegal activities and occurrences. Any activities in violation of the SRC and its IRR which were not detected and acted upon may be considered as sufficient ground for their liability. VSI and Racadio are required to monitor for all instances of unauthorized activities and securities transactions and to act upon them accordingly. Further, contrary to the claim of Mr. Racadio that he is not liable under the Rule since he is not a registered person, he would likewise be liable under the Rule as a control person based on his failure to supervise VSI registered representatives. With respect to the contention of the Respondents that VSI relies on CMIC as a watchdog for other brokerage firms to ensure that other brokerage firms also possess the same adequate internal controls and its presumption that the EQ trade protocols and authorization requirements under the PCD System were all complied with on the side of R&L is inconsequential for the simple reason that the requirement of the Rule is mandatory and the Respondents are strictly obliged to comply. To note, the SRC and its IRR are to be read into the Supervisory Procedures of VSI. Compliance with Supervisory Procedures necessarily means compliance with the laws. Thus, to determine whether the Respondents fulfil their obligation under the law, the Commission had to pass upon their compliance with VSI Supervisory Procedures and the Rules. Clearly, Respondents VSI, Racadio, Aguilar and Balabis, were gravely remiss on their duties in failing to observe their mandates under the SRC Rule with respect to the Capabilities, thereby negating the function imposed on them by SRC Rule 30.2.1.2.3. G. On the Charge for Violation of Rule 52.1.1.1.1.2 of the 2015 SRC Rules (VSI, Racadio and Mosenabre) In this charge, the Complainant alleges that: 65 1. A review on the documents in relation to the Julieto Sulapas account in VSI revealed that certain "transfer out" in the account of Julieto Sulapas lacks written request. 2. A review of the Julieto Sulapas account ledgers with VSI also revealed that there are discrepancies on the number of shares between the Stock (In) CM, the Julieto Sulapas ledgers and the EQ Trade Form. 3. These observations reveal that VSI fails to maintain and keep current complete sets of its books and records in violation of the Securities Regulation Code and its Implementing Rules and Regulations. 4. The President of VSI Wilfred Racadio has the duty to oversee the day to day operations of the broker dealer, including the proper monitoring and maintenance of its books and records. The lack of accurate and complete books and records shows the failure of VSI to comply with the requirements under the SRC and ultimately the neglect of Wilfred Racadio of his duty to oversee the day to day operations of the company. In their Answer Respondents countered: 66 1. VSI, Mr. Racadio, and Ms. Mosenabre likewise cannot be held liable for violating Rule 52.1.1 relating to Rule 52.1.1.1.1.2. of the SRC-IRR mandating that the Broker Dealer make, keep current and maintain in its principal office the In/Out Receipts Book of its clients; 2. Mr. Racadio and Ms. Mosenabre ensured that the records of transactions of the clients of Venture Securities are complete in the Company's files. These records were periodically and consistently submitted to the CMIC and to the external auditor for annual audits. In addition, since Mr. Racadio and Ms. Mosenabre are not registered persons, they cannot be made liable under the above stated SRC-IRR Rules; 3. As regards the Sulapas Account, all of the "transfer out" requests of Mr. Sulapas have a written request from him as shown by the previous submissions to this Honorable Office. In addition, there are no discrepancies on the number of shares between the Stock (In) CM, the Julieto Sulapas ledgers and the EQ Trade Form, as can be seen on the previous submissions to this Honorable Office; 4. Based on the foregoing, there is no basis to state that VSI, Mr. Racadio, and Ms. Mosenabre do not maintain the proper records in the principal office of Venture Securities. In its Position Paper, 67 Complainant insists that certain "transfer out" request in the account of Julieto Sulapas lacks written request because certain signatures of Sulapas appearing in the EQ Trade Forms attached as Annex "I" appear to be exactly the same. In addition, Mr. Julieto Sulapas also personally denied such signatures in his Supplemental Affidavit to wit: "xxxiv. Na matapos lumabas sa publiko ang mga naganap sa R&L Investments, kinontak ako ni Krystel at tinanong kung puede ba akong magpunta ng Venture Securities upang magpirma ng mga dokumento dahil nasa audit sila. Umoo ako at dalawang beses kaming nagkita ni Krystel sa Jollibee malapit sa opisina ng Venture Securities upang magpirma ng nasa isandaang dokumento, at ilang mga blankong papel. Pinapirmahan po sa akin ang mga blankong dokumento para daw hindi ko na kailanganin na bumalik ulit. Natatandaan ko na ilan sa mga dokumentong pinapirma sa akin ay mga EQ Trade Forms. Habang tinitingnan ko po ang mga dokumento, napapansin ko na parehong pareho yung mga pirma ko. Tingin ko ay kinopya lamang ang mga naturang pirma sapagkat imposible na maging magkaparehong magkapareho ang mga ito." In their Reply, 68 Respondents pointed out the following: 1. Mr. Sulapas affixed his signature in the written authorities that he executed for his "transfer out" requests as can be seen in Annex "8"-Series of Respondents Position Paper. 2. Annex "I" of the Complainant's Position Paper does not refer solely to "transfer out" requests of Mr. Sulapas. Nevertheless, the signatures appearing in Annex "I" belong to Mr. Sulapas as can be seen in Annexes "2" and "2-A" of Respondents' Position Paper. 3. Complainant appears to be implying that the signatures of Mr. Sulapas in Annex "I" are forged without providing any evidence to support such allegation. 4. The statements of Mr. Sulapas in his Supplemental Affidavit are of doubtful accuracy as they are filled with numerous inconsistencies. Moreover, the narration of events cited portion of his Supplemental Affidavit in paragraph 6.56 of Complainants position paper is incoherent because it appears that he immediately forgot the signature that he affixed on documents that he had just allegedly signed. 5. The statements of Mr. Sulapas in his Sinumpaang Salaysay and Supplemental Affidavit cannot be used against Respondents in this case under the doctrine of res inter alios acta as embodied under Section 31, Rule 130 of the Rules of Court. Complainant is trying to implicate the respondents in the conspiracy between Mr. Sulapas and Mr. Moron without showing any evidence that they are part of said conspiracy aside from the affidavit of Mr. Sulapas. 6. The Commission cannot use the affidavits of Mr. Sulapas as basis to penalize any of the Respondents. The doctrine of res inter alios acta alteri nocere debet prevents such use of the admissions made by a co-conspirator, and as seen in the case of Office of the Ombudsman v. Mislang , said doctrine finds application even in administrative cases. Likewise, Complainant in its Position Papers 69 maintains that there are discrepancies in the number of shares in the Stock (In) CM and EQ trade Forms of Julieto Sulapas based on the Attached documents in Annex "J" thereof. In their Reply, 70 Respondents admitted that the discrepancies in the number of shares in the Stock (In) CM and EQ Trade Forms of Julieto Sulapas are minimal and not indicative of bad faith. This panel finds that Respondents violated of the above-mentioned Rule of SRC-IRR. The said Rule provides that: Sec. 52.1.1. Books and Records Rule . Sec. 52.1.1.1. A Broker Dealer shall make, keep current and maintain in its principal office the following books and records relating to its business: xxx xxx xxx Sec. 52.1.1.1.1.2. An In/Out Receipts Book setting forth the receipt and delivery of securities to and from other Broker Dealers and securities depository in case of stock dividend distribution, including information on the date of receipt or delivery of the securities to or from Broker Dealers, the In/Out Receipt number, name of security, number of shares, and description of such receipt and delivery of securities ( e.g. , lodgment or upliftment of shares, transfer request by a customer). If the receipt and delivery of shares refer to a transfer of shares by a customer from/to his account with the Broker Dealer to/from his other account with another Broker Dealer, the Broker Dealer should obtain a written transfer request from the customer prior to executing the transfer and keep the document on file. The afore-quoted provision, which is also known as the "Books and Records Rule" require a Broker Dealer to make, keep current and maintain books and records relating to the business transaction of the company. After a careful review of the arguments and position of the parties, the panel while without discounting the possibility of the claim of Mr. Sulapas that the signatures appearing in the EQ Trade Forms was not his, still finds the Respondents to have violated the above-mentioned Rule. As already discussed above, the fact that the "Transfer In" request in EQ Trade requires authorization by the client coupled with the admission of Respondents that there are discrepancies in the number of shares in the Stock (In) CM and EQ Trade Forms are more than sufficient evidence to prove the violation. The claim of Respondents that the discrepancies in the number of shares in the Stock (In) CM and EQ trade Forms of Julieto Sulapas are minimal and not indicative of bad faith is not an excuse since compliance of the Rule is mandatory. Besides, we noted that the discrepancies are not just minimal as they represent substantial figures pertaining to the number of shares as illustrated below. Date Reference Stock No. of Stock per Stock Record Per EQ Trade Form Difference 03/05/2019 SCM 11100 PIZZA 15,000 150,000 (135,000) 06/09/2018 SCM 10893 BDO 100,000 50,000 50,000 16/08/2018 SCM 10602 GSMI 30,000 27,600 2,400 18/01/2019 SCM 11014 CHIB 15,000 3,000 12,000 18/01/2019 SCM 11014 ABS 15,000 10,000 5,000 06/08/2019 SCM 11175 EAGLE - 2,000 (2,000) 10/01/2019 SCM 11010 SECB 3,000 30,000 (27,000) 10/01/2019 SDM 5607 MER 2,000 3,000 (1,000) Finally, the panel will no longer discuss the issue on res inter alios acta raised by Respondents in this issue in view of our discussion above pertaining on the matter. Verily, Ms. Mosenabre as the Settlement Officer of VSI has failed on her obligation to verify the completeness of the EQ Trade transactions including the written authorizations of Sulapas. As such, she is liable for violation of the Rule pursuant to Section 52.2 of the SRC which provides that "it shall be unlawful for any person, directly, or indirectly, to do any act or thing which it would be unlawful for such person to do under the provisions of this Code or any rule or regulation thereunder." On the other hand, VSI and Mr. Racadio failed to perform their duty to implement VSI compliance procedures for the proper monitoring and maintenance of its books and records. H. On the charge for violation of Section 26 in relation to Section 54 of the Securities Regulation Code (Aguilar, Balabis and Mosenabre) In the Formal Charge, Complainant alleges, that: 71 1. During the investigation it was discovered that (i) Loreto Balabis did not personally meet Julieto Sulapas at the time the latter opened an account with VSI and (ii) Sulapas was referred to him by Marlo Moron, one who Loreto Balabis knows, is an employee of R&L Investments, another broker dealer. 2. The documents received from VSI showed that Loreto Balabis, who processed most of the transactions of Julieto Sulapas in Venture, did not make any inquiry or verification as to the transactions of Julieto Sulapas, despite the large amounts involved (roughly PhP10 billion in total from 2012 to 2019, per CMIC Report) in relation to the total net worth, liquid net worth and annual income declared in the CAIF of less than PhP1,000,000.00. 3. Despite all of these circumstances that should have caught his attention on guard, Loreto Balabis did not bother to check the disproportionate transactions pertaining to the account of Julieto Sulapas. This blatant disregard of his duties as a salesman under the law ultimately resulted to the loss of R&L clients' investments. 4. Given the large amounts and volume of transactions which were grossly disproportionate to the declared total net worth, liquid net worth and annual income of Julieto Sulapas, the Associated Person Adora Aguilar likewise did not conduct any inquiry, verification and review of the Julieto Sulapas account transactions. 5. It was also admitted by Adora Aguilar during the investigative proceedings that she knew Marlo Moron was the trading floor assistant/settlement clerk of R&L. Yet, Adora Aguilar still allowed Marlo Moron to be the authorized person of Julieto Sulapas to transact relating to the latter's account with Venture. 6. Adora Aguilar, as the Associated Person, has the duty to ensure the compliance of the broker dealer under the provisions of the Securities Regulation Code and its Implementing Rules and Regulations. The same duty is also specifically indicated under the terms and conditions of her license. In this case, the inaction of Adora Aguilar and her failure to review and verify the credentials and financial position of Julieto Sulapas such as the disproportionate transaction amounts from Sulapas declared total net worth, liquid net worth, annual income, the circumstances of his engagement with Venture, and the overarching authority granted by Sulapas to Marlo Moron, were flagrant violations of the basic principle of Risk Management. Clearly, she blatantly disregarded to perform her duties under the SRC and her license. 7. Teresita Mosenabre, as the settlement officer of VSI should have also looked into the EQ trade transactions. Despite the large volume of EQ trades, she did not make any inquiry into the Julieto Sulapas transactions. Further, she admitted during the investigative proceedings that she confirmed the EQ trade transfers of Julieto Sulapas, knowing that Marlo Moron is the settlement officer of R&L, and is the authorized person of Julieto Sulapas at the same time. 8. The above discussed circumstances reveal the gross inexcusable negligence of Venture Securities officers and employees to perform the duties entrusted to them by law in connection with the Julieto Sulapas account amounting to bad faith. Hence, they may be held liable under Section 26 of the SRC and Rule 26.1 of its 2015 SRC-IRR. In their defense, Respondents Aguilar, Balabis and Mosenabre denied the accusation against them in the Formal Charge and alleged that: 72 1. Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre cannot be held liable under Section 26 of the SRC and Rule 26.1 of the SRC-IRR because they did not engage in any fraudulent transactions as defined therein; 2. The circumstances described in the Formal Charge do not show that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre directly or indirectly (i) employed any device, scheme, or artifice to defraud, (ii) obtained money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading, (iii) engaged in any act, transaction, practice or course of business which operates or would operate as a fraud or deceit upon any person; 3. It is clear that in order to be liable for a Fraudulent Transaction under Section 26 of the SRC and Rule 26.1 of the SRC-IRR, there must be an intentional act committed by the alleged perpetrators: The Formal Charge failed to show the specific acts of Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre amounting to any of the Fraudulent Transactions described under Section 26 of the SRC and Rule 26.1 of the SRC-IRR; 4. Neither is there any allegation in the Formal Charge that Ms. Aguilar, Mr. Balabis and/or Ms. Mosenabre are in conspiracy with the alleged fraudulent schemes of Mr. Moron and Mr. Sulapas; 5. The Supreme Court in Spouses Ramos v. Obispo , G.R. No. 193804, 27 February 2013 states that was to fraud, the rule is that he who alleges fraud or mistake affecting a transaction must substantiate his allegation, since it is presumed that a person takes ordinary care of his concerns and that private transactions have been fair and regular. The (Supreme) Court has stressed time and again that allegations must be proven by sufficient evidence because mere allegation is definitely not evidence"; 6. In this case, there are no allegations and no evidence showing that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre engaged in any of the Fraudulent Transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR. The Formal Charge does not even identify that transactions that they consider as "fraudulent transactions" under said provisions; 7. Even assuming that the gross and inexcusable negligence can be the basis to commit a fraudulent transaction under Section 26 of the SRC and Rule 26.1 of the SRC-IRR, Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre did not commit gross and inexcusable negligence in the performance of their duties; 8. As already discussed above, Mr. Balabis only handed an account opening form to Mr. Moron, which the latter requested for Mr. Sulapas. Account opening forms of other broker dealers can be freely downloaded over the internet. The account of Mr. Sulapas was not created during this time. There was no omission on the part of Mr. Balabis because the account of Mr. Sulapas was created at the time he personally visited the office of Venture Securities. The identity of Mr. Sulapas was properly verified by Venture Securities; 9. The transactions of Mr. Sulapas did not elicit any suspicions on the part of Ms. Aguilar and Mr. Balabis because they are in line with his established trading profile with Venture Securities. From 2012-2019, Mr. Sulapas was an active trader, and he would execute numerous buy and sell transactions during the trading day, buying and selling the shares with the most trading action. The average value of his daily transactions fit his declared total net worth, liquid net worth, and annual income. More importantly, Mr. Sulapas was also a knowledgeable trader, and he was to sustain his numerous buy and sell transactions almost entirely from his trading activities. There were no omissions on their part to find the transactions of Mr. Sulapas as suspicious because these transactions fit the latter's trading profile; 10. The fact that Mr. Moron was an authorized person of Mr. Sulapas did not elicit any suspicions because there is no prohibition for Mr. Moron, as the trading floor assistant/settlement of R&L, to be authorized to transact Mr. Sulapas account with Venture Securities. Moreover, Mr. Moron was not granted any special or unusual authority other than the usual authority given by other clients to their authorized representatives. In addition, it was Mr. Sulapas who primarily gave instructions to Venture Securities for his account. There was no omission on the part of Ms. Aguilar to be suspicious on the authority granted to Mr. Moron because of the foregoing reasons; 11. Ms. Mosenabre monitored the EQ trade transactions of Mr. Sulapas from 2012 to 2019, and she found the volume of his EQ trades to be consistent with his established trading profile. Furthermore, she relied on the presumption that R&L followed the necessary protocols and internal control regarding "transfer out" requests such as the one present in Venture Securities. Whenever Ms. Mosenabre called R&L to discuss and/or confirm EQ trade transactions, it was only Mr. Moron who was available to answer her inquiries; 12. As discussed, there is no basis to state that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre committed gross and inexcusable negligence that would amount to bad faith. These employees of Venture Securities were performing their duties and responsibilities as mandated by law and in accordance with the Rules. Any fraudulent transaction originated and was consummated inside R&L, and the employees of Venture Securities are not participants in any of it; 13. Based on the foregoing, there is no basis to find Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre liable for any fraudulent transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR and to be penalized under Section 54 of the SRC. The panel finds the submissions of Respondents meritless. Based on the discussion above, it is undisputable that: (1) Mr. Balabis was not present during the Sulapas account opening but he still signed the CAIF. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00 but he was allowed to transact beyond his declared financial capacity. (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L. (4) Respondents failed to require Mr. Sulapas to update his CAIF. (4) n Respondents allowed the execution of EQ Trades without the written authorization from Mr. Sulapas. (5) Respondents unlawfully granted Credit Line to Sulapas account despite the fact that it is not a Margin Account. (6) As Cash Account, Respondents failed to liquidate the shares in numerous transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. Section 26 in relation to Section 54 of the SRC, provides: "SEC. 26. Fraudulent Transactions. It shall be unlawful for any person, directly or indirectly, in connection with the purchase or sale of any securities to: 26.1. Employ any device, scheme, or artifice to defraud; 26.2. Obtain money or property by means of any untrue statement of a material fact of any omission to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; or 26.3. Engage in any act, transaction, practice or course of business which operates or would operate as a fraud or deceit upon any person. (SRC) Sec. 54. Investigative Sanctions SEC. 54. Investigative Sanctions. 54.1. If, after due notice and hearing, the Commission finds that: (a) There is a violation of this Code, its rules, or its orders; xxx xxx xxx it shall, in its discretion, and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances: (i) Suspension, or revocation of any registration for the offering of securities; (ii) A fine of no less than Ten thousand pesos (P10,000.00) nor more than One million pesos (P1,000,000.00) plus not more than Two thousand pesos (P2,000.00) for each day of continuing violation; (iii) In the case of a violation of Sections 19.2, 20, 24, 26 and 27, disqualification from being an officer, member of the Board of Directors, or person performing similar functions, of an issuer required to file reports under Section 17 of this Code or any other act, rule or regulation administered by the Commission; (iv) In the case of a violation of Section 34, a fine of no more than three (3) times the profit gained or loss avoided as a result of the purchase, sale or communication proscribed by such Section; and (v) Other penalties within the power of the Commission to impose. 54.2. The imposition of the foregoing investigative sanctions shall be without prejudice to the filing of criminal charges against the individuals responsible for the violation." Section 26 of the SRC makes it unlawful for any person in the offer or sale of any security "(1) to employ any device, scheme, or artifice to defraud, or (2) to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact . . ., or (3) to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon any person." A perusal of the Formal Charge will readily reveal that the Complainant is pointing to Section 26 (3) of the SRC as the provision violated by the Respondents, it appearing that the allegations involves a transaction, practice, or course of business which operates or would operate as a fraud or deceit upon any person. It is quite clear in Section 26 (3)'s language, "to engage in any transaction, practice , or course of business which operates or would operate as a fraud or deceit ," that it plainly focuses upon the effect of particular conduct on members of the investing public, rather than upon the intent or culpability of the person responsible . In other words, for violation of this Section a showing of deliberate intent to defraud is not required as a condition precedent to protecting investors. The Respondents should not get away from the consequences of their several and repeated wrongful and unlawful acts involving huge amounts of securities transactions for dishonest purpose or moral obliquity, which resulted to the prejudice and damage of investors. In the present case, we found that the Respondents repeatedly, consciously and intentionally, for several years (2012 to 2019) , failed and ignored to comply with the pertinent regulations and provisions of the SRC and its IRR. The acts of the Respondents are conscious and intentional to do wrongful acts. These acts undoubtedly show evident bad faith on the part of the Respondents. These acts are not just mere gross inexcusable negligence amounting to bad faith as stated by the Complainant. Based on Section 26.3 of the SRC, "fraud" is akin to bad faith, which implies a conscious and intentional design to do a wrongful act for a dishonest purpose or moral obliquity. Thus, in Securities and Exchange Commission v. Honorable Court of Appeals, et al. , 73 the Honorable Supreme Court held: "To constitute, however, a violation of the Revised Securities Act that can warrant an imposition of a fine under Section 29(3) [now Section 26(3) of the SRC] , in relation to Section 46 of the Act, fraud or deceit, not mere negligence, on the part of the offender must be established. Fraud here is akin to bad faith which implies conscious and intentional design to do a wrongful act for a dishonest purpose or moral obliquity; it is unlike that of the negative idea of negligence in that fraud or bad faith contemplates a state of mind affirmatively operating with furtive objectives . x x x" (Underscoring supplied) It is worthy to mention that transactions involving securities are impressed with public interest, and are thus subject to strict public regulation. In the same case of Abacus , the Honorable Supreme Court held: " Stock market transactions affect the general public and the national economy. The rise and fall of stock market indices reflect to a considerable degree the state of the economy. Trends in stock prices tend to herald changes in business conditions. Consequently, securities transactions are impressed with public interest and are thus subject to public regulation . In particular, the laws and regulations requiring payment of traded shares within specified periods are meant to protect the economy from excessive stock market speculations, and are thus mandatory." (Underscoring supplied) As to Respondents allusion to the case of Spouses Ramos v. Obispo 74 we find the same unavailing. In this case, the Supreme Court states that "as to fraud, the rule is that he who alleges fraud or mistake affecting a transaction must substantiate his allegation, since it is presumed that a person takes ordinary care of his concerns and that private transactions have been fair and regular. The (Supreme) Court has stressed time and again that allegations must be proven by sufficient evidence because mere allegation is definitely not evidence. Moreover, fraud is not presumed it must be proved by clear and convincing evidence." In the case of Republic of the Philippines vs. Mega Pacific Esolutions, Inc., et al. , 75 the Supreme Court ruled that: While fraud cannot be presumed, it need not be proved by direct evidence and can well be inferred from attendant circumstances. Fraud by its nature is not a thing susceptible of ocular observation or readily demonstrable physically; it must of necessity be proved in many cases by inferences from circumstances shown to have been involved in the transaction in question. In the case at bar, Complainant has sufficiently discharged the burden of demonstrating the commission of a conscious and intentional design to do a wrongful act amounting to bad faith by the Respondents pertaining to the Sulapas account transactions. Here, Respondents Aguilar and Balabis are liable for fraud due to their evident bad faith in doing the above-mentioned wrongful acts for dishonest purpose or moral obliquity which is tantamount to fraud for purposes of Section 26 (3) of the SRC, to the prejudice of the investors. Anent the matter on authorizing Marlo Moron to be the authorized person of Julieto Sulapas to transact relating to the latter's account with VSI, while it may be true that Respondents did not elicit any suspicions because there is no prohibition for Mr. Moron, being the trading floor assistant settlement officer of R&L, to be authorized to transact Mr. Sulapas account with VSI, yet the glaring fact is that whenever Ms. Mosenabre called R&L to discuss and/or confirm EQ trade transactions, it was only Mr. Moron who was available to answer her inquiries. Certainly, Ms. Aguilar do not dispute that she knew Mr. Moron was the trading floor assistant/settlement clerk of R&L. That fact is suspicious in itself, and should alert all VSI officers and employees genuinely minded in pursuing good and best practices in securities transactions not to ignore such fact in their course of action. Indeed, the Respondents' act of allowing Mr. Moron as the authorized person to transact on Mr. Sulapas Account with VSI and the person who will discuss and/or confirm the EQ trade transactions from R&L with them at the same time without eliciting any suspicions, were unnatural to be believable and contrary to human experience. In this situation, the more natural thing for them to do after knowing that Mr. Moron is the authorized person and the person who will also confirm the transaction at the same time, would be to verify the legitimacy of the transactions with other employees or officers of R&L. Besides, it may be worth noting that Mr. Sulapas in paragraph 3 (xxi) of his Supplemental Affidavit alleges that he does not remember authorizing Mr. Moron to execute trade transactions in his name although he acknowledges that he signed a document without reading the contents thereof. Given the circumstances, we have sufficient basis to believe that there is thus a doubt as to the execution of the authorization. As regards Ms. Mosenabre, she would likewise be liable under Section 26 of the SRC pursuant to Section 51.2 of the SRC which provides that "it shall be unlawful for any person, directly, or indirectly, to do any act or thing which it would be unlawful for such person to do under the provisions of this Code or any rule or regulation thereunder." As mentioned above, as the Settlement Officer of VSI, she has failed on her obligation to verify the completeness of the EQ Trade transactions including the written authorizations of Mr. Sulapas. Her failure to perform her obligation resulted to the prejudice of the investors. From the foregoing and based on our previous discussions, Respondents Aguilar, Balabis and Monsenabre are found to have violated Section 26.3 in relation to Section 54 of the SRC. I. On the Charge for violation of Section 51 in relation to Section 26 of the Securities Regulation Code (Wilfred Racadio) In the Formal Charge, Complainant is accusing Mr. Racadio for violation of Section 26 of the SRC on the following reasons: 76 1. The officers and employees of VSI glaringly failed to perform their duties in connection with the transactions of the Julieto Sulapas accounts, amounting to bad faith, and 2. As president, he has the duty to oversee the day-to-day operations of the company. Apparently, he failed to perform his duties in this case. Applying Section 51 of the Securities Regulation Code makes Wilfred Racadio jointly and severally liable with Venture Securities officers and employees. In the Answer, Mr. Racadio disputed the accusations and alleged, that: 77 1. There is also no basis to find Mr. Racadio liable under Section 51.1 in relation to Section 26 of the SRC; 2. Based on the allegations in the Formal Charge, Mr. Racadio has not controlled any person liable under the SRC or the SRC-IRR through stock ownership, agency, or otherwise, or in connection with any agreement or any understanding in connection with the commission of any of the fraudulent transactions in Section 26 of the SRC; 3. It appears from the Formal Charge that the commission of the fraudulent transactions originated and was consummated inside R&L. Mr. Racadio does not control the actions of Mr. Moron in any way. Mr. Moron is not an employee of Venture Securities, and Mr. Racadio does not personally know Mr. Moron. Mr. Racadio also does not control the actions of Mr. Sulapas in any way. Mr. Sulapas is a client of Venture Securities, and he executed all his trades based on his own knowledge, judgment, and funds. There are not even any allegations of conspiracy among Mr. Racadio, Mr. Moron, and Mr. Sulapas; 4. There are no specific acts of Mr. Racadio in the Formal Charge showing that he controlled Mr. Moron and/or Mr. Sulapas to commit any of the fraudulent transactions described under the SRC; 5. In addition, Mr. Racadio is not covered by Section 51.1 of the SRC because he does not control Ms. Aguilar, Mr. Balabis, and/or Ms. Mosenabre "by or through stock ownership, agency, or otherwise or in connection with an agreement or understating." Moreover, assuming without admitting that he is covered by Section 51 of the SRC, Mr. Racadio has exercised due diligence in the performance of his duties, including but not limited to making sure that the proper and sufficient internal control systems and procedures were in place, and despite this he had no knowledge of facts by reason of which the other Respondents would be guilty of bad faith much less of fraud. As discussed in the previous section, there is no basis to state that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre committed gross and inexcusable negligence that would amount to bad faith; 6. Based on the foregoing, there is no basis to find Mr. Racadio for any fraudulent transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR under Section 51.1 of the SRC. We are not persuaded by Mr. Racadio's arguments. The liability of Mr. Racadio is more straightforward. First, he unlawfully approved the Credit Line for Sulapas' account amounting to up to 40% the value of his alleged stock position equivalent to Php44,639,825.00 despite the fact that the Sulapas account is not a Margin Account but a Cash Account and notwithstanding the obvious warning sign that Sulapas' Financial capacity per his CAIF is only Php1,000,000.00. Thus, he intentionally failed to observe his fiduciary duty when he approved the credit line facility to Mr. Sulapas. Had he fulfilled his fiduciary duty, the above circumstances would have cautioned him from approving the credit line. As the President and member of the board of directors, it is incumbent upon him to have been more circumspect in approving the prohibited credit line facility. Second, Respondent Racadio did not liquidate the shares on numerous transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares transactions within three (3) business days from the transaction date. Respondents, including Racadio had the clear obligation to liquidate the shares of stock on the next business day from the settlement date but not beyond ten (10) business days. The reason for the liquidation is that VSI and Racadio are forbidden from extending or arranging for the extension of credit to or for Mr. Sulapas cash account in purchasing shares pursuant to the margin requirements under Section 48 of the SRC and Rule 48 of the IRR. Third, the fact that Respondent Racadio signed the multiple checks lower than Five Hundred Thousand Pesos (Php500,000.00) and prepared for the same day do not discount his participation to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council. Respondent Racadio's liability under Section 26 (3) of the SRC is also laid bare by the following facts as discussed above: 1. Allowing Mr. Sulapas to transact in his securities transactions beyond his financial capacity on numerous occasions. 2. Failure to maintain and implement the corporation's internal supervisory control procedures. 3. Failure to discharge his supervisory and control responsibility to stop the illegal activities of his subordinates. To our mind, this only goes to show that Mr. Racadio would be liable for fraud in his bad faith in consciously doing the above-mentioned wrongful acts for dishonest purpose or moral obliquity which is tantamount to fraud within the contemplation of Section 26 (3) of the SRC, to the prejudice of the investors. As a director and president of VSI, he holds a fiduciary relation to the corporation, stockholders and other stakeholders. On this, he should exercise not only care and diligence but utmost good faith and fair dealings in the management of the corporate affairs in the interest of the corporation and investors. Thus, Respondent Racadio should be held liable for his wrongful acts, which resulted, to the prejudice and damage of the investors. J. On the Charge for violation of Rules 30.2.6.1 and 30.2.6.3 of the 2015 SRC Rules (Racadio and Aguilar) In the Formal Charge, Complainant alleged that: 78 1. As an Associated Person, Adora Aguilar's primary duty includes overseeing the operations of the company and the supervision of its employees. 2. However, the following circumstances show lapses in employing effective compliance functions in Venture Securities by the Associated Person Adora Aguilar: a. Inaccuracies in the CAIF of Julieto Sulapas, including the failure to indicate his other accounts with another brokerage firm; b. Improper classification of Julieto Sulapas account as cash account instead of margin account, despite the existence of a credit line agreement; c. Lack of further inquiry as to the large amount of stock transactions of Julieto Sulapas way beyond his declared annual income in the CAIF; and, d. There were transfers of shares that were not supported with written instructions signed by Sulapas. 3. Likewise, the President Wilfred Racadio has the duty to oversee the day-to-day operations of VSI, including its internal controls. However, the inaccuracies in the CAIF, the improper classification of the Julieto Sulapas account, the lack of inquiry as to the large transactions involved and the lack of written instructions to transfer show the neglect and failure Wilfred Racadio to perform his duties as president to implement proper internal control procedures. In their answer, Respondents countered: 79 1. Mr. Racadio and Ms. Aguilar likewise cannot be held liable for violating Rule 30.2.6.1 and Rule 30.2.6.3 regarding the compliance functions inside Venture Securities; 2. As already discussed above, the numerous amount of buy and sell transactions of Mr. Sulapas are in accordance with his trading profile. Moreover, Mr. Racadio and Ms. Aguilar has determined that Mr. Sulapas is able to sustain funding for his transactions almost entirely from his trading activities. Thus, it was well within his financial capacity enter to into this amount of transactions; 3. As discussed above, Ms. Aguilar repeatedly required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead, Venture Securities just duly noted that Mr. Sulapas has another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as fraudulent; 4. Mr. Racadio and Ms. Aguilar ensured all of the "transfer out" requests of Mr. Sulapas are in writing and signed by him. As regards "transfer in" requests, there is no requirement under the relevant laws and rules for a written request duly signed by the client for "transfer in" requests; 5. Lastly, Mr. Racadio and Ms. Aguilar properly classified the account of Mr. Sulapas as a cash account. We agree with the Complainant. SRC Rule Section 30.2.6 requires the management of Broker Dealer to establish and maintain an appropriate and effective compliance function within the firm which is independent of all operational and business functions. The relevant portion of the quoted provision, provides: 30.2.6. Supervision Sec. 30.2.6.1. The management of every Broker Dealer shall establish and maintain an appropriate and effective compliance function within the firm which is independent of all operational and business functions. The compliance function shall be performed by an Associated Person who shall be registered with the Commission and required to report directly to the board of directors and the company President. The management shall ensure that the Associated Person/s performing the compliance function possesses sufficient training and experience in securities regulation matters and an understanding of the securities activities of the firm enabling them to effectively execute their duties. xxx xxx xxx Sec. 30.2.6.3. Although final responsibility for proper supervision shall rest with the Broker Dealer company , diligence of a good father of the family is required from the Associated Person/s in the conduct of their compliance function. 30.2.6.4. Associated Persons shall promptly report to management all occurrences of material non-compliance by the company or its staff with legal and regulatory requirements, as well as with the company's own policies and procedures. Management shall then promptly notify the Commission and any self-regulatory organization of which such Broker Dealer is a trading participant of such findings and action taken. For this purpose, the Associated Person must maintain a logbook of all material non-compliance reports with the appropriate notation of the action taken by management on the said occurrences. Such logbook must be duly registered with the Commission within fifteen (IS) days from issuance of the Associated Persons new/renewal license. From the above, the establishment of an effective and appropriate compliance function by the management of a Trading Participant is mandatory to properly address and effectively rectify the violations, irregularities, infractions or unusual activities committed by its employees and agents. In the case at bar, VSI, Ms. Aguilar and Mr. Racadio's actions have substantially shown that an appropriate and effective compliance functions have not been implemented, established and maintained. They failed to show that VSI supervisory and compliance system is reasonably designed to achieve compliance with the applicable laws and regulations. As discussed above, the following surrounding circumstances have shown that VSI, Racadio and Aguilar willfully failed to implement, establish and maintain an appropriate and effective compliance function within the company. (1) Mr. Balabis is not present during the Sulapas account opening. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00 but he was allowed to transact beyond his declared financial capacity. (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L. (4) Respondents failure to require Mr. Sulapas to update his CAIF. (4) n Respondents allowed the execution of EQ Trade without written authorization from Mr. Sulapas. (5) The unlawful granting of Credit Line to Sulapas account which is not a Margin Account. (6) As Cash Account, Respondents failed to liquidate the shares in some transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. (7) Respondents VSI and Racadio issued multiple checks lower than Five Hundred Thousand Pesos (Php500,000.00) prepared for the same day to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council. From the foregoing, the panel concludes that not only Ms. Aguilar and Mr. Racadio violated the pertinent provision of the Supervision Rule, but also VSI since the final responsibility for proper supervision rest with the Broker Dealer company. K. On the Charge for violation of Section 30.2.1.1 of the 2015 SRC Rules (Ventures Securities, Wilfred Racadio, Adora Aguilar and Loreto Balabis) In this charge, the Complainant stated that: 80 1. Loreto Balabis did not see Julieto Sulapas fill out the Customer Account Information Form (CAIF) himself but simply gave Marlo Moron a blank CAIF (without verification of the contents of the Julieto Sulapas CAIF). 2. There are EQ Trades involving the Julieto Sulapas account without written request and/or with unsigned requests. 3. Adora Aguilar did not require Julieto Sulapas to correct his answers in the CAIF as to the existence of an account with other brokers even if she knew that Julieto Sulapas has an account with R&L. 4. Marlo Moron was allowed as authorized person of Julieto Sulapas despite knowledge that he is a trading floor assistant/settlement clerk in R&L where the subject EQ trades originated. It has also been revealed during the investigative proceedings that Venture officers relied on the confirmation of Marlo Moron as the alleged settlement officer of R&L for transactions that Marlo Moron himself instructed on behalf of Julieto Sulapas. 5. The above mentioned circumstances clearly show that Venture and its officers maintained commercial honor and principles below the required high standards of the SRC. 6. Wilfred Racadio, the President of Venture Securities, has the duty to oversee the day to day operations of the broker dealer, including the observance of Venture Securities with the high standards of commercial honor and just and equitable principles of trade as required under the Securities Regulation Code and its Implementing Rules and Regulations. The acts committed which are below the standard honor and trade principles of the officers and employees of Venture Securities as discussed above clearly shows the failure of Wilfred Racadio to perform his duties as the President of the company. In their defense, the Respondents answered: 81 1. There is also no basis to find Venture Securities, Mr. Racadio, Ms. Aguilar, and Mr. Balabis under Section 30.2.1.1 of the SRC-IRR. Venture Securities, Mr. Racadio, Ms. Aguilar, and Mr. Balabis observed high standards of commercial honor and just equitable principles of trade in relation to the account of Mr. Sulapas; 2. As already discussed above, Mr. Sulapas filled out his CAIF at the time he visited the office of Venture Securities on 29 May 2012. There is nothing unethical on the part of Mr. Balabis in giving a blank CAIF to Mr. Moron for Mr. Sulapas to fill up. The account opening forms of other broker dealers can be downloaded freely from the internet. It bears stressing that the account of Mr. Sulapas was created at the time of his visit to the office of VSI, after verifying the information he provided, and after 32 determining his financial situation, investment objective, and investment experience; 3. All of the "transfer out" requests of Mr. Sulapas contained a written authority coming from him in accordance with the SRC-IRR. As regards "transfer in" requests, VSI found the client's advice regarding "transfer in" requests is sufficient for purposes of internal control because it gives sufficient and timely information regarding the expected stock transfer and position of the client. Moreover, VSI relied on the presumption of regularity and the watchful eyes of CMIC that R&L complies with the requirements for the SRC-IRR as regards the "transfer out" requests of Mr. Sulapas and that R&L was only transferring shares coming from the account of Mr. Sulapas from 2012-2019; 4. Ms. Aguilar required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. This would be inconsistent with the high standards of commercial honor and just equitable principles of trade observed by VSI and its employees. Instead, VSI had duly noted that Mr. Sulapas maintained another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as fraudulent; 5. There is no prohibition under the SRC or the SRC-IRR for Mr. Moron, as the trading floor assistant/settlement of R&L, to be authorized to transact Mr. Sulapas' account with Venture. Moreover, Mr. Moron was not granted any special or unusual authority other than the usual authority given by other clients to their authorized representatives. It was also Mr. Sulapas who primarily transacted for his account; 6. As the President of VSI, Mr. Racadio always makes sure that VSI and its employees observe high standards of commercial honor and just equitable principles of trade in relation to the account of Mr. Sulapas. The above examples show exactly how the Company and its employees observe the same. The allegations in the Formal Charge show no basis to find that VSI and its employees acted below the said high standards of commercial honor and just equitable principles of trade. There were no laws and rules violated, and the employees of VSI did not commit any felony or offense just for the purposes of compliance. In addition, since Mr. Racadio is not a registered person, he cannot be held liable under Section 30.2.1.1 of the SRC-IRR. In dealing in securities, the Ethical Standards Rule, which, in substance, requires that every Broker Dealer, Associated Person and Salesman, in the conduct of his business; shall observe high standards of commercial honor and just and equitable principles of trade. As such, adherence to Rule 30.2.1 must be strictly observed, to wit: Rule 30.2.1. Ethical Standards Rules 30.2.1.1. Every Broker Dealer, Associated Person and Salesman of a Broker Dealer (hereinafter referred to as a "registered person"), in the conduct of his business, shall observe high standards of commercial honor and just and equitable principles of trade. Under the broad-spectrum concept of the Ethical Standards Rule, the foregoing acts and practices willfully committed by Respondents are considered contrary to such standards and may constitute grounds for the imposition of administrative sanctions, to wit: (1) Mr. Balabis was not present during the Sulapas account opening. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00 but he was allowed by Respondents to transact beyond his declared financial capacity. (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L. (4) Respondents failure to require Mr. Sulapas to update his CAIF. (5) Respondents allowed the execution of EQ Trade without written authorization to do so. (6) The unlawful granting of Credit Line to Sulapas account which is not a Margin Account. (7) As Cash Account, Respondents failed to liquidate the shares in some transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. (8) Respondents VSI and Racadio issued multiple checks lower than Five Hundred Thousand Pesos (Php500,000.00) prepared for the same day to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council; and, (9) For violating all of the above-mentioned SRC and SRC-IRR provisions. Contrary to the claim of Mr. Racadio that he is not liable under the Rule since he is not a registered person, he would likewise be liable under the Rule for his participation in the wrongful acts mentioned above and as a control person based on his failure to supervise VSI registered representatives. Evidently, the Respondents VSI, Racadio, Aguilar and Balabis in the conduct of their business and profession, failed to observe high standards of commercial honor and just and equitable principles of trade and to act honestly and fairly for the integrity of the capital market. IV. Whether or not the Formal Charge failed to allege the ultimate facts showing any culpability of the Respondents for the alleged violations of the Securities Regulation Code and it Implementing Rules and Regulations V. Whether or not Respondent sufficiently denied the allegations of facts in the Formal Charged These remaining issues raised by Complainant and Respondents namely failure to specifically deny the allegation of facts in the Formal Charged and failure to allege ultimate facts, respectively, need not be discussed further since this was already cured when both submitted their evidence, documents and affidavit of witnesses in their respective Position Papers and Comments/Reply that would support their factual allegations in their respective Formal Charge and Verified Answer. Further, as already discussed above, the Commission as administrative body is not bound by the strict application of the Rules of Procedures. FINAL NOTE The foregoing acts and violations committed by the Respondents indispensably contributed, if not they had been the proximate cause of the losses incurred by the clients of R&L. We cannot tolerate and ignore any act or omission on the part of those involved in the capital market which would violate the norm set by the securities law especially on the transactions and responsibilities of Broker Dealers and that would diminish or even just tend to diminish the faith of the investors on the integrity of the capital market. Likewise, the practice of installing undiscerning persons in entities involved in the capital market cannot be tolerated, let alone allowed to perpetuate. This must be curbed by holding accountable those who consciously and willfully commit wrongful acts in the performance of their duties as officers, registered persons or employees. The Respondents must be reminded that transactions involving securities affect the general public and the national economy. We stress that Republic Act No. 8799, otherwise known as the "The Securities Regulation Code," enunciates, inter alia , the State policy of promoting the development of the capital market and the protection of investors. 82 For this reason, it is totally unacceptable and unconscionable to place the Respondents' act and imprimatur on these issues that seriously endanger the integrity of entire securities market. For this Commission to cop-out and to close its eyes to these acts and deeds, while convenient, would be to abandon its duty of safeguarding public interest and the integrity of the capital market. PENALTIES TO BE IMPOSED Notwithstanding the provisions of SEC Memorandum Circular No. 6, series of 2005 (MC 6, s. 2005 or Circular), the Commission, in its discretion, has the power to impose other alternative penalties as provided for under Sec. 54.1 of the SRC. The pertinent portion of Sec. 54.1 of the SRC is herein reproduced: Sec. 54.1 If after due notice and hearing, the Commission finds that: (a) there is a violation of this Code, its rules , or its orders (b) x x x (c) x x x (d) x x x, it shall , in its discretion , and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances : (i) Suspension, or revocation of any registration for the offering of securities; (ii) A fine of no less than Ten Thousand Pesos (P10,000.00) nor more than One Million Pesos (P1,000,000.00) plus not more than Two Thousand Pesos (P2,000.00) for each day of continuing violation; (iii) In the case of a violation of Sections 19.2, 20, 24, 26 and 27, disqualification from being an officer, member of the Board of Directors, or persons performing similar functions, of an issuer required to file reports under Section 17 of this Code or any other act, rule or regulation administered by the Commission; (iv) In the case of a violation of Section 34, a fine of no more than three (3) times the profit gained or loss avoided as a result of the purchase, sale or communication proscribed by such Section; and (v) Other penalties within the power of the Commission to impose. (emphasis supplied) In the implementation of the foregoing and in order to give effect to the intent of the SRC, the Commission adopted SRC Rule 54.1 which mirrors the above-mentioned provision of law, thus: 54.1. If after due notice and hearing, the Commission finds that: (a) there is a violation of this Code, its rules , or its orders (b) x x x (c) x x x (d) x x x, it shall , in its discretion , and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances : 54.1.1. Suspension, or revocation of any registration for the offering of securities; 54.2.2. A fine of no less than Ten Thousand Pesos (P10,000.00) nor more than One Million Pesos (P1,000,000.00) plus not more than Two Thousand Pesos (P2,000.00) for each day of continuing violation; 54.1.3. In the case of a violation of Sections 19.2, 20, 24, 26 and 27, disqualification from being an officer, member of the Board of Directors, or persons performing similar functions, of an issuer required to file reports under Section 17 of this Code or any other act, rule or regulation administered by the Commission; 54.1.4. In the case of a violation of Section 34, a fine of no more than three (3) times the profit gained or loss avoided as a result of the purchase, sale or communication proscribed by such Section; and 54.1.5. Other penalties within the power of the Commission to impose. (emphasis supplied) On the basis of the above-quoted provisions, it is clear that the Code gives the SEC flexibility based on its discretion to impose various kinds of sanctions since not all sanctions apply in every case and the SEC is empowered to select the sanction appropriate to the facts and circumstances of each situation. The Commission may thus impose any of the above-mentioned alternative penalties against a Company and any person found administratively liable for violating any provision of the SRC and its IRR. If fine alone is the penalty imposed, the maximum shall be Php1,000,000.00. To emphasize, the phrase " in its discretion , and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances " operates to confer discretion to SEC to select the sanction appropriate to the facts and circumstances of each case. Applying Section 54.1, therefore, it does not prohibit the Commission to impose sanction based on its discretion. Thus, it could be said that the appropriate penalty under Sec. 54.1 of the SRC may be applied as an alternative penalty on the penalties imposed under MC 6, s. 2005, which was issued purposely to rationalize the penalties to be imposed by the Commission to insure strict compliance with the Code and its IRR. Likewise, under the same provision of the Circular it states that the imposition of the foregoing penalties shall be without prejudice to the imposition of other administrative sanctions or to the filing of criminal charges against the person/s responsible for the violation. The clear tenor and intention of Memorandum Circular is not to remove the application of SRC Section 54 as an alternative penalty, but to lay down a rule of preference in the application of the penalties provided for in the SRC. The pursuit of this purpose clearly does not foreclose the possibility of applying Section 54 for violators of any of the provision of the SRC. Neither does it defeat the legislative intent behind the law. Hence, the Memorandum Circular establishes a rule of preference in the application of the administrative monetary penalty provision of SRC such that where the circumstances of both the offense and the offender clearly indicate good faith or a clear mistake of fact without taint of bad faith or negligence, otherwise, the imposition of a fine under the SRC should be considered as the more appropriate penalty. Needless to say, the determination of whether the circumstances warrant the imposition of a fine under the SRC provision rests solely upon the Commission. Should the Commission decide that any of the provision under Section 54 of the SRC is the more appropriate penalty, Memorandum Circular No. 6, Series of 2005 ought not be deemed a hindrance. It is, therefore, understood that SEC Memorandum Circular No. 6, Series of 2005 does not remove the imposition of any of the penalty provided for under Section 54 of the SRC as an alternative penalty for violations of any of the provision of the SRC and its IRR. Further, Section 29 of the SRC provides: Section 29 . Revocation, Refusal or Suspension of Registration of Brokers, Dealers, Salesmen and Associated Persons . 29.1. Registration under Section 28 of this Code may be refused, or any registration granted thereunder may be revoked, suspended, or limitations placed thereon, by the Commission if, after due notice and hearing the Commission determines the application or registrant. (a) Has willfully violated any provision of this Code, any rule, regulation or order made hereunder, or any other law administered by the Commission, or in the case of a registered broker, dealer or associated persons has failed to supervise, with a view to preventing such violation, another person who commits such violation. WHEREFORE , premises considered, the panel finds that the Respondents violated the above-mentioned pertinent provisions of the SRC and the SRC-IRR and hereby imposed the following administrative sanctions: A. Venture Securities, Inc. 1. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1. (Ethical Standards Rules) 2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities) 3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients) 4. A fine of One Million Pesos (P1,000,000.00) for violation of Section 48.2 and SRC Rule 48.2 (Prohibitions on Extension of Credit) 5. A fine of One Million Pesos (P1,000,000.00) for violation of Section 50 of the SRC and SRC Rule 50 (Purchases and Sales in Cash Account) 6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule) 7. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule) 8. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6. (Supervision) 9. Revocation of its license/registration as broker/dealer pursuant to Section 29 of the SRC for willfully violating all of the above-mentioned provisions of the SRC and the SRC-IRR B. Mr. Wilfred Racadio 1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 51 in relation to Sec. 26 of the SRC and disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Sections 54.1, 28 and 29 of the SRC. 2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1. (Ethical Standards Rules) 4. n A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities) 5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients) 6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6. (Supervision). 7. A fine of One Million Pesos (P1,000,000.00) for violation of Section 48.2 of the SRC and SRC Rule 48.2 (Prohibitions on Extension of Credit) 8. A fine of One Million Pesos (P1,000,000.00) for violation of Section 50 of the SRC and Rule 50 (Purchases and Sales in Cash Account) 9. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule) 10. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule) 11. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC C. Ms. Adora Aguilar 1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC and revocation of her license as Associated Person pursuant to Section 54.1 of the SRC. 2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1. (Ethical Standards Rules) 3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities) 4. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients) 5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6. (Supervision) 6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 34 (Segregation and Limitation of Functions of Members, Brokers and Dealers) 7. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule) 8. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule) 9. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC 10. Disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Section 54.1 of the SRC D. Mr. Loreto Balabis 1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC and revocation of his license as salesman of securities pursuant to Section 54.1 of the SRC. 2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1. (Ethical Standards Rules) 3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities) 4. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients) 5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule) 6. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC 7. Disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Section 54.1 of the SRC E. Ms. Teresita Mosenabre 1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC. 2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule) 3. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC 4. Disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Section 54.1 of the SRC In conformity with SRC Rule 30.2.6.3, which provides that the final responsibility for proper supervision shall rest with the Broker Dealer Company and Section 51 of the SRC, which states that the controlling person shall also be liable jointly and severally with and to the same extent as the controlled persons, VSI and Mr. Racadio are held jointly and severally liable for the monetary penalty imposed on its officers and employees. In sum, the total monetary penalties imposed upon all Respondents amount to Thirty-Two Million Pesos (Php32,000,000.00). Finally, this Decision is without prejudice to any further action that the Investigation and Review Committee of MSRD may institute on the basis of evidence that it may, now or hereafter secure, including among others, to institute further action to charge responsible persons on the actual count or occurrences of violations committed. SO ORDERED. (SGD.) MARLON G. FACUN Chairman (SGD.) EMMA A. VALENCIA Member (SGD.) ERWIN EDWARD P. MENDINUETO Member Footnotes 1. EQ Trades are transactions for the transfer of equity securities or shares of stock from one broker to another broker. 2. Paragraph 2.50, pages 17 & 18 of Respondents Reply. 3. Paragraph 3.16, page 10 and par. 4.62, page 32 of Respondents Answer. Paragraph 2.81, pages 22-23 of the Respondents Position Paper and paragraphs 2.7-2.17 of Respondents Reply. 4. Pages 2-7 of the Respondents Position Paper. 5. Paragraphs 4, 4.1-4.6 of the Complainant's Position Paper. 6. Paragraph 2.50, pages 17 & 18 of Respondents Reply. 7. G.R. No. 198444, 4 September 2013. 8. Paragraph 20, page 17 of the Formal Charge and paragraph 5.4 of Complainant Position Paper. 9. Paragraph 2.81, page 22 1st sentence Respondents Position Paper, paragraph 3.16, page 10 and paragraph 4.62, page 32 1st sentence of Respondents Answer. 10. Paragraph 2.8, page 4 of Respondents Reply 1st sentence. 11. G.R. No. L-46908, May 17, 1980. 12. Control Persons May be Liable for Stock Broker Misconduct, Daniel Broxup, August 19, 2017. 13. G.R. No. 170735, December 17, 2007. 14. Pages 19-20 of the Formal Charge. 15. Pages 35-36 of Respondents Answer. 16. Attached as Annex "16" of the Respondents Position Paper. 17. Page 21 of the Answer and also mentioned in pars. 5-7 of Ms. Aguilar Affidavit attached as Annex 14 of the Respondent Position Paper. 18. Page 21, Annex 12 of the Respondents Position Paper. 19. Annexes 1 and 1A of the Respondents Position Paper. 20. Paragraph 16 of Aguilar Affidavit dated March 8, 2021 attached as Annex "14" of the Respondents Position Paper. 21. Submitted during the investigation also attached as Annex "4" of the Respondents Position Paper and Annexes "F" and "G" of Complainant's Position Paper. 22. Credit Line Agreement dated August 18, 2015 signed by Mr. Racadio, Annex 11 of Respondents Position Paper, cited in Par. 3.46, pages 16 & 17 Respondents Answer and Annex H of Complainant Position Paper. 23. Paragraph 3.5.1, page 10, par. 3.29, page 13, par. 3.33, page 14, par. 4.9, page 22 and par. 4.30, page 27 of Respondents Answer, par. 2.16, page 9, par. 2.39, page 15 of Respondents Position Paper and par. 2.31, page 13 and par. 2.35, page 13 Respondents Reply. 24. Investo.gov.US Securities and Exchange Commission, https://www.investor.gov/introduction . Also cited in par. 617 of Complainant Position Paper. 25. Paragraph 23 of Adora Aguilar Affidavit attached as Annex 14 of the Position Paper. Also part of Complainant's arguments in paragraphs 2-2.4 of its Comments. 26. Annex "C" of Complainant Position Paper. 27. Annex "D" of Complainant Position Paper. 28. Par. 2.27, page 9 Respondents Reply. 29. G.R. No. 181381, July 20, 2015. 30. Pars. 2.28-2.32, Pages 10-11 Respondents Reply. 31. G.R. No. 186967, January 18, 2017. 32. People v. Estibal , G.R. No. 208749, November 26, 2014. 33. Pages 23-24 of Formal Charge. 34. Page 40 of the Respondents Answer. 35. Pages 49-50, Annex 12 of the Respondents Position Paper. 36. Annex 1-A position paper. 37. Attached as Annex "A" Formal Charge and Annex "B" of Complainant Position Paper. 38. Rep. Act No. 8799 (2000), sec. 4.1. 39. Pres. Decree No. 902-A (1976), secs. 5 and 6. 40. Pres. Decree No. 902-A (1976), sec. 3, Republic Act 11232, Section 179 (a). 41. Securities and Exchange Commission v. Subic Bay Golf and Country Club, Inc. and Universal International Group Development Corporation , G.R. No. 179047, March 11, 2015. 42. Par. 4.40, page 28 of Respondents Answer. 43. Par. 2.81, page 24 Respondents Reply. 44. See paragraph 3.69 (last sentence) page 20 of Respondents Answer. 45. Page 21 of the Formal Charge. 46. Page 38 of Respondents Answer. 47. Page 22 of the Formal Charge. 48. Page 39 of the Respondents Answer. 49. Item B.3, par. 3, page 7 CMIC Report. 50. Republic Act 8799 (2000). 51. G.R. No. 160016, 27 February 2006. 52. Par. 2.135, page 31 Position Paper. 53. Attachment to Annex 1 and Annex 1-A of Respondents Position Paper. 54. Page 29, Annex 12 of the Respondents Position Paper. 55. Abacus case. 56. Baviera vs. Paglinawan , G.R. Nos. 168380 and 170602, February 8, 2007. 57. Page 21 of the Formal Charge. 58. Pages 37-38 of the Answer. 59. Paragraphs 26-29, page 18 of the Formal Charge. 60. Paragraph 6.50 Complainant Position Paper. 61. Paragraphs 4.70-4.75, pages 34-35 of the Answer. 62. Paragraph 4.36, page 28 of the Answer. 63. Paragraph 2.95, pages 25-26 Position Paper. 64. Paragraph 2.100, page 26 Position Paper. 65. Pages 22 of the Formal Charge. 66. Page 39 of the Answer. 67. Paragraphs 6.55 and 6.56 Complainant Position Paper. 68. Paragraphs 2.77-279, pages 23-24 Respondents Reply. 69. Paragraph 6.57. 70. Paragraph 2.80, page 24. 71. Pages 15-16 of the Formal Charge. 72. Pages 29-31 of the Answer. 73. G.R. Nos. 106425 & 106431-32, (July 21, 1995). 74. G.R. No. 193804, 27 February 2013. 75. G.R. No. 184666, June 27, 2016. 76. Page 17 of the Formal Charge. 77. Pages 31-32 of the Answer. 78. Page 20 of the Formal Charge. 79. Pages 36-37 of the Answer. 80. Pages 17-18 of the Formal Charge. 81. Pages 32-33 of the Answer. 82. SEC. 2. Declaration of State Policy . The State shall establish a socially conscious, free market that regulates itself, encourage the widest participation of ownership in enterprises, enhance the democratization of wealth, promote the development of the capital market, protect investors, ensure full and fair disclosure about securities, minimize if not totally eliminate insider trading and other fraudulent or manipulative devices and practices which create distortions in the free market. To achieve these ends, this Securities Regulation Code is hereby enacted. n Note from the Publisher: Copied verbatim from the official document. Irregular numerical sequence. n Note from the Publisher: Copied verbatim from the official document. Irregular numerical sequence. n Note from the Publisher: Copied verbatim from the official document. Irregular numerical sequence.