Lehman Brothers Financial SA (LEHNQ)

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II. Responses to Questions Related to JP Morgan Settlement Agreement
2. QUESTION: On February 1, 2017, the Plan Administrator filed a motion with the Bankruptcy
Court [Docket No. 54683] for approval of the settlement agreement among LBHI, certain
Controlled Entities, and JPMorgan (the “JPM Settlement Agreement”). In the motion, the “Claims
Allowance and CDA” term provided for the treatment of certain claims against LBHI and certain
Controlled Entities. Please provide additional clarification on the actual treatment of each of these
claims.
Response: On February 9, 2017, LBHI filed a supplement to the motion to approve the JPM
Settlement Agreement with the Bankruptcy Court [Docket No. 54735] to provide further details on
the treatment of each of these claims.

(4) Question: What is the timeframe assumed for “Beyond 2015”?
Response: The wind-down of the Company may continue beyond 2015 due to a variety of factors outside the Company’s
control, including but not limited to uncertainties relating to the ongoing claims resolution process, uncertainties relating to
ongoing or pending litigation, changes in the market for asset monetizations, and the timing of distributions made by Non-
Controlled Affiliates to their claimants (several Debtors and Debtor-Controlled Entities have filed claims against Non-
Controlled Affiliates). As such, the Company cannot at this time determine the date when the Company’s activities shall be
completed. The 2012+ Cash Flow Estimates incorporate an assumption that the preponderance of the assets will be monetized
by the end of 2015, and that a minimal staff will remain through the end of 2018 to handle certain corporate activities. The
2012+ Cash Flow Estimates present cash flows from asset monetizations and related costs of operations beyond 2016 at an
assumed present value as of December 31, 2016.