Hagens Berman Sobol Shapiro, LLP and Stoll Stoll Berne Lokting & Shlachter P.C. Announce Proposed Settlements in the Aequitas Securities Litigation

Hagens Berman Sobol Shapiro, LLP and Stoll Stoll Berne Lokting & Shlachter P.C.:

SUMMARY NOTICE OF PENDENCY AND PROPOSED SETTLEMENTS OF CLASS ACTION

IF YOU PURCHASED COVERED AEQUITAS SECURITIES, YOU MAY BE ENTITLED TO A PAYMENT FROM THE CLASS ACTION SETTLEMENTS.¹

Proposed settlements have been reached in a class action lawsuit alleging violations of the Oregon Securities Laws. The Court in charge of the case is the United States District Court for the District of Oregon, and the case is known as Ciuffitelli, et al. v. Deloitte & Touche LLP, et al., Case No. 3:16-cv-00580-AC (the “Action”). The plaintiffs that sued and represent the Class in the Action (Lawrence P. Ciuffitelli (on behalf of himself and as Trustee of the Ciuffitelli Revocable Trust U/A 5/1/1996); Greg and Angela Julien (as Trustees of the Gregory and Angela Julien Revocable Trust U/A 7/2/2012); R.F. MacDonald Co.; James and Susan MacDonald (as co-Trustees of the MacDonald Family Trust U/A 12/05/2000); William Ramstein; Greg Warrick (on behalf of himself and as co-Trustee of the Warrick Family Trust); and Susan Warrick (as co-Trustee of the Warrick Family Trust)) (collectively, the “Class Representatives”) and Defendants Deloitte & Touche LLP (“Deloitte”); EisnerAmper LLP (“EisnerAmper”); Sidley Austin LLP (“Sidley”); TD Ameritrade, Inc. (“Ameritrade”); Duff & Phelps, LLC (“Duff”); Tonkon Torp LLP (“Tonkon”); and Integrity Bank & Trust (“Integrity”) (the “Defendants”) have entered into three proposed settlements (the “Settlements”). The Defendants deny all of the allegations, and deny that they did anything wrong. The Court did not decide in favor of the Class Representatives or the Defendants. Instead, the lawyers for the Class Representatives, and the Defendants and their insurers, with the assistance of experienced mediators, have negotiated Settlements that they believe are in the best interests of their respective clients.

How Do I Know If I Am Part of the Settlements? The Settlements include a “Class” of all persons who purchased any Covered Aequitas Securities on or after June 9, 2010 (the “Class Period”) and who had an account balance related to any Covered Aequitas Securities as of March 31, 2016.

“Covered Aequitas Securities” means any security issued by the following entities: 1) Aequitas Commercial Finance, LLC (“ACF”); 2) Aequitas Income Opportunity Fund, LLC (“AIOF”); 3) Aequitas Income Opportunity Fund II, LLC (“AIOF-II”); 4) Aequitas Capital Opportunities Fund, LP (“ACOF”); 5) Aequitas Income Protection Fund, LLC (“AIPF”); 6) Aequitas Enhanced Income Fund, LLC (“AEIF”); 7) Aequitas ETC Founders Fund, LLC (“AETC”); and 8) MotoLease Financial, LLC (“AMLF”).

The Class excludes: (a) Defendants; (b) the past and present officers and directors of the Aequitas-affiliated companies, including without limitation, Robert Jesenik, Brian Oliver, Craig Froude, Scott Gillis, Andrew MacRitchie, Olaf Janke, Brian Rice, William Ruh, Steve Hedberg, Brett Brown, Tom Goila, Patricia Brown, Bill Malloy, and Thomas Szabo, and their respective families and affiliates; (c) the past and present members of the Aequitas Advisory Board, including without limitation, William McCormick, L. Martin Brantley, Patrick Terrell, Edmund Jensen, Donna Miles, William Glasgow, Keith Barnes, Bob Zukis, and their respective families and affiliates; (d) registered investment advisors and investment advisor representatives; (e) any investor who received finder’s fees or other consideration from Aequitas in connection with referring investors to Aequitas; and (f) plaintiffs in certain individual actions against the Defendants and related parties. As detailed in the Settlements, certain parties who have filed individual actions are included in some, but not all, of the Settlements (the “Partially Covered Class Members”). The Partially Covered Class Members have the opportunity to participate in any of the three Settlements from which they are not excluded.

What Do the Settlements Provide? The Settlements provide for $234,613,000 in cash to be paid pursuant to the Settlement agreements. A Class Member’s recovery will be based upon the amount of Covered Aequitas Securities purchased during the Class Period, minus any dividends or interest received on those Covered Aequitas Securities. That amount will be the Class Member's “Net Loss.” Class Members will receive payment from the Settlement proceeds on a proportional basis calculated by determining each person’s Net Loss as a percentage of all eligible Class Member Net Losses.

How Do I Get a Payment? You do not have to do anything to participate in the Settlements. If the Court grants final approval of the Settlements and you do not exclude yourself, you will be bound by the Settlements (including the releases of all known and unknown claims provided in the Settlements) and will receive a payment according to the Plan of Allocation.

What Are My Other Rights and Options? Unless you exclude yourself, you will remain in the Class, and that means that you cannot sue, continue to sue, or be part of any other lawsuit against the Defendants about the issues that have been asserted in this Action or that could have been asserted in this Action. All of the Court’s orders will apply to you and legally bind you and you will release the Defendants and related parties from the released claims, including any and all known and unknown claims and causes of action of every nature and description, whether arising under federal, state, statutory, regulatory, common, foreign, or other law, that arise in any way from or relate to the Action. If you do not want a payment from the Settlements, but you want to keep any right you may have to sue or continue to sue the Defendants and related parties on your own about the legal claims released by the Settlements, you must exclude yourself from the Class. The Partially Covered Class Members (and only the Partially Covered Class Members) may participate in the settlement(s) in which they are eligible to participate without being bound by the releases in the settlement(s) from which they are excluded. Exclusion requests must be received no later than October 29, 2019. If you are a Class Member (and have not excluded yourself from the Class), you can object to the Settlements, the Plan of Allocation, or Class Counsel’s request for an award of attorneys’ fees, charges, and expenses in representing the Class. You may also ask the Court for permission to speak at the Settlement hearing. Objections and requests to appear and speak at the Settlement hearing must be received no later than October 29, 2019. Specific information regarding these rights and options, and how to exercise them, are provided in the Notice and Settlement Agreements, all of which are available at www.AequitasSettlements.com. The Notice will be mailed to all known members of the Class.

When and Where Will the Court Decide Whether to Approve the Settlements? The Court will hold the Settlement hearing at 9:00 a.m., on November 26, 2019, in Courtroom 11B of the United States District Court for the District of Oregon, 1000 SW Third Ave., Portland, OR 97204. At this hearing, the Court will consider whether the Settlements are fair, reasonable, and adequate. The Court will also consider whether to approve the Plan of Allocation and Class Counsel’s request for an award of attorneys’ fees in the amount of 20-25% of the settlement funds and reimbursement of litigation expenses (to be paid from the settlement funds).

How Do I Get More Information? You may visit the Claims Administrator’s website at www.AequitasSettlements.com or call the Claims Administrator toll-free at (855) 474-3896. You can also contact Class Counsel: Steve W. Berman, by mail at Hagens Berman Sobol Shapiro, LLP, 1301 Second Ave., Suite 2000, Seattle, WA 98101, by telephone at (206) 623-7292, or by email at [email protected]; or Timothy S. DeJong, by mail at Stoll Stoll Berne Lokting & Shlachter P.C., 209 SW Oak Street, Suite 500, Portland, Oregon 97204, by telephone at (503) 227-1600, or by email at [email protected].

¹This Summary Notice incorporates by reference the definitions in the Stipulations of Settlement for each of the Settlements, and all capitalized terms used, but not defined herein, shall have the same meanings as in the Stipulations. The three Stipulations can be obtained at www.AequitasSettlements.com.

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