You are receiving this Notice because records indicate that you may have transacted in one or more Mexican Government Bond Transactions between at least January 1, 2006, and April 19, 2017 and may be a Settlement Class Member in this class action.

The Notice advises you of your rights and options with respect to this Action, what benefits are available, who is eligible for them, and what you must do to receive your portion of the benefits if you are eligible. The purpose of the Notice is also to inform you of the Fairness Hearing to be held by the Court to determine, among other things, whether the Settlements, the Distribution Plan, and the application by Plaintiffs’ Lead Counsel for attorneys’ fees and payment of expenses are fair, reasonable, and adequate.

Plaintiffs allege that each Defendant, from January 1, 2006 through April 19, 2017, inclusive, conspired to fix the prices for Mexican Government Bonds (“MGBs”) issued by the Mexican government through the Bank of Mexico. Plaintiffs allege that each Defendant transacted in price-fixed MGBs at artificial prices with market participants like Plaintiffs and the Class. Plaintiffs’ lawsuit contends that Defendants fixed MGB prices through several interrelated means.

Additional details can be found in the Long-Form Notice.

A description of the Mexican Government Bonds Transactions entered into by the member of the Settlement Class that fall within the Settlement Class definition (including, for each transaction, the identity of the broker, the date of the transaction, the type of the transaction, the counterparty (if any), any transaction identification numbers, the rate, and the notional amount of the transaction).

The Stipulations and the Court’s Preliminary Approval Orders can be found here.

All capitalized terms used, but not defined, shall have the same meanings as in the Stipulations and the Court’s Preliminary Approval Orders.

Plaintiffs and Plaintiffs’ Lead Counsel believe that Settlement Class Members have been damaged by Defendants’ alleged conduct. Settling Defendants do not agree with the allegations made by Plaintiffs, believe that they have meritorious defenses to Plaintiffs’ allegations, and believe that Plaintiffs’ claims would have been rejected prior to trial, at trial (had Plaintiffs successfully certified a class and survived summary judgment motions), or on appeal. As a result, Settling Defendants believe Settlement Class Members would have received nothing if the litigation had continued to trial.

The Settling Defendants have collectively agreed to pay $86.4 million (the “Settlement Amount”) in cash for the benefit of the proposed Settlement Class. If the Settlement is approved, the Settlement Amount, plus interest earned from the date it was established, less any Taxes, any Notice and Administration Costs, any Court-awarded attorneys’ fees, litigation costs and expenses, and service awards for Plaintiffs, and any other costs or fees approved by the Court (the “Net Settlement Fund”), will be divided among all Settling Class Members who file valid Claim Forms.

If the Settlement is approved, the Action will conclude. If the Settlement is not approved, Settling Defendants will remain as defendants in the Action, and Plaintiffs will continue to pursue their claims against Settling Defendants.

In the Preliminary Approval Order, the Court preliminarily approved the following Settlement Class, defined as:
All Persons that entered into a Mexican Government Bond Transaction with a Defendant or an affiliate of a Defendant between at least January 1, 2006, and April 19, 2017, where such persons were either domiciled in the United States or its territories or, if domiciled outside the United States or its territories, transacted in the United States or its territories. Excluded from the Class are Defendants and their employees, agents, affiliates, parents, subsidiaries and co-conspirators, whether or not named in the Complaint in this Action, and the United States and Mexican governments; provided, however, that Investment Vehicles shall not be excluded from the definition of “Class” or “Settlement Class” solely on the basis of being deemed to be Defendants or affiliates or subsidiaries of Defendants.

Not everyone who fits this description will be a Settlement Class Member.

Additional details can be found in the Long-Form Notice.

The Settling Defendants are Banco Santander México, S.A., Institución de Banca Múltiple, Grupo Financiero Santander México (formerly known as Banco Santander (México), S.A., Institución de Banca Múltiple, Grupo Financiero Santander México) (“Santander Mexico”); BBVA México, S.A., Institución de Banca Múltiple, Grupo Financiero BBVA México (formerly known as BBVA Bancomer S.A., Institución de Banca Múltiple, Grupo Financiero BBVA Bancomer) (“BBVA México”); Banco Nacional de México, S.A., Institución de Banca Múltiple, Grupo Financiero Banamex (“Citibanamex”); Deutsche Bank México, S.A., Institution de Banca Múltiple (“Deutsche Bank Mexico”); HSBC México, S.A., Institución De Banca Múltiple, Grupo Financiero HSBC (“HSBC Mexico”); and Bank of America México, S.A., Institución de Banca Múltiple (“Bank of America Mexico”).

Yes. Excluded from the Class are Defendants and their employees, agents, affiliates, parents, subsidiaries and co-conspirators, whether or not named in the Complaint in this Action, and the United States and Mexican governments; provided.

However, that Investment Vehicles shall not be excluded from the definition of “Class” or “Settlement Class” solely on the basis of being deemed to be Defendants or affiliates or subsidiaries of Defendants.

If you are a Settlement Class Member and do not exclude yourself, you are eligible to file a Claim to receive your share of money from the Net Settlement Funds.

To participate in and receive your share of the Net Settlement Fund, you must submit a valid and timely Claim Form demonstrating that you are an Authorized Claimant as set forth in the Settlement Agreement. You may obtain and submit a Claim Form no later than January 4, 2027 via this page. Claim Forms, if sent by mail, must be addressed to the Settlement Administrator (see address below in How Do I Get More Information?) and postmarked no later than January 4, 2027.

IF YOU TIMELY SUBMITTED A VALID CLAIM FORM PURSUANT TO THE APRIL 21, 2021 NOTICE RELATED TO THE $20.7 MILLION IN SETTLEMENTS WITH BARCLAYS AND JPMORGAN, YOU DO NOT HAVE TO SUBMIT A NEW CLAIM FORM TO PARTICIPATE IN THIS SETTLEMENT.

The Court has scheduled a Fairness Hearing for December 3, 2026 at 3:00 P.M. to be held telephonically from the Thurgood Marshall United States Courthouse (855-244-8681 access code 2312 828 7066##). During the Fairness Hearing, the Court will determine, among other things, if the proposed Settlement is fair, reasonable, and adequate. The Court will also consider Plaintiffs’ Lead Counsel’s request for attorneys’ fees and reimbursement of litigation expenses.

The time, date, and venue of the Fairness Hearing may be continued from time to time without further notice and could be conducted remotely or in-person. You are advised to confirm the time and location if you wish to attend; as soon as practicable after any change in the scheduled date, time, and/or location, such change will be posted on the Settlement Website.

Unless you exclude yourself, you remain a Settling Class Member. That means you can’t sue, continue to sue, or be part of any other lawsuit about the Released Claims in this Action against Settling Defendants or any of the Released Parties. Upon the Effective Date, the Releasing Parties shall release and be deemed to release and forever discharge and shall be forever enjoined from prosecuting the Released Claims against the Released Parties, regardless of whether such Releasing Party executes and delivers a Claim Form.

Additional details can be found in the Long-Form Notice.

You are automatically a member of a Settling Class if you fit the Settlement Class description. However, if you do not submit a timely and valid Claim Form, you will not receive any payment from the Settlement. You will be bound by past and any future Court rulings, including rulings on the Settlement and Released Claims. Unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be a part of any other lawsuit against Settling Defendants or any of the other Released Parties on the basis of the Released Claims.

You can exclude yourself by sending a written “Request for Exclusion.” You cannot exclude yourself by telephone or email. Your written Request for Exclusion must contain:

(a) the name, address, and telephone number of the Settlement Class Member;
(b) a list of all trade names or business names that the Settlement Class Member requests to be excluded;
(c) the name of this Action (In re Mexican Government Bonds Antitrust Litigation, No. 18-cv-02830 (JPO) (S.D.N.Y.));
(d) a statement certifying such person is a member of the Settlement Class;
(e) a description of the Mexican Government Bonds Transactions entered into by the member of the Settlement Class that fall within the Settlement Class definition (including, for each transaction, the identity of the broker, the date of the transaction, the type of the transaction, the counterparty (if any), any transaction identification numbers, the rate, and the notional amount of the transaction);
(f) a statement that “I/we hereby request that I/we be excluded from the Settlement Class”; and
Requests for exclusion from the Settlement Class for the Settlement Agreement(s) must be sent by U.S. first class mail (preferably certified mail) (or, if sent from outside the U.S., by a service that provides for guaranteed delivery within five (5) or fewer calendar days of mailing) to the Settlement Administrator at:

Requests for exclusion must be postmarked by October 29, 2026 to be considered timely. Additional details can be found in the Long-Form Notice.

If you are a Class Member and you do not exclude yourself, you can tell the Court what you think about the Settlement. You can object to all or any part of the Settlement, Distribution Plan, and/or application for attorneys’ fees, reimbursement of litigation costs and expenses, and any service awards for Plaintiffs. You can give reasons why you think the Court should approve them or not. The Court will consider your views.

If you want to make an objection in the Action, you may enter an appearance in the Action, at your own expense, individually or through counsel of your own choice, by filing with the Clerk of Court a notice of appearance and your objection, and serving copies of your objection on Plaintiffs’ Lead Counsel and Settling Defendants’ Counsel by October 29, 2026, to the following mailing addresses:

If you choose to object, you must file a written objection with the Clerk of the Court. You cannot file an objection by telephone or email.

Your written objection must include a statement of the objection as well as the specific legal and factual reasons for each objection, including all support that you wish to bring to the Court’s attention and all evidence you wish to introduce in support of your objection. The submission must contain:

(i) a heading that refers to this Action by case name and case number (In re Mexican Government Bonds Antitrust Litigation, No. 18-cv-02830 (JPO) (S.D.N.Y.));

(ii) a statement of the specific legal and factual basis for each objection , including whether the objection applies only to you, a specific subset of the Class or the entire Class;

(iii) a statement of whether you intend to appear at the Fairness Hearing, either in person or through counsel and, if through counsel, a statement identifying that counsel by name, address, telephone number, and email address;

(iv) a description of any and all evidence you may offer at the Fairness Hearing, including but not limited to the names, addresses, email addresses and expected testimony of any witnesses; all exhibits intended to be introduced at the Fairness Hearing; and documentary proof of your membership in the Class;

(v) a description of your Mexican Government Bond Transactions that fall within the Class definition (including, for each transaction, the identity of the broker, the date of the transaction, the type of the transaction, the counterparty (if any), any transaction identification numbers, the rate, and the notional amount of the transaction); and

(vi) a list of other cases in which you or your counsel has appeared either as an objector or counsel for an objector in the last five years.

Persons who have timely submitted a valid Request for Exclusion are not members of the Class and are not entitled to object. All written objections must be signed by you (or your legally authorized representative), even if you are represented by counsel.

Objecting is telling the Court that you do not like something about the Settlements. You can object to the Settlements only if you remain a Settlement Class Member and do not exclude yourself from the Settlements. Excluding yourself from the Settlements is telling the Court that you do not want to be a part of the Settlement Class. If you exclude yourself, you have no right to object to the Settlements because they no longer affect you.

No. Plaintiffs’ Lead Counsel will answer any questions the Court may have. You are, however, welcome to come at your own expense. You are advised to confirm the time and location if you wish to attend; as soon as practicable after any change in the scheduled date, time, and/or location, such change will be posted on the Settlement Website.

If you send an objection, you do not have to come to Court to talk about it. As long as you file and serve your written objection on time, the Court will consider it. You may also hire your own lawyer to attend, but you are not required to do so.

If you are a Settling Class Member, you are entitled to appear, in person or through duly authorized attorneys, and to show cause why the Settlement or other applications should or should not be approved. However, if you wish to appear, you must submit a written statement, along with any materials you wish the Court to consider. This written statement must be received by the Court no later than October 29, 2026, or it will not be considered. Such materials must also be served on Plaintiffs’ Lead Counsel and counsel of record for the Settling Defendants by overnight mail or by hand or they will not be considered.

Additional details can be found in the Long-Form Notice.

More details are included in the Stipulations and Distribution Plan (Including Multiplier Table), which are available for your review in the Court Documents section of this website. You may also call toll-free 1-877-829-2941 (if calling from outside the United States or Canada, call 1-414-961-6592) or write to the Settlement Administrator at: