All persons or entities that purchased, acquired, sold, held, traded or otherwise had any interest in BBSW-Based Derivatives at any time from January 1, 2003 through August 16, 2016, inclusive. Excluded from the Settlement Class are (i) the Defendants and any parent, subsidiary, affiliate or agent of any Defendant or any co-conspirator whether or not named as a Defendant; and (ii) the United States Government.

U.S.-based transactions in financial instruments that were priced, benchmarked and/or settled based on BBSW (BBSW based derivatives). Examples are BSW based swaps, FRAs, AUD futures on the CME, AUD FX Forwards, Swaps, BAB futures.

The complaints allege that each Defendant, from January 1, 2003 through August 16, 2016, manipulated or aided and abetted the manipulation of BBSW and the prices of BBSW-Based Derivatives. For example, Plaintiffs allege that Defendants coordinated manipulative, uneconomic transactions of Prime Bank Bills during the daily BBSW “Fixing Window” in order to move the published BBSW rate in a direction that benefitted their BBSW-Based Derivatives trading positions.

The complaints allege manipulation of the Bank Bill Swap Rate (“BBSW”) and the prices of BBSW-Based Derivatives from January 1, 2003 through August 16, 2016, inclusive. JPMorgan, Westpac, ANZ, CBA, NAB, Morgan Stanley, Credit Suisse, BNPP, Deutsche Bank, RBC, RBS and UBS each has denied and continues to deny each and every claim asserted against them in the Action and deny having engaged in any wrongdoing or violation of law of any kind whatsoever. They have agreed to the Settlements solely to avoid the continuing cost and burden of, and expense associated with, continued litigation.