BNY Mellon International Operations TA-1/A Registration as a transfer agent (amended)

Form TA-1 Filer Information	UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A	OMB APPROVAL
FORM TA-1/A		OMB Number:   3235-0084 Estimated average burden hours per response: 1.5

TA-1/A : Filer Information

Form Version X0405

1(a). Filer CIK:	0001559963
1(b). Filer CCC:	********
1(c). Is this a LIVE or TEST submission?	Live   Test
1(d). Would you like a Return Copy?	Yes

Submission Contact Information

The registrant may provide a single e-mail address for contact purposes.

1(f)(i). Contact Name:

1(f)(ii). Contact Phone Number:

1(f)(iii). Contact E-Mail Address:

Notification Information

The registrant may provide additional e-mail addresses for those persons the filer would like to receive notification e-mails regarding the filing.

1(g). Notification E-mail Address:

TA-1/A : Registrant Information

2. Appropriate regulatory agency (check one):   Securities and Exchange Commission     Federal Deposit Insurance Corporation     Comptroller of the Currency  

3(a). Full Name of Registrant:	BNY Mellon International Operations (India) Private Ltd
3(a)(i). Previous name, if being amended:
3(b). Financial Industry Number (FINS) number:	347971

3(c). Address of principal office where transfer agent activities are, or will be, performed:

3(c)(i). Address 1	L1 Tower S-3 Cyberycity, Magarpatta City
3(c)(ii). Address 2	Hadapsar
3(c)(iii). City	Pune
3(c)(iv). State or Country	INDIA
3(c)(v). Postal Code	411013
3(d). Is Mailing address different from response to Question 3c? If "yes" provide address(es):	Yes   No
3(e). Telephone Number (Include Area Code)	412-234-6365
4. Does Registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Questions 3(c) above? If "Yes" provide address (es):	Yes   No
Other Business Location Record: 1
4(a)(i). Address 1	SEZ Unit, Block 3, Mount-Poonamallee Rd
4(a)(ii). Address 2	DLF IT Park Nandambakam Post, Ramapuram
4(a)(iii). City	Chennai
4(a)(iv). State or Country	INDIA
4(a)(v). Postal Code	600089
Other Business Location Record: 2
4(a)(i). Address 1	Embassy Property Floor 2-5 Coral Block3
4(a)(ii). Address 2	Thoraipakkam Radial Road Pallavaram Talu
4(a)(iii). City	Chennai
4(a)(iv). State or Country	INDIA
4(a)(v). Postal Code	600043
5. Does registrant act, or will it act, as a transfer agent solely for its own securities, and/or securities of an affiliate(s)?	Yes   No
6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions?	Yes   No

7. Has registrant been engaged, or will it be engaged as a service company by a named transfer agent to perform transfer agent functions?  Yes   No

If "Yes" provide the name(s) and File Number(s) of the named transfer agent(s) for which the registrant has been engaged, or will be engaged, as a service company to perform transfer agent functions: Engaged transfer agent company information Related to item 7 Record: 1

7(a). Name	BNY Mellon Investment Servicing (US) Inc.
7(b). File Number	084-01761
7(c)(i). Address 1	118 Flanders Road
7(c)(ii). Address 2
7(c)(iii). City	Westborough
7(c)(iv). State or Country	MASSACHUSETTS
7(c)(v). Postal Code	01581

Engaged transfer agent company information Related to item 7 Record: 2

7(a). Name	The Bank of New York Mellon
7(b). File Number	085-05006
7(c)(i). Address 1	240 Greenwhich Street
7(c)(ii). Address 2
7(c)(iii). City	New York
7(c)(iv). State or Country	NEW YORK
7(c)(v). Postal Code	10286-0001

TA-1/A : Independent, Non-Issuer Registrant Information

Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select "Not Applicable".

8. Is registrant a: Corporation

Section for Initial Registration and for Amendments Reporting Additional Persons.

corporation or partner information Related to item 8 Record: 1

8(a)(i). Full Name	BNY Mellon APAC Services Holdings f/k/a iNautix Technologies Mauritius
8(a)(ii). Relationship Start Date	12/19/2016
8(a)(iii). Title or Status	Shareholder entity
8(a)(iv). Ownership Code	E
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 2

8(a)(i). Full Name	BNY Foreign Holdings, Inc.
8(a)(ii). Relationship Start Date	12/19/2016
8(a)(iii). Title or Status	Shareholder entity
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 3

8(a)(i). Full Name	BNY International Financing Corporation
8(a)(ii). Relationship Start Date	12/19/2016
8(a)(iii). Title or Status	Owner of Shareholder entities
8(a)(iv). Ownership Code	E
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 4

8(a)(i). Full Name	The Bank of New York Mellon
8(a)(ii). Relationship Start Date	12/19/2016
8(a)(iii). Title or Status	Parent entity
8(a)(iv). Ownership Code	E
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 5

8(a)(i). Full Name	The Bank of New York Mellon Corporation
8(a)(ii). Relationship Start Date	01/09/2008
8(a)(iii). Title or Status	Ultimate parent entity
8(a)(iv). Ownership Code	E
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 6

8(a)(i). Full Name	Michael DeNofrio
8(a)(ii). Relationship Start Date	03/12/2013
8(a)(iii). Title or Status	Vice President- US TA
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	12/31/2020

corporation or partner information Related to item 8 Record: 7

8(a)(i). Full Name	Sudish Panicker
8(a)(ii). Relationship Start Date	06/27/2016
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 8

8(a)(i). Full Name	Shailendra Pandey
8(a)(ii). Relationship Start Date	06/09/2017
8(a)(iii). Title or Status	Compliance Officer
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 9

8(a)(i). Full Name	Craig Bayer
8(a)(ii). Relationship Start Date	05/30/2018
8(a)(iii). Title or Status	Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 10

8(a)(i). Full Name	Nitin Chandel
8(a)(ii). Relationship Start Date	03/13/2019
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 11

8(a)(i). Full Name	Jasmin Ignatius
8(a)(ii). Relationship Start Date	03/13/2019
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	05/05/2022

corporation or partner information Related to item 8 Record: 12

8(a)(i). Full Name	Ann Fogarty
8(a)(ii). Relationship Start Date	03/13/2019
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	06/17/2020

corporation or partner information Related to item 8 Record: 13

8(a)(i). Full Name	Denise Sommerville
8(a)(ii). Relationship Start Date	03/13/2019
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date	05/08/2020

corporation or partner information Related to item 8 Record: 14

8(a)(i). Full Name	Francis Braeckevelt
8(a)(ii). Relationship Start Date	03/13/2019
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 15

8(a)(i). Full Name	Joanne Cash
8(a)(ii). Relationship Start Date	03/11/2021
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 16

8(a)(i). Full Name	Alexandra Waite Goodburn
8(a)(ii). Relationship Start Date	03/11/2021
8(a)(iii). Title or Status	Managing Director - US TA
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 17

8(a)(i). Full Name	Janet Menezes
8(a)(ii). Relationship Start Date	06/06/2022
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

corporation or partner information Related to item 8 Record: 18

8(a)(i). Full Name	Rajeev Bhatnagar
8(a)(ii). Relationship Start Date	03/20/2023
8(a)(iii). Title or Status	Board Director
8(a)(iv). Ownership Code	NA
8(a)(v). Control Person	Yes
8(a)(vi). Relationship End Date

9. Does any person or entity not named in the answer to Question 8:

9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant, or;….  Yes   No

9(b). wholly or partially finance the business of the applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others?…..  Yes   No

TA-1/A : 10. Applicant and Control Affiliate Disciplinary History

The following definitions apply for purposes of answering this Question 10

Control Affiliate	- An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority.
Investment or investment related	- Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association).
Involved	- Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act.

10(a). In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contendere ("no contest") to:

10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting, or extortion?  Yes   No

Entity information Related to item 10(a)(1) Record: 1

10(a)(1)(i). The individuals named in the Action	Pershing Securities Australia Pty. Ltd (Pershing Australia)
10(a)(1)(ii). Title of Action	Australian Securities & Investments Commission (ASIC) vs. Pershing Australia
10(a)(1)(iii). Date of Action	11/15/2019
10(a)(1)(iv). The Court or body taking the Action and its location	Downing Centre Local Court, Sydney, Australia
10(a)(1)(v). Description of the Action	Pershing Australia was charged with three counts under the Australian Corporations Act 2001 (the Act). On May 5, 2020, Pershing Australia pled guilty to two investment-related counts related to securities clearance and settlement. Australian law does not recognize misdemeanors or felonies, but the fine will exceed $1000. Sequence 1: Pled guilty to breaching s993C(1) between 30 June 2016 and 16 December 2017 through making payments out of a client money account that were not permitted by Reg 7.8.02 of the Corporations Regulations 2001. Sequence 3: Pled guilty to breaching s993B(1) between 25 January 2016 and 31 December 2018 by receiving money in connection with financial services, and then failing to pay that money into an account complying with the client money requirements within s981B of the Act. Sequence 2: Charged for a one-time underpayment of 1,044.65 Australian dollars to its trust account on 21 August 2017
10(a)(1)(vi). The disposition of the proceeding	On May 5, 2020, Pershing Australia pled guilty to Sequences 1 and 3, breaching s993C(1) and s993B(1) of the Act. Sentencing is expected to occur on July 27, 2020, and will consist only of a monetary fine and certain revised license conditions with ASIC.

10(a)(2). any other felony?  Yes   No

10(b). Has any court in the past ten years:
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity?	Yes   No

Entity information Related to item 10(b)(1) Record: 1

10(b)(1)(i). The individuals named in the Action	CIBC Mellon Trust Company
10(b)(1)(ii). Title of Action	U.S. Securities and Exchange Commission v. CIBC Mellon Trust Company
10(b)(1)(iii). Date of Action	01/14/2005
10(b)(1)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission ("SEC")
10(b)(1)(v). Description of the Action	CIBC Mellon Trust Company ("CMTC"), a transfer agent that is an affiliate of Registrant by virtue of Mellon Canada Holding Company's 50 percent interest in the joint venture, submitted a Consent to Entry of Judgment (the "Consent"), which was presented by the SEC in the U.S. District Court for the District of Columbia (the "Court") on February 16, 2005. In the Consent, and solely for the purpose of the injunctive action and any other proceedings arising out of the SEC's investigation brought by or on behalf of the SEC or to which the SEC is a party, CMTC consented to the entry of Final Judgment as to Defendant CMTC (the "Final Judgment") without admitting or denying the matters set forth therein (other than those relating to the jurisdiction of the Court and the subject matter of the action). The Final Judgment, entered on Feb. 24, 2005, resolved the allegations that CMTC had failed to register as a transfer agent with the SEC, that it had issued "legend free" stock certificates of a company whose shares were not registered with the SEC, that one of its managers had accepted payments of stock from that company's officers to issue the certificates, and that it had acted as an unregistered broker or dealer in connect n with its stock plan administration business. CMTC was permanently enjoined from prescribed violations of Securities Act Section 5, Exchange Act Section 10(b) and Rule 10b-5, Exchange Act Section 15(a), Exchange Act Section 17A(c)(1), and from aiding and abetting future violations of Exchange Act Section 10(b) or Rule 10b-5. CMTC also agreed to pay a civil monetary penalty of $5 million and disgorgement of $889,773 and prejudgment interest of $140,270. Payment was made on March 4, 2005. CMTC also consented, without admitting or denying the SEC complaint's allegations, to the entry of an SEC administrative order based on the Final Judgment on March 2, 2005 (the "Order"). Pursuant to the Order, CMTC was censured and agreed to an undertaking to engage an independent consultant to review its relevant businesses and procedures. This matter responds to items 10B(1) and 10C(2).
10(b)(1)(vi). The disposition of the proceeding	Entry of Judgment on consent. See item (v) above for detail

10(b)(2). found that the applicant or control affiliate was involved in a violation of investment-related statutes or regulations?  Yes   No

10 (c). Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:
10(c)(1). found the applicant or control affiliate to have made a false statement or omission?	Yes   No

Entity information Related to item 10(c)(1) Record: 1

10(c)(1)(i). The individuals named in the Action	One or more controlled affiliates- See attached file for Question 10 Data
10(c)(1)(ii). Title of Action	See attached file for Question 10 Data
10(c)(1)(iii). Date of Action	12/17/2007
10(c)(1)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(c)(1)(v). Description of the Action	See attached file for Question 10 Data
10(c)(1)(vi). The disposition of the proceeding	See attached file for Question 10 Data

Entity information Related to item 10(c)(1) Record: 2

10(c)(1)(i). The individuals named in the Action	The Bank of New York Mellon (the Bank)
10(c)(1)(ii). Title of Action	SEC Administrative Preceeding File No. 3-17268
10(c)(1)(iii). Date of Action	06/13/2016
10(c)(1)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(1)(v). Description of the Action	On June 13, 2016, the SEC finalized a settlement with the Bank, an affiliate of the Registrant, relating to the Bank's standing instruction foreign exchange ("FX") program. The SEC instituted a settled administrative proceeding against the Bank, finding that the Bank violated Section 34(b) of the Investment Company Act of 1940, and caused violations of Section 31(a) of the act and Rule 31a-1(b) thereunder. The order requires the Bank to cease and desist from such violations, pay a $30 million civil penalty, and disgorge $133,022,207 which is deemed satisfied by the Bank's prior payments in related settlements with the U.S. Attorney's Office for the Southern District of New York and The New York Attorney General. The order also requires the Bank to report on its remediation and implementation of compliance measures relating to its standing instruction FX programs offered to registered investment adviser custodial clients.
10(c)(1)(vi). The disposition of the proceeding	See 10(c)(1)(v) above.

10(c)(2). found the applicant or control affiliate to have been involved in a violation of its regulation or statutes?  Yes   No

Entity information Related to item 10(c)(2) Record: 1

10(c)(2)(i). The individuals named in the Action	One or more controlled affiliates- See attached file for Question 10 Data
10(c)(2)(ii). Title of Action	See attached file for Question 10 Data
10(c)(2)(iii). Date of Action	12/17/2007
10(c)(2)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(c)(2)(v). Description of the Action	See attached file for Question 10 Data
10(c)(2)(vi). The disposition of the proceeding	See attached file for Question 10 Data

Entity information Related to item 10(c)(2) Record: 2

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon
10(c)(2)(ii). Title of Action	SEC Admin. Proceeding File No. 3-12269
10(c)(2)(iii). Date of Action	04/24/2006
10(c)(2)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(2)(v). Description of the Action	The SEC alleged that The Bank of New York Mellon (formerly, The Bank of New York) ("BNY") failed as a transfer agent to exercise reasonable care to ascertain the correct addresses of lost security holders and escheated assets belonging to those security holders to various
10(c)(2)(vi). The disposition of the proceeding	See 10(c)(2)(v) above

Entity information Related to item 10(c)(2) Record: 3

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon
10(c)(2)(ii). Title of Action	SEC Admin. Proceeding File No. 3-12526
10(c)(2)(iii). Date of Action	01/09/2007
10(c)(2)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(2)(v). Description of the Action	The SEC alleged that from at least January 1, 2003 through June 30, 2004, in connection with certain auctions, The Bank of New York Mellon (formerly, The Bank of New York) ("BNY") accepted initial or revised bids after submission deadlines and allowed broker-dealers to intervene in auctions. In certain instances, this conduct also affected the rate paid on the auction rate securities. As a result, BNY caused violations of section 17(a)(2) of the Securities Act. BNY was required to make certain disclosures regarding its material auction practices and procedures; and not later than 6 months after the date of this order, unless otherwise extended by the Staff of the Commission for good cause shown, have its CEO or General Counsel certify in writing to the Staff of the Commission that BNY has implemented procedures. In addition, BNY paid a monetary settlement in the amount of $750,000.
10(c)(2)(vi). The disposition of the proceeding	See 10(c)(2)(v) above

Entity information Related to item 10(c)(2) Record: 4

10(c)(2)(i). The individuals named in the Action	CIBC Mellon Trust Company
10(c)(2)(ii). Title of Action	U.S. Securities and Exchange Commission v. CIBC Mellon Trust Company
10(c)(2)(iii). Date of Action	01/14/2005
10(c)(2)(iv). The Court or body taking the Action and its location	See 10(b)(1) above
10(c)(2)(v). Description of the Action	See 10(b)(1) above
10(c)(2)(vi). The disposition of the proceeding	See 10(b)(1) above

Entity information Related to item 10(c)(2) Record: 5

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon Corporation (BNY Mellon)
10(c)(2)(ii). Title of Action	SEC Release No. 34-75720
10(c)(2)(iii). Date of Action	08/18/2015
10(c)(2)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(2)(v). Description of the Action	The SEC staff alleged violations of the U.S. Foreign Corrupt Practices Act in connection with the provision of a limited number of internships to relatives of sovereign wealth fund officials.
10(c)(2)(vi). The disposition of the proceeding	An order was issued against BNY Mellon in the amount of $14,800,000, consisting of disgorgement fees of $8,300,000, prejudgment interest of $1,500,000 and a civil monetary penalty of $5,000,000. BNY Mellon effected payment on August 24, 2015.

Entity information Related to item 10(c)(2) Record: 6

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon (the Bank)
10(c)(2)(ii). Title of Action	SEC Administrative Preceding File No. 3-17268
10(c)(2)(iii). Date of Action	06/13/2016
10(c)(2)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(2)(v). Description of the Action	See 10(c)(1)(v) above.
10(c)(2)(vi). The disposition of the proceeding	See 10(c)(1)(v) above.

Entity information Related to item 10(c)(2) Record: 7

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon Corporation (BNY Mellon)
10(c)(2)(ii). Title of Action	SEC Release No. 34-79777;Administrative file no.3-17768
10(c)(2)(iii). Date of Action	01/12/2017
10(c)(2)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(2)(v). Description of the Action	The SEC Staff alleged violations of Sections 13(b)(2)(A) & (B) of the Securities Exchange Act of 1934 for books and records and internal regulatory accounting control deficiencies in connection with the calculation of risk-based regulatory capital ratios presented.
10(c)(2)(vi). The disposition of the proceeding	A civil money penalty in the amount of $6,600,000 was ordered to be paid by BNY Mellon. BNY Mellon will effect payment on a date TBD.

Entity information Related to item 10(c)(2) Record: 8

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon (BNY Mellon)
10(c)(2)(ii). Title of Action	SEC Release No. 33-10856; Administrative Proceeding File No. 3-18933
10(c)(2)(iii). Date of Action	12/17/2018
10(c)(2)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(2)(v). Description of the Action	This action arises out of the SEC's assertion that BNY Mellon, as depositary bank, engaged in improper practices in connection with the pre-release of American Depositary Receipts ("ADRs"). Specifically, the SEC staff alleged violations of Section 17(a)(3) of the Securities Act of 1933, which prohibits, in the offer or sale of securities, engaging in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser. As the SEC Order relates, (1) ADRs are negotiable instruments that trade on a U.S. market that represent an interest in a specified number foreign securities that have been deposited with a depositary bank or with the depositary bank's foreign custodian; (2) ADRs allow U.S. investors to invest in foreign companies without having to purchase shares in the foreign market; (3) in some situations, a person may seek to obtain ADRs through a "pre-release" transaction whereby a market participant obtains newly-issued ADRs from the depositary bank (as opposed to purchasing an existing ADR from the market) without having already delivered the corresponding ordinary shares to the custodian; (4) the traditional rationale for pre-release transactions was to address settlement timing disparities that could delay delivery to the foreign custodian of recently purchased ordinary shares; and (5) several instruments (the "Pre-Release Agreements"), including the agreements with the depositary bank, the ADR itself and pre-release agreements with the involved broker-dealers ("Pre-Release Brokers"), either included or required BNY Mellon to obtain representations from the Pre-Release Brokers stating that for the duration of each pre-release transaction, the Pre-Release Broker or its customer (I) beneficially owned corresponding ordinary shares, (ii) assigned all beneficial right, title, and interest in the shares to the depositary, (iii) would not take any action with respect to such shares that was inconsistent with the transfer of beneficial ownership, and (iv) would pay foreign withholding taxes at the rate required for ADR holders and pass through to the depositary any dividends and dividend-related tax credits or refunds. The SEC found that BNY Mellon (1) did not take reasonable steps to determine that the Pre-Release Brokers or their counterparties complied with the obligations set forth in the Pre-Release Agreements and (2) at times, negligently facilitated short selling and enabled the settlement of trades with some ADRs that were not actually backed by the ordinary shares held for the benefit of the depositary in accordance with the requirements of the ADR facility.
10(c)(2)(vi). The disposition of the proceeding	On 12/17/18 the SEC entered into an administrative settlement on a neither-admit-nor-deny basis with BNY Mellon in which BNY Mellon agreed to pay $29.3 million in disgorgement, prejudgment interest of $4.2 million and a civil penalty of $20.5 million.

Entity information Related to item 10(c)(2) Record: 9

10(c)(2)(i). The individuals named in the Action	The Bank of New York Mellon Corporation
10(c)(2)(ii). Title of Action	CFTC Docket No. 19-42
10(c)(2)(iii). Date of Action	09/30/2019
10(c)(2)(iv). The Court or body taking the Action and its location	Commodities Futures Trading Commission
10(c)(2)(v). Description of the Action	The CFTC alleged that BNYM failed to correctly report certain swap transactions to a swap data repository from December 31, 2012 through at least 2018, in violation of Sections 2a13G and 4ra3 of the Commodity Exchange Act, 7 U.S.C. 2a13), 6ra3 2012, and Regulations 43.3 and 45.3, 17 C.F.R. 43.3, 45.3 2019 the collectively, CFTC Rules.
10(c)(2)(vi). The disposition of the proceeding	On September 30, 2019, without admitting or denying any of the findings or conclusions, a settlement was reached in which BNY Mellon was ordered to cease and desist from violating the CFTC Rules and pay a civil monetary penalty in the amount of $750,000.

10(c)(3). found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?  Yes   No

Entity information Related to item 10(c)(3) Record: 1

10(c)(3)(i). The individuals named in the Action	One or more controlled affiliates - See attached file for Question 10 Data
10(c)(3)(ii). Title of Action	See attached file for Question 10 Data
10(c)(3)(iii). Date of Action	12/17/2007
10(c)(3)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(c)(3)(v). Description of the Action	See attached file for Question 10 Data
10(c)(3)(vi). The disposition of the proceeding	See attached file for Question 10 Data

10(c)(4). entered an order denying, suspending or revoking the applicant’s or control affiliate’s registration or otherwise disciplined it by restricting its activities?  Yes   No

Entity information Related to item 10(c)(4) Record: 1

10(c)(4)(i). The individuals named in the Action	One or more control affiliates - see attached file for Question 10 Data
10(c)(4)(ii). Title of Action	See attached file for Question 10 Data
10(c)(4)(iii). Date of Action	12/17/2007
10(c)(4)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(c)(4)(v). Description of the Action	See attached file for Question 10 Data
10(c)(4)(vi). The disposition of the proceeding	See attached file for Question 10 Data

Entity information Related to item 10(c)(4) Record: 2

10(c)(4)(i). The individuals named in the Action	The Bank of New York Mellon
10(c)(4)(ii). Title of Action	Sec Admin. Proceeding File No. 3-12526
10(c)(4)(iii). Date of Action	01/09/2007
10(c)(4)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(4)(v). Description of the Action	See 10(c)(2) above
10(c)(4)(vi). The disposition of the proceeding	See 10(c)(2) above

Entity information Related to item 10(c)(4) Record: 3

10(c)(4)(i). The individuals named in the Action	The Bank of New York Mellon
10(c)(4)(ii). Title of Action	SEC Admin. Proceeding File No. 3-12269
10(c)(4)(iii). Date of Action	04/24/2006
10(c)(4)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(4)(v). Description of the Action	See 10(c)(2) above
10(c)(4)(vi). The disposition of the proceeding	See 10(c)(2) above

Entity information Related to item 10(c)(4) Record: 4

10(c)(4)(i). The individuals named in the Action	The Bank of New York Mellon (the Bank)
10(c)(4)(ii). Title of Action	SEC Administrative Preceding File No. 3-17268
10(c)(4)(iii). Date of Action	06/13/2016
10(c)(4)(iv). The Court or body taking the Action and its location	The Securities and Exchange Commission (the "SEC")
10(c)(4)(v). Description of the Action	See 10(c)(1)(v) above.
10(c)(4)(vi). The disposition of the proceeding	See 10(c)(1)(v) above.

10(d). Has any other Federal regulatory agency or any state regulatory agency :
10(d)(1). ever found the applicant or control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical?	Yes   No

10(d)(2). ever found the applicant or control affiliate to have been involved in a violation of investment-related regulations or statutes?  Yes   No

Entity information Related to item 10(d)(2) Record: 1

10(d)(2)(i). The individuals named in the Action	One or more control affiliates - see attached file for Question 10 Data
10(d)(2)(ii). Title of Action	See attached file for Question 10 Data
10(d)(2)(iii). Date of Action	12/17/2007
10(d)(2)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(d)(2)(v). Description of the Action	See attached file for Question 10 Data
10(d)(2)(vi). The disposition of the proceeding	See attached file for Question 10 Data

Entity information Related to item 10(d)(2) Record: 2

10(d)(2)(i). The individuals named in the Action	The Bank of New York Mellon (BNYM)
10(d)(2)(ii). Title of Action	Docket No. 12-018-CMP-SMB
10(d)(2)(iii). Date of Action	12/01/2010
10(d)(2)(iv). The Court or body taking the Action and its location	Board of Governors of the Federal Reserve System ("BGFRS")
10(d)(2)(v). Description of the Action	On 9/22/08, BNYM borrowed from the Boston Federal Reserve Bank under the Asset-Backed Commercial Paper Money Market Mutual Fund Liquidity Facility ("AMLF") program.
10(d)(2)(vi). The disposition of the proceeding	The BGFRS and BNYM have mutually agreed to enter into a combined Order to Cease & Desist and Order of Assessment of a civil Monetary Penalty of $6,000,000.

Entity information Related to item 10(d)(2) Record: 3

10(d)(2)(i). The individuals named in the Action	BNY Mellon Fund Services (Ireland) DAC
10(d)(2)(ii). Title of Action	NA
10(d)(2)(iii). Date of Action	03/22/2022
10(d)(2)(iv). The Court or body taking the Action and its location	Central Bank of Ireland aka CBI
10(d)(2)(v). Description of the Action	In 2017, the CBI commenced an enforcement investigation against DAC, an Irish entity, in relation to the oversight of outsourced fund administration activities and related regulatory engagement. As part of the investigation, the CBI identified suspected breaches of Irish law/regulation between 2013 and 2019, which the CBI refers to as suspected prescribed contraventions.
10(d)(2)(vi). The disposition of the proceeding	DAC agreed to a settlement with the CBI pursuant to which the CBI reprimanded and fined DAC pursuant to its Administrative Sanctions Procedure (the ASP) for 16 regulatory breaches relating to the outsourcing of fund administration activities.

10(d)(3). ever found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business Denied, suspended, revoked or restricted?  Yes   No

10(d)(4). in the past ten years entered an order against the applicant or control affiliate in connection with investment-related activity?  Yes   No

Entity information Related to item 10(d)(4) Record: 1

10(d)(4)(i). The individuals named in the Action	One or more control affiliates - see attched file for Question 10 Data
10(d)(4)(ii). Title of Action	See attached file for Question 10 Data
10(d)(4)(iii). Date of Action	12/17/2007
10(d)(4)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(d)(4)(v). Description of the Action	See attached file for Question 10 Data
10(d)(4)(vi). The disposition of the proceeding	See attached file for Question 10 Data

Entity information Related to item 10(d)(4) Record: 2

10(d)(4)(i). The individuals named in the Action	Dreyfus Service Organization, Inc.
10(d)(4)(ii). Title of Action	Proceeding by the Commissioner of Banking and Ins. State of NJ Ref. No. 8059711
10(d)(4)(iii). Date of Action	09/08/2008
10(d)(4)(iv). The Court or body taking the Action and its location	State of New Jersey Department of Banking and Insurance, Trenton, New Jersey
10(d)(4)(v). Description of the Action	It was alleged that Dreyfus Service Organization ("DSO") between June 2002 and November 2002 "caused, permitted or was otherwise responsible for allowing an employee to solicit and write eight New Jersey annuity contracts without the benefit of a current license." DSO had an employee with a non-resident NJ insurance license which had expired and was later reinstated. The sales were made during the period when the employee's license was inactive, although DSO had reason to believe the license was, in fact, active. Without admitting or denying any violation of the insurance statutes or regulations or any wrongdoing, DSO consented to an administrative sanction in the amount of $4000.00 to fully and completely resolve the matter.
10(d)(4)(vi). The disposition of the proceeding	See 10(d)(4)(v) above

Entity information Related to item 10(d)(4) Record: 3

10(d)(4)(i). The individuals named in the Action	The Bank of New York Mellon (BNYM)
10(d)(4)(ii). Title of Action	Docket No. 12-018-CMP-SMB
10(d)(4)(iii). Date of Action	12/01/2010
10(d)(4)(iv). The Court or body taking the Action and its location	Board of Governors of the Federal Reserve System ("BGFRS")
10(d)(4)(v). Description of the Action	On 9/22/08, BNYM borrowed from the Boston Federal Reserve Bank under the Asset-Backed Commercial Paper Money Market Mutual Fund Liquidity Facility ("AMLF") program.
10(d)(4)(vi). The disposition of the proceeding	The BGFRS and BNYM have mutually agreed to enter into a combined Order to Cease & Desist and Order of Assessment of a Civil Monetary Penalty of $6,000,000.

Entity information Related to item 10(d)(4) Record: 4

10(d)(4)(i). The individuals named in the Action	The Bank of New York Mellon Corporation (BNYM) and Newton Investment Management Limited (NIM)
10(d)(4)(ii). Title of Action	CMP/01-2016/CA98
10(d)(4)(iii). Date of Action	02/21/2019
10(d)(4)(iv). The Court or body taking the Action and its location	U.K. FINANCIAL CONDUCT AUTHORITY (FCA)
10(d)(4)(v). Description of the Action	On 21 February 2019, FCA found that NIM, through the actions of a former employee in 2014 and 2015, shared information with three other UK investment advisors in relation to 2initial public offerings and 1 placing by UK issuers by disclosing the price intended to pay, or accepting such information, or both, shortly before the share prices were set. The FCA found that parts of this conducts violated the UK Competition Act 1998. NIM self-reported this matter to the FCA following identification of the issue. The former employee's actions contravened NIM's code of conduct and ethical standards, and the employee has since been dismissed. BNYM was found jointly and severally liable by reason if being NIM's ultimate parent company. Neither BNYM nor any of its employees was involved in any aspect of the relevant conduct and there has been no allegation nor negative finding by the FCA in respect of the conduct of BNYM.
10(d)(4)(vi). The disposition of the proceeding	The FCA issued their decision on 21 February 2019. The FCA's findings are provisional and the parties are entitled to make written and oral representations on them. Following any such representations by the parties, the FCA will make its final decision.

10(d)(5). ever denied, suspended, or revoked applicant’s or control affiliate’s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities?  Yes   No

Entity information Related to item 10(d)(5) Record: 1

10(d)(5)(i). The individuals named in the Action	One or more control affiliates - see attached file for Question 10 Data
10(d)(5)(ii). Title of Action	See attached file for Question 10 Data
10(d)(5)(iii). Date of Action	12/17/2007
10(d)(5)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(d)(5)(v). Description of the Action	See attached file for Question 10 Data
10(d)(5)(vi). The disposition of the proceeding	See attached file for Question 10 Data

10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant?  Yes   No

10(e). Has any self-regulatory organization or commodities exchange ever:

10(e)(1). found the applicant or a control affiliate to have made a false statement or omission?  Yes   No

Entity information Related to item 10(e)(1) Record: 1

10(e)(1)(i). The individuals named in the Action	One or more control affiliates - see attached file for Question 10 Data
10(e)(1)(ii). Title of Action	See attached file for Question 10 Data
10(e)(1)(iii). Date of Action	04/14/2009
10(e)(1)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(e)(1)(v). Description of the Action	See attached file for Question 10 Data
10(e)(1)(vi). The disposition of the proceeding	See attached file for Question 10 Data

10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules?  Yes   No

Entity information Related to item 10(e)(2) Record: 1

10(e)(2)(i). The individuals named in the Action	One or more control affiliates - see attached file for Question 10 Data
10(e)(2)(ii). Title of Action	See attached file for Question 10 Data
10(e)(2)(iii). Date of Action	12/17/2007
10(e)(2)(iv). The Court or body taking the Action and its location	See attached file for Question 10 Data
10(e)(2)(v). Description of the Action	See attached file for Question 10 Data
10(e)(2)(vi). The disposition of the proceeding	See attached file for Question 10 Data

10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business?  Yes   No

10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities?  Yes   No

10(f). Has any foreign government, court, regulatory agency or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud?  Yes   No

Entity information Related to item 10(f) Record: 1

10(f)(i). The individuals named in the Action	The Bank of New York Mellon Corporation
10(f)(ii). Title of Action	Administrative Order Imposing a Fine
10(f)(iii). Date of Action	11/14/2010
10(f)(iv). The Court or body taking the Action and its location	Bundesanstalt fur Finanzdienstleistungsaufscht - Germany
10(f)(v). Description of the Action	Bundesanstalt fur Finanzdienstleistungsaufscht the (BaFin), the financial supervisory authority in Germany, alleged that The Bank of New York Mellon Corporation (BNY Mellon)required under the Act to prevent contravention of the shareholding notice obligations by its subsidiaries. On May 12, 2011 the BaFin issued an administrative order that: (1) determined that BNY Mellon negligently failed to comply with the supervisory requirements with respect to its subsidiaries in order to ensure compliance with the notification deadlines and (2) imposed against BNY Mellon an administrative fine of EUR 22,500.00 (approx. $31,725) and a fee (for procedural costs) of EUR 1,125.00 (approx. $1,586). BNY Mellon made payment effective May 27, 2011.
10(f)(vi). The disposition of the proceeding	See response in 10(f)(v)

Entity information Related to item 10(f) Record: 2

10(f)(i). The individuals named in the Action	The Bank of New York Mellon - London Branch (BNYM)
10(f)(ii). Title of Action	Docket No. 122467
10(f)(iii). Date of Action	02/24/2014
10(f)(iv). The Court or body taking the Action and its location	U.K. Financial Conduct Authority
10(f)(v). Description of the Action	The U.K. Financial Conduct Authority alleged that BNYM failed to comply with certain rules set forth in the U.K. Clients Assets Sourcebook, which sets forth the regime in the U.K. for the protection of client interests.
10(f)(vi). The disposition of the proceeding	BNY Mellon entered into a settlement agreement with the UK Financial Conduct Authority (the "FCA") on March 6, 2015, and the FCA issued its Final Notice, in which the 126 million pounds (approx. $188M) fine was imposed, on April 14, 2015.

Entity information Related to item 10(f) Record: 3

10(f)(i). The individuals named in the Action	The Bank of New York Mellon Corporation (BNYM) and Newton Investment Management Limited (NIM)
10(f)(ii). Title of Action	CMP/01-2016/CA98
10(f)(iii). Date of Action	02/21/2019
10(f)(iv). The Court or body taking the Action and its location	U.K. FINANCIAL CONDUCT AUTHORITY (FCA)
10(f)(v). Description of the Action	On 21 February 2019, FCA found that NIM, through the actions of a former employee in 2014 and 2015, shared information with three other UK investment advisors in relation to 2initial public offerings and 1 placing by UK issuers by disclosing the price intended to pay, or accepting such information, or both, shortly before the share prices were set. The FCA found that parts of this conducts violated the UK Competition Act 1998. NIM self-reported this matter to the FCA following identification of the issue. The former employee's actions contravened NIM's code of conduct and ethical standards, and the employee has since been dismissed. BNYM was found jointly and severally liable by reason if being NIM's ultimate parent company. Neither BNYM nor any of its employees was involved in any aspect of the relevant conduct and there has been no allegation nor negative finding by the FCA in respect of the conduct of BNYM.
10(f)(vi). The disposition of the proceeding	The FCA issued their decision on 21 February 2019. The FCA's findings are provisional and the parties are entitled to make written and oral representations on them. Following any such representations by the parties, the FCA will make its final decision.

10(g). Is the applicant or a control affiliate now the subject of a proceeding that could result in a yes answer for questions 10(a) – 10(f) ?  Yes   No

Entity information Related to item 10(g) Record: 1

10(g)(i). The individuals named in the Action	The Bank of New York Mellon Corporation (BNYM)
10(g)(ii). Title of Action	CMP/01-2016/CA98
10(g)(iii). Date of Action	11/29/2017
10(g)(iv). The Court or body taking the Action and its location	U.K. Financial Conduct Authority (FCA), England
10(g)(v). Description of the Action	The FCA has made provisional findings that BNYM is jointly and severally liable for certain conduct of its subsidiary Newton Investment Management Limited (NIM) solely by reason of being NIM's parent company. Neither BNYM nor any of its employees was involved in any aspect of the relevant conduct. The FCA has made provisional findings that NIM shared information with three other U.K. investment advisers in relation to two Initial Public Offerings (IPOs) and one placing by U.K. issuers by disclosing the price it intended to pay, or accepting such information, or both, shortly before the share prices were set. The FCA has provisionally concluded that the conduct infringed the prohibition imposed by section 2(1) of the U.K. Competition Act 1998 and Article 101 of the Treat on the Functioning of the European Union which prohibit concerted practices which have as their object the prevention, restriction or distortion of competition.
10(g)(vi). The disposition of the proceeding	FCA's findings are provisional and the parties are entitled to make written and oral representations on them. Following any such representations, the FCA will make its final decision which the parties can challenge before the Competition Appeal Tribunal.

10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate?  Yes   No

10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it?  Yes   No

TA-1/A : Signature

ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a) SIGNATURE: The registrant submitting this form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.

11(a). Signature of Official responsible for Form:	Alexandra Waite Goodburn
11(b). Telephone Number:	44 207-163-5294
11(c). Title of Signing Officer:	Managing Director - US TA
11(d). Date Signed (Month/Day/Year):	07/05/2023