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MORGAN STANLEY DATA SECURITY SETTLEMENT

In re Morgan Stanley Data Security Litigation, 1:20-cv-05914-AT (S.D.N.Y.)

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IF YOU ARE A FORMER OR CURRENT MORGAN STANLEY CLIENT WHO WAS SENT A DATA BREACH
NOTICE LETTER IN JULY 2020 AND/OR JUNE 2021 NOTIFYING YOU THAT YOUR PERSONAL
INFORMATION MAY HAVE BEEN COMPROMISED IN DATA SECURITY INCIDENTS, YOU MAY BE
ELIGIBLE FOR BENEFITS FROM THIS CLASS ACTION SETTLEMENT.

A Settlement has been reached with Morgan Stanley Smith Barney LLC (“Morgan
Stanley” or “Defendant”) in a class action lawsuit regarding the decommissioning
or retiring of information technology (“IT”) equipment that contained client
data that occurred in 2016 and 2019 (“the Data Security Incidents”). Morgan
Stanley issued notices to customers regarding the Data Security Incidents in
July 2020 and/or June 2021. The Settlement, if approved, would create a fund of
$60 million, which will be used to provide substantial benefits to Settlement
Class Members including at least 24-months of fraud insurance coverage,
reimbursement to the members of the Settlement Class who file a valid claim for
out-of-pocket losses and lost time researching and remedying the effects of the
Data Security Incidents, as well as to pay Plaintiffs’ attorneys’ fees, costs,
and expenses, and a service award for each of the named Plaintiffs.

In addition, Morgan Stanley will hire a third party to work for a period of 12
months to attempt to locate and retrieve additional IT devices which have been
sold to third parties. Morgan Stanley will also separately pay reasonable costs
of notice and administration of the Settlement.

The lawsuit asserts claims against Morgan Stanley relating to the Data Security
Incidents. Plaintiffs allege that in 2016 and 2019, Morgan Stanley failed to
properly dispose of certain IT assets and that, as a result, unauthorized third
parties may have gained access to Morgan Stanley’s clients’ private information,
including, but not limited to, names, work and home addresses, Social Security
numbers, driver’s license numbers, income, asset value, asset holding
information, passport information, telephone numbers, dates of birth and other
personal information (collectively, “PII”). Some of these devices that may
contain customer PII were sold on the internet and/or remain unaccounted for.

Morgan Stanley denies all the claims, denies any liability whatsoever, and
believes that no member of the Settlement Class, including Plaintiffs, has
sustained any damages or injuries due to the Data Security Incidents.

The Settlement Class includes all individuals with existing or closed Morgan
Stanley accounts established in the United States who received the notice
letters sent by Morgan Stanley regarding the Data Security Incidents in July
2020 and/or June 2021. If you are a member of the Settlement Class, you should
have received a Settlement notice from the Settlement Administrator in the mail
or by email. That Notice includes a unique code for you to verify your identity
to receive certain Settlement benefits. If for some reason you have not received
a unique code, but believe you are a Settlement Class Member, please call
1-855-604-1744 (Toll-Free) to verify your identity and receive further
information.


Your Legal Rights and Options in This Settlement

Submit a Claim Form
Postmarked by June 2, 2022 This is the only way to receive a monetary payment
for losses suffered as a result of the Data Security Incidents. You can file a
claim by filing online here, downloading a copy of the Claim Form from the
Documents page and mailing it in, or you may call 1-855-604-1744 (Toll-Free) and
ask that a Claim Form be mailed to you. For detailed information on how to
submit a Claim Form, see FAQ 9. Ask to be Excluded from the Settlement
Postmarked by May 3, 2022 You will not receive a payment or any other Settlement
benefits, but you will retain the right to bring your own action against Morgan
Stanley related to the Data Security Incidents. This is the only option that
allows you to bring a separate action against Morgan Stanley related to the Data
Security Incidents. For detailed information on how to exclude yourself from the
Settlement, see FAQ 15. Object to the Settlement
Postmarked by May 3, 2022 You may write to the Court about why you do not like
the Settlement. You may also write the Court about why you support the
Settlement. For detailed information on how to object to or comment on the
Settlement, see FAQ 18. Go to the Final Approval Hearing
June 8, 2022, at 11:00 a.m. ET You may ask to speak in Court about the fairness
of the Settlement. If you wish to speak at the Final Approval Hearing, you must
make a request to do so in your written objection or comment. Do Nothing If you
do nothing, you will not get a monetary payment from this Settlement. If the
Court grants final approval, you will be entitled to enroll in Aura’s Financial
Shield Services for a period of at least 24 months from the Effective Date of
the Settlement, which will provide broad fraud insurance coverage. You will give
up rights to submit a claim in this Settlement or to bring a separate action
against Morgan Stanley related to the Data Security Incidents.

These rights and options—and the deadlines to exercise them—are explained
further on the Frequently Asked Questions page of this website.


Current Status

The Court in charge of this case must still decide whether to approve the
Settlement and the requested attorneys’ fees and expenses. No Settlement
benefits or payments will be provided unless the Court approves the Settlement
and it becomes Final.


Important Dates
 * May 3, 2022
   Deadline to Exclude Yourself from the Settlement
 * May 3, 2022
   Deadline to Object to the Settlement
 * June 2, 2022
   Deadline to File a Claim Form
 * June 8, 2022, at 11:00 a.m. ET
   Final Approval Hearing



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Questions? Contact the Settlement Administrator at
info@MorganStanleyDataSecuritySettlement.com or 1-855-604-1744 (toll-free).

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