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It sets the Execution Date, requires a one-time lump-sum settlement payment of $37,500,000 within ten business days, and provides timing and procedures for dismissal with prejudice. It also establishes escrow disbursement, dismissal-document mechanics, termination rights, and consequences including nullification, restoration of the parties’ positions, and return of the settlement with interest, plus a broad mutual release framework.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/settlement-agreement-and-release-execution-and-settlement-terms/281658/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/settlement-agreement-and-release-execution-and-settlement-terms/281658.png","ImageObject",442,249,{"name":88,"@type":89},"Jasmine","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-27","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":20},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"When is the settlement payment due and how is it made?","Question",{"text":108,"@type":109},"Defendants must make a one-time lump-sum payment of $37,500,000 within ten business days after the Execution Date, payable to Plaintiff via wire instructions provided by Plaintiff.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What steps are required to dismiss the lawsuit?",{"text":113,"@type":109},"Within five business days after Plaintiff receives the settlement payment, Plaintiff’s counsel must file a motion for an order of voluntary dismissal with prejudice in the Circuit Court of Cook County, substantially in the form of Exhibit B.",{"name":115,"@type":106,"acceptedAnswer":116},"What happens if the agreement is terminated?",{"text":117,"@type":109},"If terminated under the specified conditions, the settlement becomes null and void, the parties are restored to their positions as of the Execution Date, and Plaintiff must return the settlement amount, including any interest, within two business days of termination.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},281658,1790249751,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":20,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":79},2336478487870,"https://ap-avatar.wpscdn.com/davatar_085a072bc5b1113ac321206ff7593b45","# SETTLEMENT AGREEMENT AND RELEASE\n\nThis settlement agreement(“Agreement”)is made as of this 8th day of April 2016,between and among Plaintiff Federal Home Loan Bank of Chicago(“Plaintiff),and DefendantsThe Goldman Sachs Group,Inc.,Goldman,Sachs &Co.,GS Mortgage Securities Corp.andGoldman Sachs Mortgage Co.(collectively,“Defendants”)(each of the Plaintiff or Defendantsmay be referred to herein as a “Party”or“Settling Signatory,\"and collectively as the \"Parties”or“Settling Signatories”).  \nWHEREAS,Plaintiff asserted claims against Defendants in the action pending in theCircuit Court of Cook County,styled Federal Home Loan Bank of Chicago v.Banc of AmericaFunding Corp.,et al.No.10 CH 45033(Cook County Ch.Ct.,filed Apr.8,2011)(the\"Lawsuit\");  \nWHEREAS,the Lawsuit alleges claims in connection with the offering and sale ofcertain United States mortgage-related securities issued,underwritten,and/or sold by Defendantsas listed in Exhibit A attached hereto (the “RMBS”);  \nWHEREAS,Defendants deny the allegations in the Lawsuit and all claims ofwrongdoing,damages,and any liability whatsoever to Plaintiff;  \nWHEREAS,without conceding the merit or lack of merit of any claim or defense or theexistence of any liability whatsoever,the Settling Signatories wish to settle,compromise,andfinally and forever resolve all matters,controversies,disputes,and claims that may exist betweenthe Parties relating to the subject matter of the Lawsuit,including without limitation any claimsin respect of the RMBS that were or could have been asserted in the Lawsuit by Plaintiff,including the released claims described herein;  \nNOW,THEREFORE,in consideration of the mutual covenants and promises set forthin this Agreement,and for other good and valuable consideration,the adequacy and sufficiencyof which are hereby acknowledged,the Settling Signatories agree as follows:  \n1.EXECUTION DATE.As used in this Agreement,the “Execution Date”shallmean the date as of which the Agreement is fully executed.  \n2.   SETTLEMENT AMOUNT.In consideration of the release and dismissal ofPlaintiff's claims against the Defendants'Released Parties as set forth herein,within ten(10)business days after the Execution Date,Defendants shall make or cause to be made a one-time,lump sum payment of thirty-seven million,five hundred thousand dollars($37,500,000.00)(the\"Settlement Amount\"),payable to Plaintiff,pursuant to wire instructions to be separatelyprovided by Plaintiff to Defendants.  \n(a)The Settlement Amount to be paid out of the escrow account(as that termis definedin Defendants’related agreement with the United States Department of Justice)shallbe disbursed from the Escrow Account in accordance with Paragraph 3,below.There shall beno other condition of escrow or release whatsoever.  \n3.   DISMISSAL OF THE LAWSUIT.Within five(5)business days after thePlaintiff's receipt of the payment of the Settlement Amount by Defendants,counsel for Plaintiffwill file in the Circuit Court of Cook County,a motion for an order of voluntary dismissal withprejudice—substantially in the form attached hereto as Exhibit B.The documents described inthis Paragraph 3 shall be referred to collectively herein as the “Dismissal Documents.”EachParty shall take such further actions as may be necessary to obtain immediate dismissal withprejudice of the claims against Defendants in the Lawsuit,with each side to bear its own costsand disbursements.  \n4..  TERMINATION PROVISIONS.  \n(a)  Defendants may terminate or enforce this Agreement in the event that theDismissal Documents are not filed within the time set forth in Paragraph 3 above.  \n(b)  Plaintiff may terminate or enforce this Agreement in the event thatDefendants fail to make payment in accordance with Paragraph 2 above.  \n(c)   In the event of termination by Defendants or Plaintiff pursuant to theforegoing Paragraphs 4(a)or 4(b):(i)the Settlement will become null and void and withoutforce or effect on the Parties;(ii)the Parties shall be restored to their r","cbCain4o4bpulWIS","https://ap.wps.com/l/cbCain4o4bpulWIS","pdf",948914,10,"English","# Settlement Agreement and Release\n## Definitions and Parties\n## Settlement Amount\n## Dismissal of the Lawsuit\n## Termination Provisions\n## Release","[{\"question\":\"When is the settlement payment due and how is it made?\",\"answer\":\"Defendants must make a one-time lump-sum payment of $37,500,000 within ten business days after the Execution Date, payable to Plaintiff via wire instructions provided by Plaintiff.\"},{\"question\":\"What steps are required to dismiss the lawsuit?\",\"answer\":\"Within five business days after Plaintiff receives the settlement payment, Plaintiff’s counsel must file a motion for an order of voluntary dismissal with prejudice in the Circuit Court of Cook County, substantially in the form of Exhibit B.\"},{\"question\":\"What happens if the agreement is terminated?\",\"answer\":\"If terminated under the specified conditions, the settlement becomes null and void, the parties are restored to their positions as of the Execution Date, and Plaintiff must return the settlement amount, including any interest, within two business days of termination.\"}]","SETTLEMENT AGREEMENT AND RELEASE - Execution and Settlement Terms | PDF",1789567278]