You may have received a Notice of Class Action Settlement (“Notice”) because the records of the KPMG 401(k) Capital Accumulation Plan, formerly known as the KPMG 401(k) Plan, and each of its predecessor plans or successor plans, individually and collectively (the “Plan”), indicate that you were a participant in the Plan during the period October 26, 2015, through March 4, 2024 (the “Class Period”). As such, your rights may be affected by a proposed settlement of this class action lawsuit (the “Settlement”).
The Notice contains summary information with respect to the Settlement. The complete terms and conditions of the Settlement are set forth in a Settlement Agreement (“Settlement Agreement”).
| YOUR LEGAL RIGHTS AND OPTIONS UNDER THE SETTLEMENT | |
| YOU ARE NOT REQUIRED TO FILE A CLAIM IF YOU ARE ENTITLED TO A PAYMENT UNDER THE SETTLEMENT AGREEMENT. | If the Settlement is approved by the Court and you are a member of the Settlement Class, you will not need to file a claim in order to receive a Settlement payment if you are entitled to receive a payment under the Settlement Agreement. |
| HOW SETTLEMENT PAYMENTS WILL BE DISTRIBUTED. | If you currently have a positive account balance in the Plan and are a Settlement Class member, any share of the Net Settlement Amount to which you are entitled will be deposited into your Plan account. If you are a Former Participant (i.e., no longer a participant in the Plan) and are a Settlement Class member, such funds shall be paid directly to you by the Settlement Administrator. |
| YOU MAY OBJECT TO THE SETTLEMENT BY JUNE 21, 2024. | If you wish to object to any part of the Settlement, you may write to the Court and the attorneys for the Parties about why you object to the Settlement. See further information in the Notice. |
| YOU MAY ATTEND THE FAIRNESS HEARING TO BE HELD ON JULY 22, 2024. | If you submit a written objection to the Settlement to the Court and counsel before the Court-approved deadline, you may (but do not have to) attend the Fairness Hearing about the Settlement and present your objections to the Court. You may attend the Fairness Hearing even if you do not file a written objection, but you will only be allowed to speak at the Fairness Hearing if you file a written objection by the Court-approved deadline in advance of the Fairness Hearing AND you file a Notice of Intention to Appear, as described in the answer to Question 16 in the Notice. |
Your options are explained in the Notice. This is only a summary of the proposed settlement. For the precise terms and conditions of the settlement, please see the Settlement Agreement. Alternatively, you can contact the Settlement Administrator or Class Counsel.
You should contact Class Counsel with any questions regarding this Settlement. YOU SHOULD NOT CONTACT THE COURT, KPMG, OR COUNSEL FOR THE DEFENDANTS. THEY WILL NOT BE ABLE TO ANSWER YOUR QUESTIONS.