Epstein Secrets

date of the debentures, the debentures will be treated as indebtedness for U.S. federal income tax purposes. However, there can be no assurance that the Internal Revenue Service ("IRS") or a court will agree with our determination. No ruling is being sought from the IRS on any of the issues discussed herein. S-24 EFTA_R1_0

"Item IA. Risk Factors" of our Annual Report on Form 10-K for the year ended December 31, 2015 before purchasing any of the debentures. Trustee The Bank of New York Mellon. Governing Law The debentures will be governed by the laws of the State of New York. S-3 EFTA_R1_02074080 EFTA02702274 RISK FACTORS Before

y may obtain a refund of any amounts withheld under the backup withholding rules that exceed your income tax liability by filing a refund claim with the Internal Revenue Service. THE PRECEDING DISCUSSION OF THE MATERIAL UNITED STATES FEDERAL INCOME TAX CONSEQUENCES IS FOR GENERAL INFORMATION PURPOSES ONLY AND IS NOT BEING

Statements" and "Risk Factors" to the Company's consolidated businesses, operations and prospects). all references in this prospectus supplement to "The Bank of New York Mellon Corporation","BNY Mellon","we","our" and "us" mean The Bank of New York Mellon Corporation and do not include its consolidated subsidiaries. Refere

de at this time, and upon a particular Member's individual circumstances. No advance rulings have been or will be sought by the AlphaKeys Fund from the Internal Revenue Service (the "IRS") regarding any matter discussed in this Memorandum. IN VIEW OF THE FOREGOING, EACH PROSPECTIVE INVESTOR SHOULD CONSULT ITS OWN TAX ADVI

AlphaKeys Fund to limit the transferability of Interests to Benefit Plan Investors or to Disregarded Parties. Ropes & Gray LLP Ernst & Young LLP The Bank of New York Mellon ER305378-MAXWELL -21- CONFIDENTIAL UBSTERFtAMAR00001802 EFTA00237433 ER305378-MAXWELL -22- CONFIDENTIAL UBSTERFtAMAR00001803 EFTA00237434

uld result to Investors in the AlphaKeys Fund. The AlphaKeys Fund may, from time to time, report tax positions that may be subject to challenge by the Internal Revenue Service (the "IRS"). If the IRS challenges such a position and is successful, there may be substantial retroactive taxes, plus interest and possibly penalti

out herein concerning the AlphaKeys Fund or the Administrator, other service providers and their affiliates and personnel. Custodian/Escrow Agent The Bank of New York Mellon (the "Custodian") serves as the primary custodian of the assets of the AlphaKeys Fund, and may maintain custody of such assets with domestic and non