EFTA Document EFTA01358942

Page 8 SANCTN funds managed by affiliates of Apollo Global Management, LLC. After receiving this nonpublic information from Whelehan, on January 22, 2016, Tsai purchased 1,500 shares of ADT stock. On that same day, Tsai also recommended to a close relative to purchase ADT stock. Later that day, Tsai's close relative purchased 343 shares of ADT stock. Whelehan did not trade in ADT stock. According to the complaint, when ADT's acquisition was announced on February 16, 2016, its stock price