The Long Form Notice provides information about the Settlement of all economic loss claims relating to the Recalls filed in the United States District Court for the Southern District of New York in In re: General Motors Ignition Switch Litigation, Case No. 14-MD-2543 (JMF) (“MDL 2543”), as well as those filed in the past, present or future in any federal or state court or other tribunal, and all economic loss claims in the chapter 11 case pending in the United States Bankruptcy Court captioned In re Motors Liquidation Company, et al., f/k/a General Motors Corp., et al., Case No. 09-50026 (MG) filed in the United States Bankruptcy Court for the Southern District of New York (collectively, the “Actions”). These economic loss claims are made by current and former owners and lessees of GM vehicles containing ignition switches, side airbag wiring, and/or electronic power steering systems that were subject to recalls with the National Highway Traffic Safety Administration (“NHTSA”) recall numbers listed below.

The Long Form Notice explains the terms of the Settlement and your legal rights.

Plaintiffs filed proposed class claims against New GM in the MDL 2543 Court and the GUC Trust in the Bankruptcy Court claiming that consumers overpaid when they bought or leased GM vehicles that were subject to the Recalls. New GM, the GUC Trust and the AAT deny these allegations. The Plaintiffs, New GM, the GUC Trust and the AAT (together the “Parties”) negotiated the Settlement to resolve these claims, as well as the economic loss claims for these Recalls that have been or may be asserted by the Class against New GM, the GUC Trust, the AAT and certain other released parties (collectively with the Plaintiffs, the “Class Members”). The Settlement avoids the risk and cost of a trial and provides Settlement benefits to Class Members. The Plaintiffs and their attorneys think that the Settlement is in the best interests of all Class Members and that it is fair, reasonable, and adequate.

If you fall under one of the categories below, you may be a Class Member. The Class, which is for Settlement purposes only, is defined as:

All Persons who, at any time as of or before the Recall Announcement Date of the Recall(s) applicable to the Subject Vehicle, own(ed), purchase(d), and/or lease(d) a Subject Vehicle in any of the fifty States, the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, and all other United States territories and/or possessions.

Some persons, however, are excluded from the Class, including daily fleet rental companies, governmental entities, authorized GM dealers and persons who already released their claims as part of a different settlement.

The Class is comprised of the five Subclasses below (the “Subclasses”). If a Class Member owned and/or leased more than one Subject Vehicle or a Subject Vehicle subject to more than one Recall, they may be in more than one Subclass:

• Subclass 1: The Delta Ignition Switch Subclass, comprised of those Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to NHTSA Recall No. 14v047.
• Subclass 2: The Key Rotation Subclass, comprised of those Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to NHTSA Recall Nos. 14v355, 14v394, and 14v400.
• Subclass 3: The Camaro Knee-Key Subclass, comprised of those Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to NHTSA Recall No. 14v346.
• Subclass 4: The Electronic Power Steering Subclass, comprised of those Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to NHTSA Recall No. 14v153.
• Subclass 5: The Side Airbag Subclass, comprised of those Class Members who own(ed), purchase(d), and/or lease(d) a Subject Vehicle subject to NHTSA Recall No. 14v118.

The Subject Vehicles are:

1. "Production Part Recall 14v047 Vehicles,” which are those 2005-2007 Chevrolet Cobalt vehicles not also subject to Recall 14v153, those 2004-2007 Saturn Ion vehicles not also subject to Recall 14v153, 2006-2007 Chevrolet HHR vehicles, those 2007 Pontiac G5 vehicles not also subject to Recall 14v153, some 2005-2006 Pontiac Pursuit vehicles imported into the United States not also subject to Recall 14v153, 2007 Saturn Sky vehicles, 2003 Saturn Ion vehicles, and 2006-2007 Pontiac Solstice vehicles. The Recall Announcement Date for the Production Part Recall 14v047 Vehicles is February 28, 2014.
2. "Production Part Recall 14v047 Vehicles also subject to Recall 14v153,” which are those 2005-2007 Chevrolet Cobalt vehicles subject to both Recalls, those 2007 Pontiac G5 vehicles subject to both Recalls, some 2004-2007 Saturn Ion vehicles, and some 2005-2006 Pontiac Pursuit vehicles imported into the United States subject to both Recalls. The Recall Announcement Date for the Production Part Recall 14v047 Vehicles also subject to Recall 14v153 is March 31, 2014.
3. "Service Part Recall 14v047 Vehicles,” which are those 2008-2010 Chevrolet Cobalt vehicles not also subject to Recall 14v153, 2008 and 2011 Chevrolet HHR vehicles, those 2009-2010 Chevrolet HHR vehicles not also subject to Recall 14v153, those 2008-2010 Pontiac G5 vehicles imported into the United States not also subject to Recall 14v153, 2008-2010 Saturn Sky vehicles, and 2008-2010 Pontiac Solstice vehicles. The Recall Announcement Date for these Service Part Recall 14v047 Vehicles is March 31, 2014. Additionally, for 105 vehicles of various other makes, models and model years as identified by VINs provided by New GM for such Subject Vehicles to the Class Action Settlement Administrator, the Recall Announcement Date is August 31, 2014.
4. "Service Part Recall 14v047 Vehicles also subject to Recall 14v153,” which are those 2008-2010 Chevrolet Cobalt vehicles subject to both Recalls, those 2009-2010 Chevrolet HHR vehicles subject to both Recalls, and those 2008-2010 Pontiac G5 vehicles imported into the United States subject to both Recalls. The Recall Announcement Date for the Service Part Recall 14v047 Vehicles also subject to Recall 14v153 is March 31, 2014.
5. "Recall 14v346 Vehicles,” which are 2010-2014 Chevrolet Camaro vehicles. The Recall Announcement Date for the Recall 14v346 Vehicles is June 30, 2014.
6. "Recall 14v355 Vehicles,” which are 2005-2009 Buick Lacrosse vehicles, 2000 and 2006-2013 Chevrolet Impala vehicles, 2014 Chevrolet Impala Limited vehicles, 2000-2005 Cadillac Deville vehicles, 2006-2011 Cadillac DTS vehicles, 2006-2011 Buick Lucerne vehicles, 2006-2007 Chevrolet Monte Carlo vehicles, 2005-2009 Buick Allure vehicles, 2004 Buick Regal vehicles, 2002-2009 Cadillac Commercial Chassis vehicles, and 2000-2011 Cadillac Professional Chassis vehicles. The Recall Announcement Date for the Recall 14v355 Vehicles is June 30, 2014.
7. "Recall 14v394 Vehicles,” which are those 2003-2014 Cadillac CTS vehicles as identified by VINs provided by New GM for such Subject Vehicles to the Class Action Settlement Administrator, and those 2004-2006 Cadillac SRX as identified in the list of VINs provided by New GM for such Subject Vehicles to the Class Action Settlement Administrator, and 2004-2007 Cadillac CTS-V vehicles. The Recall Announcement Date for the Recall 14v394 Vehicles is July 31, 2014, except that the Recall Announcement Date is August 31, 2014 for 2012-2014 Cadillac CTS vehicles and those 2011 Cadillac CTS vehicles as identified in the list of VINs provided by New GM for such Subject Vehicles to the Class Action Settlement Administrator.
8. "Recall 14v400 Vehicles,” which are 1997-2003 Chevrolet Malibu vehicles, 2000-2005 Chevrolet Impala vehicles, 2000-2005 Chevrolet Monte Carlo vehicles, 2004-2005 Chevrolet Classic vehicles, 1999-2004 Oldsmobile Alero vehicles, 1998-2002 Oldsmobile Intrigue vehicles, 1999-2005 Pontiac Grand Am vehicles, and 2004-2008 Pontiac Grand Prix vehicles. The Recall Announcement Date for the Recall 14v400 Vehicles is July 31, 2014.
9. "Recall 14v118 Vehicles,” which are those 2008-2009 Buick Enclave vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, 2010-2013 Buick Enclave vehicles, those 2009 Chevrolet Traverse vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, 2010-2013 Chevrolet Traverse vehicles, those 2008-2009 GMC Acadia vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, 2010-2013 GMC Acadia vehicles, and 2008-2010 Saturn Outlook vehicles. The Recall Announcement Date for the Recall 14v118 Vehicles is March 31, 2014.
10. "Recall 14v153 Only Vehicles,” which are those 2004-2006 and 2008-2009 Chevrolet Malibu vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, the 2004-2005 Chevrolet Malibu Maxx, some 2006 Chevrolet Malibu Maxx vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, 2005 Pontiac G6 vehicles, those 2006 and 2008-2009 Pontiac G6 vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, those 2008-2009 Saturn Aura vehicles as identified in the list of VINs for such Subject Vehicles provided by New GM to the Class Action Settlement Administrator, those 2005-2006 Pontiac G4 vehicles imported into the United States, and those 2006 Pontiac G5 Pursuit vehicles imported into the United States. The Recall Announcement Date for the Recall 14v153 Only Vehicles is March 31, 2014.

Under the terms of the Settlement, each Class Member is deemed to have waived, released, and promised not to sue for any economic loss claims that the Class Member has or may have in the future, directly or indirectly, against New GM, the GUC Trust, the AAT and certain other related parties (the “Released Parties”). However, Class Members did not waive or release any claims they may have against the Released Parties for personal injury, wrongful death or actual physical injury.

The Settlement prohibits Class Members from suing or being part of any other lawsuit or claim against the Released Parties that relates to the subject matter of the Actions, the Recalls, or that are or could have been described in the Fifth Amended Consolidated Complaint filed in the MDL 2543 Court or in the Late Claims or Proposed Proofs of Claims filed in the Bankruptcy Court, including, but not limited to, those relating to the design, manufacturing, advertising, testing, marketing, functionality, servicing, sale, lease or resale of the Subject Vehicles (the “Released Claims”). The specifics of the Released Claims are set out in more detail in the Amended Settlement Agreement, which is posted on the Important Documents page. The Amended Settlement Agreement describes the Released Claims in specific legal terminology.

Talk to your own lawyer if you have questions about the Released Claims or what it means.

The Settlement allowed Class Members to submit claims to the Class Action Settlement Administrator, and, if eligible, receive a settlement payment from the Settlement. As described below, any and all communication to the Class Action Settlement Administrator must include the Class Member’s full name, current and former address(es), Unique ID and Claim Number, if known, along with any other identifying information.

1. The Settlement Amount
   In exchange for Class Members’ release of the Released Claims, a $121.1 million settlement fund was established (the “Settlement Amount”). Settlement payments to eligible Class Members will only occur because the Settlement Order became final and after settlement implementation costs (such as for claims administration) are deducted.
2. How will payments for eligible claims be allocated?
   The Net Common Fund, which is the Settlement Amount less the costs of providing notice to the Class, the expenses of administering the Settlement and the Plaintiff Incentive Awards, will be exclusively used to provide payments to Class Members for eligible claims. To ensure that the Fund is fairly allocated, a Court-appointed mediator assessed the relative strength and value of the claims of each Subclass, with input from counsel separately representing each of those Subclasses. Based on that assessment, the mediator decided that members of two Subclasses with claims relating to the ignition switch (Delta Ignition Switch Subclass and Key Rotation Subclass) had relatively stronger claims than those of the other three Subclasses. The amount of the payment will be greater, therefore, for eligible claims in those two Subclasses than in the other three Subclasses (Camaro Knee-Key Subclass, Electronic Power Steering Subclass, and Side Airbag Subclass). Specifically, the Net Common Fund will be divided such that the payment for an eligible claim in the Delta Ignition Switch subclass will be twice the amount, and payment for an eligible claim in the Key Rotation Subclass be 1.5 times the amount, as the payment for an eligible claim in the other three Subclasses. (This allocation is reflected in a formula contained in the Settlement Claim Review Protocol and described in the Allocation Decision.)  The settlement payment amount for an eligible Settlement Claim in each Subclass is as follows:

   Subclass	Settlement Payment Amount
   Subclass 1 - The Delta Ignition Switch Subclass	$97.43
   Subclass 2 - The Key Rotation Subclass	$73.07
   Subclass 3 - The Camaro Knee-Key Subclass	$48.72
   Subclass 4 - The Electric Power Steering Subclass	$48.72
   Subclass 5 - The Side Airbag Subclass	$48.72
   Subclasses 1 & 4 - Delta Ignition Switch & Electric Power Steering	$146.15

    

3. How do I get a payment from the Net Common Fund?
   To receive payment, you need to have filed a valid claim form on or before April 20, 2021. For certain Class Members, both a complete claim form and additional documentation was required to establish eligibility including proof of the applicable recall repair by an authorized GM dealer after the recall date and/or an attestation signed under penalty of perjury.  Subclass membership was determined by the applicable Recall(s) for the Subject Vehicle. More information on the Subclasses can be found in FAQ 3. The chart below identifies by Subclass the number of Settlement Claims approved as eligible for a settlement payment:

   Subclass	Number of Settlement Claims Eligible For Settlement Payments
   Subclass 1 - The Delta Ignition Switch Subclass	185,670
   Subclass 2 - The Key Rotation Subclass	1,037,237
   Subclass 3 - The Camaro Knee-Key Subclass	40,725
   Subclass 4 - The Electric Power Steering Subclass	129,483
   Subclass 5 - The Side Airbag Subclass	80,841
   Total Number of Settlement Claims per Subclass Eligible For Settlement Payments	1,473,956

   Distribution to Settlement Claimants for eligible Settlement Claims commenced the week of November 22 to 28, 2021.

The lawyers representing Plaintiffs (“Plaintiffs’ Class Counsel”), listed below, negotiated the Amended Settlement Agreement and jointly filed the Settlement Motion with New GM and the GUC Trust. You will not be charged for services performed by Plaintiffs’ Class Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

If you want to contact Plaintiffs’ Class Counsel, they can be reached by sending an email to GMIgnitionswitch@hbsslaw.com or as follows:

Co-Lead Counsel for the Economic Loss Plaintiffs in the District Court.

The Federal District Court awarded Plaintiffs’ counsel $34.5 million in Attorneys’ Fees and Expenses. New GM paid these Attorneys’ Fees and Expenses approved by the District Court. This amount is in addition to, and not deducted from, the $121.1 million Settlement Amount described above.

The deadline to opt out or exclude yourself from the Class was October 19, 2020 and has passed.

If you opted out or excluded yourself from the Class, you will not get any money or benefits from this Settlement. By opting out or excluding yourself, however, you retained your individual right to sue the Released Parties about the same claims alleged in this lawsuit, at your own expense.

The deadline to object to the proposed Settlement was October 19, 2020 and has passed.

Pursuant to the hearing held on December 18, 2020, the District Court granted Final Approval of the Settlement.

No. Plaintiffs’ Class Counsel appeared at the hearing in support of the Settlement and answered any questions asked by the District Court. However, you were welcome to attend the hearing at your own expense.

If you sent a written objection, you did not have to come to District Court to talk about it. So long as you mailed your written objection on time and complied with the other requirements for a proper objection, the District Court considered it. You may have attended or you may have paid your own lawyer to attend, but it was not required.

Yes. If you submitted a proper written objection to the Settlement, you or your lawyer may have, at your own expense, come to the hearing to speak.

You had the right to do nothing. If you did nothing, you will not get any Settlement benefits. In addition, you can no longer be part of a class action or any other lawsuits against the Released Parties involving the Released Claims in this Settlement. Specifically, the Settlement prohibits you from suing or being part of any other lawsuit or claim against the Released Parties that relate to the subject matter of the Actions, the Recalls, or that are or could have been described in the Fifth Amended Consolidated Complaint filed in the MDL 2543 Court or in the Late Claims or Proposed Proofs of Claims filed in the Bankruptcy Court, including, but not limited to, those relating to the design, manufacturing, advertising, testing, marketing, functionality, servicing, sale, lease or resale of the Subject Vehicles.

The Long Form Notice summarizes the Settlement. For the precise terms and conditions of the Settlement, please see the Amended Settlement Agreement, the Order Granting Final Approval of Class Settlement, and any additional orders entered by the District Court pertaining to the Settlement, all of which are available on the Important Documents page.

PLEASE DO NOT CALL THE JUDGE OR THE COURT CLERK TO ASK QUESTIONS ABOUT THE LAWSUITS, THE SETTLEMENT, OR THE LONG FORM NOTICE.