NEW YORK--(BUSINESS WIRE)--Between July and October 2015, a mediation (the “First Mediation”) took place between the members of the Steering Committee (“Steering Committee”) of the Ad Hoc Committee of Washington Mutual Bank (“WMB”) Senior Note Holders and certain holders (“Institutional Investors”) of residential mortgage-backed securities (“RMBS”) sponsored by WMB. Among other terms, the last proposal made by the Steering Committee to the Institutional Investors, reflected in a proposed memorandum of understanding, included an allowed unsecured claim against the WMB Receivership in the amount of approximately $2.28 billion on behalf of the WMB RMBS trusts for which Deutsche Bank National Trust Co. (“Deutsche Bank”) serves as trustee (not including trusts with mortgage repurchase liability claims for which Washington Mutual Mortgage Securities Corporation is obligor). Other terms and conditions of the last proposal included, but were not limited to, provisions regarding the possible reduction of Deutsche Bank's claims against the WMB Receivership in the event of a successful appeal in the WMB Litigation (defined below), the payment of counsel fees, and various procedural details. It was contemplated that the terms would be reflected in an executed memorandum of understanding, and then would be fully documented in settlement agreements that would include Deutsche Bank and the FDIC. The Steering Committee and the Institutional Investors have not executed the memorandum of understanding or any settlement agreement. An agreement between the parties to the First Mediation was meant to be a step towards a global settlement of the claims asserted by Deutsche Bank on behalf of certain WMB RMBS trusts in the action Deutsche Bank Nat’l Trust Co. v. FDIC, et al., No. 09-1656 (D.D.C.), and of the indemnity claims asserted against the WMB Receivership by JPMorgan Chase Bank N. A. (“JPMorgan”) (collectively, the “WMB Litigation”). The members of the Steering Committee understand that a mediation among the named parties to the WMB Litigation (the “Second Mediation”) commenced in December 2015. The members of the Steering Committee further understand that the legal and financial advisors to the Ad Hoc Committee may have information regarding the Second Mediation, but no information regarding that mediation has been shared with members of the Steering Committee.