EXHIBIT B-2 

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 EXHIBIT B-2 

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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

In re Peregrine Financial Group 

Customer Litigation

Civil Action No. 12-cv-5546

Notice of Proposed Class Action Settlement, 

Settlement Hearing, and Motion for Attorneys’ 

Fees and Reimbursement of Litigation 

Expenses

SUMMARY NOTICE 

To: All persons or entities who held money, property, and/or securities pursuant to 7 U.S.C. § 

6d(a)(2) at Peregrine Financial Group (“PFG”) as of the filing of bankruptcy of PFG on 

July 10, 2012. 

You are hereby notified that, pursuant to an Order of the United States District Court for 

the Northern District of Illinois, a hearing will be held on _________________, 201__, at __:__ 

__.m., before the Honorable Sara L. Ellis, at the United States District Court for the Northern 

District of Illinois, Everett McKinley Dirksen United States Courthouse, 219 South Dearborn 

Street, Chicago, IL 60604, for the purpose of determining: (1) whether the proposed Settlement 

with U.S. Bank National Association and its parents, subsidiaries and affiliates (“U.S. Bank”) for 

U.S. Bank’s cash payment of $44,500,000 to the proposed Settlement Class should be approved 

by the Court as fair, reasonable and adequate; (2) whether U.S. Bank should be released from all 

claims and potential claims as set forth in the Settlement Agreement dated as of June 18, 2015; 

(3) the reasonableness of the application of Co-Lead Counsel for the payment of attorneys’ fees 

and expenses incurred in connection with this Customer Class Action Litigation, together with 

interest thereon, and for the payment of service awards to the Class Representatives; and (4) the 

reasonableness of the Plan of Allocation. 

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If you are a member of the Settlement Class, your rights may be affected by this 

Settlement with U.S. Bank. If you have not received a detailed Notice of Proposed Settlement of 

Class Action, you may obtain a copy by writing to , or by downloading 

this information at www.omnimgt.com. If you are a Settlement Class member you may receive a 

distribution from U.S. Bank’s $44,500,000 cash payment. 

If you have an allowed claim in the PFG bankruptcy case, you will automatically receive 

a payment unless you choose to exclude yourself. 

If you do not have an allowed claim in the PFG bankruptcy case and you wish to 

participate in the settlement, you must submit a class action proof of claim form. You may 

download the claim form, entitled “Commodity Futures Customer Claim Form—Peregrine 

Financial Group, Inc.—U.S. Bank Settlement,” from www.omnimgt.com. Claim forms must be 

postmarked by [forty-five (45) calendar days after the Notice Date] or filed online by midnight 

on [DATE] to receive a payment. If you do not have an allowed claim in the PFG bankruptcy 

case and you do not timely submit a proof of claim, you will receive nothing from this settlement 

but will be bound by its terms unless you choose to exclude yourself. 

Regardless of whether you have an allowed claim in the PFG bankruptcy case, if you 

exclude yourself from the settlement, you will not share in the payment made by U.S. Bank to 

settle this case. This is the only option that allows you to be part of any other legal proceeding 

against U.S. Bank about the claims in this case. You will be bound by any judgment rendered in 

the class action unless your written request to be excluded is received no later than [21 calendar 

days prior to the Settlement Hearing] __________, 201__. 

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Any objection to any aspect of this Settlement must be filed with the Clerk of the Court 

and received by the following no later than [21 calendar days prior to the Settlement Hearing] 

________, 201__: 

BERGER & MONTAGUE, P.C. 

Michael C. Dell’Angelo 

1622 Locust Street 

Philadelphia, PA 19103 

Daniel C. Girard 

GIRARD GIBBS LLP 

601 California Street, 14th Floor 

San Francisco, CA 94108 

(415) 981-4800 

Co-Lead Counsel for Customer Representative Plaintiffs 

Eric R. Sherman 

DORSEY & WHITNEY LLP 

50 South Sixth Street, Suite 1500 

Minneapolis, Minnesota 55402 

(612) 340-2600 

Counsel for U.S. Bank National Association 

Mark L. Radtke 

SHAW FISHMAN GLANTZ & TOWBIN LLC 

321 N. Clark Street, Suite 800 

Chicago, Illinois 60654 

(312) 276-1325 

Counsel for the Trustee 

PLEASE DO NOT CONTACT THE COURT OR THE CLERK’S OFFICE 

REGARDING THIS NOTICE. 

DATED: _________________, 201__ BY ORDER OF THE COURT 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOS 

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