Bulletin: SLS2023007

Dear Associates:

This bulletin advises you regarding the purchase and sale of tenancy in common interests in connection with one or more of the following Walton companies, their affiliates, or their related entities (collectively “The Walton Group of Companies”):

Walton Global Holdings, LLC

Walton International Group, Inc.

Walton International Group (USA), Inc.

Walton Development Holdings, Inc.

Walton Land Fund

Walton Development & Management (USA)

Walton Colorado, LLC

Walton Georgia, LLC

Other Walton Single Purpose Entities or State Specific Entities

These transactions usually occur in three (3) separate phases:

Phase 1: Walton entity or affiliate purchases the land from a third-party seller

Phase 2: Walton sells undivided interests in the land acquired to various proposed trusts, entities, or individuals as tenants in common (“UDI Interest Holders”)

Phase 3: Walton finds a buyer for the land, contingent on approval from the UDI Interest Holders

Due to the unique aspects of Phase 2 and Phase 3 transactions, all issuing offices are instructed not to accept any orders, issue commitments, or close any transactions involving any of the Walton Group of Companies; their investors, or UDI Interest Holders regardless of the transaction dollar amount. Regarding Phase I transactions, all issuing offices are instructed not to accept any orders, issue commitments, or close any transactions involving any of the Walton Group of Companies; their investors, or UDI Interest Holders regardless of the transaction dollar amount without first contacting a Stewart Title Regional Underwriting Counsel or Stewart Title’s Chief Underwriting Counsel for guidance and written approval. For transactions involving a Stewart Title National Commercial Services (“NCS”) office, one of the following should be contacted in lieu of a Stewart Title Regional Underwriting Counsel: Chief Underwriting Counsel-Commercial Services or a Deputy Chief Underwriting Counsel-Commercial Services.

If you have questions about a transaction involving a bank closed by the FDIC, or other issues not addressed by this bulletin, please contact a Stewart Title Guaranty Company Underwriter.

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