MBIA Inc. Policy Statement

Topic: Insider trading policy

Inside Information. It is against the laws of many countries, including the U.S., to “tip” others who might make an investment decision based on Inside Information, as defined below, or to trade on such a tip. The penalties for trading on or communicating Inside Information are severe, both for the individual involved in such unlawful conduct and for MBIA. These penalties include treble damages, disgorgement of profits and jail sentences. In addition, Covered Persons could be subject to disciplinary action for violating the policies set forth herein, including termination. If your securities transactions become the subject of scrutiny, your actions will be decided after the fact with the clarity of 20/20 hindsight. Therefore, if you have any questions about how to implement this Policy, and the procedures herein for avoiding violations of insider trading laws and regulations, contact the Legal Department or Chief Compliance Officer before taking action.

Personal Trading Plans. Rule 10b5-1 (the “Rule”), adopted by the SEC in connection with the issuance of Regulation FD, the “Fair Disclosure” rule, addresses certain issues relating to insider trading liability. The Rule states that when a person trades in a security while he or she is aware of material, non-public information, that person has traded “on the basis of” that information for purposes of the anti-fraud provisions of the federal securities laws. Thus, an individual cannot avoid insider trading liability based on the argument that the individual did not actually use material inside information known to the individual in making his/her trade.

The Rule also creates an affirmative defense to insider trading liability by providing that a person's purchase or sale of a security is not “on the basis of” material non-public information if the person making the purchase or sale demonstrates that before becoming aware of the Inside Information, the person had (a) entered into a binding contract to purchase or sell the security, (b) instructed another person to purchase or sell the security for the instructing person's account, or (c) adopted a written plan for trading securities (such contract, instruction or plan, a “Plan”), and the transactions in question were executed pursuant to the Plan. A purchase or sale is not pursuant to a contract, instruction, or plan if, among other things, the person who entered into the Plan altered or deviated from the Plan to purchase or sell securities (whether by changing the amount, price, or timing of the purchase or sale), or entered into or altered a corresponding or hedging transaction or position with respect to those securities.

A Plan must:

Members of MBIA’s Board of Directors and employees of MBIA engaging in transactions in securities issued by the Company, including the sale of stock obtained as a result of the exercise of options on MBIA Securities, may wish to take advantage of the safe harbor offered by the Rule by utilizing a Plan as described in the Rule. Individuals can create a variety of types of Plans to meet their financial preferences. While it is the responsibility of the individual Covered Person to establish a Plan and trade in accordance with the Plan, the Company can assist in the effort through procedures it established to help design, create and maintain effective Plans that comply with the provisions of the Rule.

“Covered Persons” or “you” means MBIA directors, officers and employees, whether full-time, part-time or temporary, and those consultants, contractors, interns, vendors and other individuals working for or on behalf of MBIA who have regular access to MBIA property, who represent MBIA to third parties or who are identified as Covered Persons in consultation with Compliance or the Legal Department. Any Covered Person action that could be questionable is also unacceptable if engaged in by a related third party, such as a spouse, family member, friend or any other person or entity with whom the Covered Person is closely identified or in which the Covered Person has any significant financial interest.

“Inside Information” is information that is both material and non-public.

“Insider” means directors, officers and employees of MBIA. It may also include people who enter into a special relationship with MBIA and are given access to material, non-public information solely for MBIA purposes (e.g., outside attorneys, accountants, consultants, reinsurers, rating agencies, etc.).

Information is considered “material,” in general, if there is a likelihood that a reasonable investor would consider it important in making an investment decision or information that is likely to affect the price of securities.

Information is “non-public” if it has not been broadly disseminated to investors (e.g., by a press release or in a report filed with the SEC) and if there has not been a sufficient opportunity for the marketplace to absorb the information and make allowance for its impact.

“Interested Parties Securities” means the securities of an issuer for which MBIA provides a financial guaranty insurance policy, whether or not such securities are insured by MBIA.

“MBIA,” “Company” or “us” means MBIA Inc. and its subsidiaries.

“MBIA Securities” means equity or debt securities issued by MBIA Inc. or its subsidiaries, and related derivatives.

“NYSE” means the New York Stock Exchange.

“Permitted Parties” means attorneys and/or investment bankers who are working on specific projects for MBIA, MBIA’s accountants, rating agency professionals, regulators and reinsurers, banks and others who have been or are considering providing or underwriting credit to MBIA or its subsidiaries.

“Plan” means a written plan for trading securities.

“Policy” means this Policy Statement.

“Related Parties” means spouses, children, and adults living in the same household or family trusts.

“Reporting Persons” means directors, executive officers and other persons who are required to file reports under Section 16 of the Securities Exchange Act of 1934, as amended.

“Retirement Plan Blackout Periods” mean certain blackout periods that are imposed on any Company retirement plans.

“Rule” means Rule 10b5-1 under the Securities Exchange Act of 1934, as amended.

“SEC” means the United States Securities and Exchange Commission.

“Selective disclosure” means disclosure made in a forum that is not simultaneously available to all investors, such as one-on-one telephone calls or meetings with analysts or investors, correspondence, presentations, etc.

“Senior Officials” of MBIA for purposes of Regulation FD include members of the MBIA Board of Directors, the senior management of MBIA Inc., the Head of Investor Relations, and any other officers whose primary responsibility is to communicate with investors and other external audiences.

“Tipping” means sharing material nonpublic information with a third party, whether or not for compensation.

Inside Information Policy Statement.

Restrictions on Trading Securities and Tipping. Covered Persons are prohibited from directly or indirectly trading any securities or Tipping Inside Information related to any securities when they obtain Inside Information about the security in the course of their employment or engagement, including MBIA Securities or Interested Parties Securities. Covered Persons must comply with all applicable insider trading laws and regulations.

Restrictions on Trading MBIA Securities and Interested Parties Securities. It is MBIA’s policy that, in order to minimize the risk that a Covered Person trades in, or is even viewed as having traded in, MBIA Securities or Interested Parties Securities while in possession of or having access to Inside Information, Covered Persons must comply with the procedures set forth herein.

If you are in possession of Inside Information when your employment with the Company terminates, the restrictions on trading securities and Tipping set forth above shall continue until such time that such information has become public or is no longer material.

Personal Trading Plan Policy Statement. It is MBIA’s policy to allow members of MBIA’s Board of Directors and employees of MBIA engaging in transactions in MBIA Securities, including the sale of stock obtained as a result of the exercise of options on MBIA Securities, to take advantage of the safe harbor offered by the Rule by utilizing a Plan as described in the Rule in accordance with the procedures set forth below.

Covered Persons who violate this Policy will be subject to disciplinary and/or legal action for violating the policies set forth herein, including termination and/or forfeiture of certain benefits. If a Covered Person knows or learns of a violation or potential violation of this Policy, he or she must promptly report the facts to the Legal Department or Compliance. Nothing in this Policy concedes or admits that any practice or act by MBIA is not subject to an immunity, exception or defense to applicable laws or regulations.

A. Responsibility for the Implementation of this Policy

Each Covered Person is responsible for adhering to the policies and procedures set forth herein.

The Legal Department and Chief Compliance Officer are responsible for implementing this Policy, for answering all questions regarding the implementation of this Policy and for resolving issues of whether information received by a Covered Person is material and non-public and thus, Inside Information.

The Legal Department and Chief Compliance Officer will approve and review this Policy on a regular basis and update it as necessary. Upon learning of a violation or potential violation of any provision of this Policy, the Legal Department or Chief Compliance Officer will, in appropriate cases, promptly prepare a written report to the MBIA Risk Oversight Committee providing full details and recommendations for further action.

This Policy sets forth the policies and procedures of MBIA on a global, enterprise-wide basis with respect to the use and dissemination of Inside Information by Covered Persons.

In addition to complying with this Policy, all Covered Persons located outside the United States must comply with any and all local rules and regulations relating to the use and dissemination of Inside Information, as advised by the Legal Department, Chief Compliance Officer or local counsel, and where there may be a conflict between this Policy and any local rule or regulation, such local rule or regulation will prevail.

Part 1 Use of Inside Information

Restrictions on Trading MBIA Securities, Interested Parties Securities and Tipping. In order to minimize the risk that a Covered Person trades in, or is even viewed as having traded in, MBIA Securities or Interested Parties Securities or Tipping Inside Information related to MBIA Securities or Interested Parties Securities while in possession of or having access to Inside Information, MBIA has adopted the following procedures. In addition, this Policy identifies those times when trading in MBIA's stock by certain Covered Persons is not appropriate and is therefore not permitted. Furthermore, this Policy prohibits trading in various derivative instruments related to MBIA Securities.

Blackout Periods: Covered Persons (and Related Parties) are prohibited from trading in MBIA Securities during the period that begins no later than on the last NYSE trading day prior to any scheduled key assumptions meetings in anticipation of MBIA Loss Reserve Committee meetings in accordance with a notice provided by the Chief Compliance Officer and ends after the second full NYSE trading day following the date on which MBIA releases annual and quarterly earnings for such quarter. In addition, Covered Persons are prohibited from trading in MBIA Securities during any other period during which the Company announces that trading in MBIA Securities is prohibited. Any automatic investments in MBIA Securities within any benefit plans are permitted at any time, but discretionary trades within any benefit plans are only allowed during the trading window and are subject to the preapproval requirements above.

Part 2 Personal Trading Plans Under SEC Rule 10b5-1

Personal Trading Plan Guidelines. The following guidelines are intended to assist Covered Persons in the adoption of personal trading plans and other arrangements as a defense to liability for insider trading violations, in accordance with the Rule:

This Policy is effective January 15, 2025.