1. The Plaintiff’s appeal against Defendant Financial Supervisory Service and Defendant Financial Services Commission’s appeal are all dismissed.

2. Appeal.

1. Details of the disposition;

A. On June 9, 2008, the Plaintiff entered into a golf membership sales agreement with B Co., Ltd. (hereinafter “B”) and the Plaintiff (hereinafter “B”) to pay 2.2 billion won (2.2 billion won per old unit) to the sales price of the corporate membership in the 10 unit of the golf course (hereinafter “instant golf course”).

(hereinafter “instant agreement”). On December 29, 2009, the Plaintiff concluded a membership agreement with B pursuant to the said agreement.

B. On August 30, 201, the Defendant Financial Services Commission imposed a penalty surcharge of KRW 740,000,000 in total on the Plaintiff on the ground of the following reasons for disposition Nos. 1 and 2 (i.e., the ground for disposition No. 717,00,000) (i.e., KRW 23,00,000)

(hereinafter “instant penalty surcharge”). The internal resolution of the Defendant Financial Services Commission was made on August 26, 201.

According to the evidence No. 1 (Notice of Details of Disposition of Imposition of Penalty Surcharge), the reason for disposition is specified as “unfair credit extension without interest to a major shareholder” (the ground for Disposition No. 1) and “special benefits to policyholders, etc.” (the ground for Disposition No. 2).

On September 2, 2011, Defendant Financial Supervisory Service issued a warning to the Plaintiff on the ground that the reasons for the following dispositions were 1,3,4,5, and 6:

(hereinafter “instant warning disposition”). On June 9, 2008, the Plaintiff agreed to purchase the right of preferential purchase of ten corporate members of the instant golf course, the business approval of which was not completed, and granted credit equivalent to B’s interest accrued to KRW 22 billion during the period from June 29, 2008 (the date of advance payment) to December 29, 2009 (the date of entry into the agreement) by advance payment of deposit KRW 22 billion.

(1) The Plaintiff’s former E branch head: (a) 9 cases, such as insurance policy holders F, etc. (the total amount of lump-sum payment KRW 752 million), recruited during the period from October 31, 2003 to December 22, 2003, such as G insurance policy holders F, etc. (the total amount of lump-sum payment KRW 750,000,000) are distributed to three persons, including insurance policy holders H, belonging to the E branch.