Lehman Brothers Preliminary Report on Chapter 11 Plan

NEW YORK, March 29, 2010 – On March 15, 2010, Lehman Brothers Holdings Inc. and
its 22 affiliated chapter 11 debtors (collectively, the “Debtors”) filed a joint proposed
chapter 11 plan (“Plan”) with the United States Bankruptcy Court for the Southern
District of New York. The Debtors’ time within which to file a disclosure statement
relating to the Plan has been extended by Order of the Bankruptcy Court to at least April
14, 2010. For the purpose of providing preliminary and general information as to the
formulation of the Plan, the Debtors have filed a Current Report on a Form 8-K with the
Securities and Exchange Commission that sets out preliminary and general information
as to the progress that the Debtors have made in connection with the over 65,000 claims
that have been filed against the Debtors.

The Report is not intended and does not constitute a solicitation of acceptances of the
Plan. The Report has been filed for the sole purposes stated above.

US_ACTIVE:\43349979\01\58399.0008
 UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM 8-K
CURRENT REPORT
Pursuant to Section 13 or 15(d) of The Securities Exchange Act of 1934
Date of Report (Date of earliest event reported): March 29, 2010

LEHMAN BROTHERS HOLDINGS INC.

(Exact name of registrant as specified in its charter)

Delaware 1-9466 13-3216325

(State or other jurisdiction (Commission (IRS Employer
Of incorporation) File Number) Identification No.)

1271 Avenue of the Americas

New York, New York
10020
(Address of Principal Executive Offices)
(Zip Code)

Registrant’s telephone number, including area code:

(646) 285-9000

Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant
under any of the following provisions (see General Instruction A.2. below):

† Written communications pursuant to Rule 425 under the Securities Act (17 CFR 230.425)

† Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17 CFR 240.14a-12)

† Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17 CFR 240.14d-2(b))

† Pre-commencement communications pursuant to Rule 13e-4(c) under the Exchange Act (17 CFR 240.13e-4(c))
ITEM 7.01 Regulation FD Disclosure.

As previously disclosed, on September 15, 2008, Lehman Brothers Holdings Inc. (the “Registrant” or “LBHI”) filed a
voluntary petition for relief under Chapter 11 of the United States Code (the “Bankruptcy Code”) in the United States Bankruptcy
Court for the Southern District of New York (the “Bankruptcy Court”) in a jointly administered proceeding named In re Lehman
Brothers Holdings Inc., et. al. under Case Number 08-13555 (the “Chapter 11 Case”). As further disclosed previously, certain of the
Registrant’s subsidiaries (collectively with the Registrant, the “Debtors”) have also filed proceedings under Chapter 11 of the
Bankruptcy Code. The Debtors’ Chapter 11 cases have been consolidated for procedural purposes only and are being jointly
administered pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure and the Debtors continue to operate as debtors-
in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code.

On March 15, 2010, consistent with the provisions of Chapter 11 of the Bankruptcy Code, the Debtors filed in the
Bankruptcy Court a proposed joint plan of reorganization (the “Plan”). In relation thereto, the Bankruptcy Court extended the
statutory time within which the Debtors may file the requisite proposed disclosure statement that, if approved, will be used to solicit
acceptances of the Plan, to April 14, 2010. Notwithstanding the enormous complexities presented by these extraordinary and a-typical
Chapter 11 cases, the Debtors are making every reasonable effort and hope to be in a position to file the disclosure statement by
April 14, 2010.

In the interim, and since March 15, 2010, there has been substantial trading in the claims against the Debtors and various
asserted and non-restricted claimants have requested information and private meetings as to the filed Plan. The Debtors are concerned
that all interested parties have equal access to information and data concerning the Plan and that the prevailing principle of full
transparency continue. In that context, the Debtors are filing this report to outline the progress they have made in the analysis of the
over 65,000 claims that have been filed against the Debtors. The claims analysis process represents a primary foundation of the Plan
and the disclosure statement that will be filed.

The Plan Objective

The Plan as filed constitutes a proposed economic resolution of the manifold complex, difficult and often perplexing issues
and conflicts that exist among the Debtors and their claimants. It represents an attempt to reasonably and equitably evaluate the
contentions and arguments of the various claimants to arrive at a conclusion that would obviate extensive, prolix and expensive
litigation that will be detrimental and prejudicial to the ultimate recoveries to holders of allowed claims.

The Debtors believe that the filed Plan is the result of a thorough, comprehensive and reasoned review of the potential issues
presented by these Chapter 11 cases. The filed Plan proposes the allocation of claim amounts to each category of claims and provides
a relatively simple structure that would facilitate prompt distributions to holders of allowed claims. The Debtors believe that the Plan
encompasses a fair, reasonable economic outcome for each class of claimants that is provided for in the Plan.

The Plan contemplates that in each of the Debtors’ cases, the Plan will be confirmed and provide for the satisfaction of
allowed claims to the extent provided for therein. The primary Plan is proposed for LBHI, the parent Debtor. It encompasses four key
elements critical to the determination of the total allowed claims against that Debtor. The four key elements are:

LBHI Direct Liabilities: this category includes the outstanding noteholder claims as at September 15, 2008 of approximately
$99 billion; accounts payable/accrued claims of $2 billion; and

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 unliquidated direct damage claims. The Debtors have designated a specific workstream to reconcile the foregoing filed
claims against their estimate of the amounts of such claims;

Third Party Subsidiary Guarantee Claims: this category includes third party claims against LBHI by creditors that assert
claims against LBHI subsidiaries and affiliates who claim that LBHI guaranteed the payment of such claims;

Affiliate Guarantee Claims: this category includes claims asserted by subsidiaries and affiliates of LBHI on the basis of
alleged transaction guarantees made by LBHI and alleged general corporate resolutions of LBHI purporting to guarantee
liabilities of certain subsidiaries and affiliates; and

Intercompany Accounts Payable Claims: this category includes claims based upon intercompany transactions as at the
commencement date based on the “global close” of the Debtors financial and accounting records as of the close of business
on September 14, 2008.

The Plan proposes an allowed claims pool for LBHI that will include:

(i) allowance of established direct debt and liabilities of LBHI;

(ii) for the purposes of this proposal and without prejudice to potential revisions and amendments of the Plan,
that the corporate integrity of the Debtors be respected, and, therefore allowance of Third Party Subsidiary
Guarantee Claims in an amount equal to the lower of the Debtors estimate of such claims (inclusive of an
estimate for ISDA claimed damages) or the aggregate amount of Third Party Subsidiary Guarantee Claims
filed;

(iii) an allowance of an aggregate claim for all Affiliate Guarantee Claims in the amount of $21 billion to be
allocated pro rata among established individual asserted claims based on the alleged transaction and
corporate resolution guarantees;

(iv) allowance of established intercompany net claims as of the commencement date, other than the
intercompany claim of Lehman Brothers Treasury (“LBT”);

(v) the settlement of the intercompany claim of LBT by allowance of that claim in an amount equal to 50% of
the net intercompany payable as of the commencement date. The settlement is proposed based upon the
conclusion that LBT served as a conduit for LBHI in the sale and distribution of EURO denominated
bonds versus dollar denominated bonds of LBHI. In that capacity, LBT acted as an agent and
instrumentality of LBHI and had no separate integrity or purpose. Accordingly, the Plan offers the
proposed allowed claim as a recovery settlement for the benefit of LBT bondholders.

The Claims Filed Against the Debtors

During the early part of 2009, the Bankruptcy Court established a “Bar Date” for the filing of claims against the Debtors.
Pursuant to the expiration of the Bar Date in November 2009, over 65,000 proofs of claim were filed with the designated claims
agent. The IRS has a June 30, 2010 bar date. The filed claims against LBHI (including intercompany claims by Debtors and other
Lehman entities) total in excess of $819 billion plus potentially significant unliquidated claims. The current breakdown of the filed
claims against LBHI is set forth on Schedule 1 of Exhibit 99.1 attached hereto.

The Debtors have designated a claims management team that is devoted to the review, analysis and consideration of the filed
claims. Over the last four months that team has concluded that based upon

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clear errors, duplications and non-controversial corrections that are appropriate, the aggregate total of the filed claims should be
reduced to $605 billion (“Adjusted Total Filed Claims”) as of March 10, 2010. Schedule 1 of Exhibit 99.1 attached hereto sets forth
the breakdown of the claims adjustment.

The review of the Adjusted Total Filed Claims is an ongoing, intensive and laborious process. The Debtors, for the purposes
of the Plan, have made a preliminary estimate of the potential allowed amount of the Adjusted Total Filed Claims. It is the Debtors
estimate that such amount will approximate $260 billion. Schedule 1 of Exhibit 99.1 attached hereto sets forth the basis of the Debtors
estimate.

Conclusion

This Current Report on Form 8-K is being filed for explanation purposes only. It is not intended to be a solicitation for
acceptance of the Plan, which may only be undertaken after the approval of a disclosure statement by the Bankruptcy Court, after
notice and a hearing. In that context, it is emphasized that this Current Report on Form 8-K is preliminary and that the Plan and the
information contained therein is subject to revision, amendments and other factors that may cause a different approach to the Chapter
11 plan process.

The amounts stated in this report are the Debtors’ best estimates at this time and, in the perspective of the extremely complex
issues presented by these gargantuan cases, will be refined and revised as the Plan process proceeds and the views of claimant
constituencies are received and considered. This Current Report on Form 8-K has been prepared and filed in the interests of
transparency and clarity as to the Plan and the claims that would be affected by its provisions.

This Current Report on Form 8-K, as stated, is not a solicitation to accept or reject the proposed Plan or an offer to sell or a
solicitation of an offer to buy any securities of the Debtors. Any solicitation or offer to sell will be made pursuant to and in
accordance with the disclosure statement and applicable law.

A copy of the press release announcing the filing of this Current Report on Form 8-K is attached hereto as Exhibit 99.2.

Limitation on Incorporation by Reference

In accordance with General Instruction B.2 of Form 8-K, the information in this Item 7.01, including Exhibits 99.1 and 99.2
hereto, shall not be deemed “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), or otherwise subject to the liabilities of that section, nor shall such information be deemed incorporated by reference in any
filing under the Securities Act of 1933, as amended, except as shall be expressly set forth by specific reference in such a filing.

Cautionary Statement Regarding Forward-Looking Statements

This Current Report on Form 8-K, including Exhibits 99.1 and 99.2 hereto, may contain forward-looking statements within
the meaning of the Private Securities Litigation Reform Act of 1995 with respect to the Registrant’s financial condition, results of
operations, and business that is not historical information. As a general matter, forward-looking statements are those focused upon
future or anticipated events or trends and expectations and beliefs relating to matters that are not historical in nature. The words
“believe,” “expect,” “plan,” “intend,” “estimate,” or “anticipate” and similar expressions, as well as future or conditional verbs such as
“will,” “should,” “would,” and “could,” often identify forward-looking statements. The Registrant believes there is a reasonable basis
for its expectations and beliefs, but they are inherently uncertain, and the Registrant may not realize its expectations and its beliefs
may not prove correct. The Registrant undertakes no obligation to publicly update or revise any forward-looking statement, whether
as a result of new information, future events, or otherwise. The Registrant’s actual results and future financial condition may differ
materially from those described or implied by any such

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forward-looking statements as a result of many factors that may be outside the Registrant’s control. Such factors include, without
limitation: (i) the ability of the Registrant to develop, prosecute, confirm, and consummate any plan of reorganization or liquidation
with respect to the Chapter 11 Case; (ii) the Registrant’s ability to obtain Bankruptcy Court approval with respect to motions in the
Chapter 11 Case; (iii) risks associated with third parties seeking and obtaining Bankruptcy Court approval for the appointment of a
Chapter 11 trustee; and (iv) the potential adverse impact of the Chapter 11 Case on the Registrant’s liquidity or results of operations.
This list is not intended to be exhaustive.

The Registrant’s informational filings with the Bankruptcy Court are available to the public at the office of the Clerk of the
Bankruptcy Court, Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408. Such informational
filings may be available electronically, for a fee, through the Bankruptcy Court’s Internet world wide web site
(www.nysb.uscourts.gov), and/or free of cost, at a world wide web site maintained by the Registrant’s Court-approved noticing agent
(www.lehman-docket.com).

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ITEM 9.01 Financial Statements and Exhibits.

(a) Exhibits

99.1 Breakdown of Debtor and Non-Debtor Claims.

99.2 Press Release.

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 SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the Registrant has duly caused this report
to be signed on its behalf by the undersigned hereunto duly authorized.

LEHMAN BROTHERS HOLDINGS INC.

Date: March 29, 2010 By: /s/ William J. Fox

Name: William J. Fox
Title: Chief Financial Officer and Executive Vice President

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 EXHIBIT INDEX

Exhibit No. Description

99.1 Breakdown of Debtor and Non-Debtor Claims.

99.2 Press Release.

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 Exhibit 99.1

LBHI Schedule 1
Unsecured Claims Summary and Analysis
As of March 2010
($ in millions)

Claims Estimated
Filed Per Claims Estimated
Official After Allowed
Claims Estimated Initial Claims
Register Adj’s (1) Claims Adj’s (2) Analysis Per POR

Direct 3rd Party Claims filed against LBHI $ 170,373 $ 0 $ 170,373 $ 12,176 $ 182,549 $ 101,604(3)

LBHI Intercompany Payables to Affiliates 68,742 10,592 79,334 (22,952) 56,382 42,966(4)

Guarantee Claims filed by 3rd Parties of Affiliates against LBHI 254,976 0 254,976 (112,441) 142,535 94,138(5)

Guarantee Claims filed by Affiliates against LBHI 201,467 113,123 314,590 (90,672) 223,918 21,186(6)

Total $ 695,558 $ 123,715 $ 819,273 $ (213,889) $ 605,384 $ 259,894

A review of claims both on a substantive basis and for purposes of plan classification is ongoing. Notwithstanding best efforts, given the volume of claims, the documentation supporting those claims and the fact that many
claims have been (i) filed in unliquidated amounts, (ii) filed without any supporting documentation, (iii) filed without sufficient documentation and/or (iv) filed without properly identifying the basis for their claim (i.e.
claimants asserting either guarantee or or derivative claims but not completing or incorrectly completing the required box on proof of claim form, claimants asserting secured or priority claims with no support for such
assertions, etc.), it is likely and expected that claims or portions of claims will be disallowed or reclassified with respect to priority and/or plan class. Such disallowances and reclassifications will affect, and may materially
affect, the analysis presented herein.

(1) Upward adjustment to claim amounts that appear to have been incorrectly omitted from the Official Claims Register. The Debtors will work with the Official Claims Agent to update the Official Claims Register as
appropriate.

(2) Adjustments to capture certain (i) claims believed to be duplicative of earlier-filed claims or amended by later-filed claims, (ii) upward adjustments to estimate certain liquidated amounts for claims filed without specific
liquidated amounts, and (iii) obvious over-statements.

(3) Notwithstanding the requirements in the bar date order, many claims have either been filed without specification of a Debtor or have been filed against what appears to be the incorrect Debtor. To the extent that such
claims are later determined to be properly asserted against LBHI or , conversely, that claims asserted against LBHI are determined to be properly asserted against other Debtors, the numbers reflected herein will vary and may
vary materially. The amount reflected above is based on the Debtor’s review of 3rd party liaibilities per the LBHI 9-14-08 and 6-30-09 financial statements.

(4) Represents LBHI net intercompany payable as of 9-14-08 except for LB Treasury which was compromised by 50% of the net intercompany payable.

(5) See Schedule 2.

(6) See Schedule 3.

LBHI Schedule 2
Classes 7A to 7R
Guarantee Claims Filed by 3rd Parties of Affiliates
As of March 2010
($ in millions)

Estimated
Claims Allowed
After Initial Pursuant
Class 7 Affiliate Analysis to Plan

7A LBSF $ 41,552 $ 15,861(1)

7B LBCS 2,776 2,776
7C LBCC 353 353
7D LOTC 310 310
7E LBDP 702 201(1)
7F LCPI 1,162 1,162
7G LB International (Europe) 18,203 18,203
7H Lehman Brothers Limited 4,477 2,439(2)
7I Lehman Brothers Treasury Co. B.V. 28,159 26,411(2)
7J Lehman Brothers Bankhaus AG 37,829 19,410(2)
7K Lehman Brothers Finance S.A. 2,763 2,763
7L Lehman Brothers Securities NV 746 746
7M Lehman Brothers Japan Inc. 410 410
7N Lehman Brothers Holdings Japan Inc. 1,289 1,289
7O Sunrise Finance Co. 622 622
7P LB Commercial Corp Asia Ltd 142 142
7Q LBI 748 748
7R Schedule 5 (per POR) Affiliates 292 292

Total $ 142,535 $ 94,138

The claim numbers presented herein relate to the claims estimates provided in Schedule 1 and, as such, the reader should review
Schedule 1 and the accompanying notes in conjunction with any review of this Schedule 2.

(1) Based on Debtor’s review of affiliate 3rd party liabilities per the affiliate’s 9-14-08 financial statements and the addition of a 1
times liability provision for estimated ISDA claims over the Affiliate derivative liabilities.

(2) Based on Debtor’s review of affiliate 3rd party liabilities per the affiliate’s 9-14-08 financial statements.
LBHI Schedule 3
Class 8
Guarantee Claims Filed by Affiliates
As of March 2010
($ in millions)

Estimated
Guarantee
Claims
filed by
Affiliates
Affiliate (1)

LBSF $ 8,340
LBCS 1,176
LBCC 1,005
LOTC 52
LCPI 1,004
LB International (Europe) 73,567
Lehman Brothers Europe Limited 1,457
Lehman Brothers Limited 2,071
Lehman Brothers UK Holdings Limited 1,938
LBIE Affiliates (5) 123
Lehman Brothers Treasury Co. B.V. 39
Lehman Brothers Bankhaus AG 24,410
Lehman Brothers Finance S.A. 58,304
Lehman Brothers Securities NV 283
Lehman Brothers Japan Inc. 22,794
Lehman Brothers Holdings Japan Inc. 314
Lehman Brothers Finance (Japan) Inc. 289
Other LBJ affiliates 39
LB Asia Holdings Limited 4,807
LB Commercial Corp Asia Ltd 1,599
LB Securities Asia Limited 1,740
Lehman Brothers Asia Ltd 780
LBAH & LBCCA affiliates (3) 221
LB Finance Asia PTE Ltd 161
LB (Pte) Ltd. 14
Other Singapore affiliates (7) 88
LB (Luxembourg) SA 418
LB Equity Finance (Lux) 103
LBI 11,000
LB RE 1,050
LB Australia 107
Misc. Affiliates 4,624

Total $ 223,917

Allowed Pursuant to Plan $ 21,186

The claim numbers presented herein relate to the claims estimates provided in Schedule 1 and, as such, the reader should review
Schedule 1 and the accompanying notes in conjunction with any review of this Schedule 3.

(1) Based on Debtor’s preliminary review of guarantee claims filed by affiliates. Includes amounts for claims not picked up by EPIQ
summary and adjustments for amended claims, duplicate claims, obvious adjustments, and estimates for certain unliquidated claims.
Also, includes estimates for LBSF, LBCS, LBCC, LOTC, LCPI and other affiliates under LBHI’s control not yet required to file
proofs of claim.
 Exhibit 99.2

Lehman Brothers Preliminary Report on Chapter 11 Plan

NEW YORK, March 29, 2010 — On March 15, 2010, Lehman Brothers Holdings Inc. and its 22 affiliated chapter 11 debtors
(collectively, the “Debtors”) filed a joint proposed chapter 11 plan (“Plan”) with the United States Bankruptcy Court for the Southern
District of New York. The Debtors’ time within which to file a disclosure statement relating to the Plan has been extended by Order
of the Bankruptcy Court to at least April 14, 2010. For the purpose of providing preliminary and general information as to the
formulation of the Plan, the Debtors have filed a Current Report on a Form 8-K with the Securities and Exchange Commission that
sets out preliminary and general information as to the progress that the Debtors have made in connection with the over 65,000 claims
that have been filed against the Debtors.

The Report is not intended and does not constitute a solicitation of acceptances of the Plan. The Report has been filed for the sole
purposes stated above.