X0303 4 2009-12-09 0 0001348259 VALIDUS HOLDINGS LTD VR 0000070858 BANK OF AMERICA CORP /DE/ BANK OF AMERICA CORPORATE CENTER 100 N TRYON ST CHARLOTTE NC 28255 1 0 0 0 Common Stock 2009-12-09 4 P 0 8 26.73 A 5714293 I By Subsidiary Common Stock 2009-12-11 4 S 0 8 26.98 D 5714285 I By Subsidiary Common Stock 2009-12-16 4 P 0 400 26.97 A 5714685 I By Subsidiary Common Stock 2009-12-16 4 P 0 200 26.98 A 5714885 I By Subsidiary Common Stock 2009-12-16 4 S 0 600 27.01 D 5714285 I By Subsidiary This Form 4 is being filed by Bank of America Corporation (?BAC?), a Delaware corporation and bank holding company registered under the Bank Holding Company Act of 1956, on behalf of its subsidiaries. Transaction executed by the error correction section of Merrill Lynch, Pierce, Fenner & Smith Incorporated ("MLPFS"), a broker-dealer and subsidiary of BAC, to correct errors made in connection with trades made on behalf of clients of MLPFS. In connection with this transaction, BAC has agreed to voluntarily remit appropriate profits, if any, to Validus Holdings Ltd. BAC disclaims that such transaction is subject to reporting under Section 16(a) or disgorgement under Section 16(b), and this report shall not be deemed an admission that those sections apply to such transaction. 4,285,714 shares are owned directly by ML Global Private Equity Fund, L.P. ("MLGPE"), a partnership whose general partner is MLGPE Ltd., a wholly-owned subsidiary of ML Global Private Equity Partners, L.P. ("MLGPELP"), whose general partner is Merrill Lynch GP, Inc. ("ML GP"), a wholly-owned subsidiary of Merrill Lynch Group, Inc. ("ML Group"), a wholly-owned subsidiary of Merrill Lynch & Co., Inc. ("ML&Co."), which is a direct wholly-owned subsidiary of BAC. 1,428,571 shares are owned directly by Merrill Lynch Ventures L.P. 2001 ("ML Ventures LP"), a partnership whose general partner is Merrill Lynch Ventures, L.L.C. ("ML Ventures LLC"), a wholly-owned subsidiary of ML Group. 8 shares are directly owned by MLPFS. No shares are directly owned by MLPFS. 400 shares are directly owned by MLPFS. 600 shares are directly owned by MLPFS. Each of BAC, ML&Co., MLGPE, MLGPE Ltd., MLGPELP, ML GP, ML Group, ML Ventures LP, ML Ventures LLC and MLPFS (collectively, the "Reporting Persons") disclaims beneficial ownership of these securities, except to the extent of its pecuniary interest therein. BAC may be deemed a director by virtue of the fact that an employee of an affiliate of BAC, Mandakini Puri, serves as a director of the Issuer. Each of the Reporting Persons disclaims its possible status as director of the Issuer. /s/ William Woo, Attorney-in-Fact for Bank of America 2009-12-30