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COMPLAINT JURY TRIAL DEMANDED

In addition, the Bundesbank also offers an electronic procedure intended specifically for the handling of mass payments (credit transfers, cheques and direct debits), namely the Retail Payment System (RPS). (The principal features of the above-mentioned payment systems of the Deutsche Bundesbank are described in Section 3.) Apart from operating national payment systems with a European linkage to TARGET, the Bundesbank also processes cross-border and cross-currency payments via AZV (Auslandszahlungsverkehr; Cross- border Payment Services). For this reason it holds bilateral accounts with credit institutions abroad. Since March 1995, banks have also been able to process incoming and outgoing cross-border payments via the. | UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK FEDERAL HOUSING FINANCE AGENCY AS CONSERVATOR FOR THE FEDERAL NATIONAL MORTGAGE ASSOCIATION AND THE FEDERAL HOME LOAN MORTGAGE CORPORATION Plaintiff -against- BANK OF AMERICA CORPORATION BANK OF AMERICA NATIONAL ASSOCIATION MERRILL LYNCH PIERCE FENNER SMITH INC. f k a BANC OF AMERICA SECURITIES LLC ASSET BACKED FUNDING CORPORATION BANC OF AMERICA MORTGAGE SECURITIES INC. BANC OF AMERICA FUNDING CORPORATION GEORGE C. CARP ROBERT CARUSO GEORGE E. ELLISON ADAM D. GLASSNER DANIEL B. GOODWIN JULIANA JOHNSON AASHISH KAMAT MICHAEL J. KULA JAMES H. LUTHER WILLIAM L. MAXWELL MARK I. RYAN AND ANTOINE SCHETRITT Defendants. CIV. COMPLAINT JURY TRIAL DEMANDED TABLE OF CONTENTS Page NATURE OF ACTION.1 PARTIES.6 The Plaintiff and the GSEs.6 The Defendants.7 The Non-Party Originators.10 JURISDICTION AND VENUE.11 FACTUAL ALLEGATIONS.12 I . THESECURITIZATIONS.12 A . Residential Mortgage-Backed Securitizations In General.12 B . The Securitizations At Issue In This Case.13 C . The Securitization Process.15 1. BOA National Groups Mortgage Loans in Special Purpose Trusts.15 2. The Trusts Issue Securities Backed by the Loans.16 II. THE DEFENDANTS PARTICIPATION IN THE SECURITIZATION PROCESS. 20 A. The Role of Each of the Defendants.20 1. BOA National.20 2. ABF Corp.22 3. BOA Mortgage.22 4. BOA Funding.23 5. MLPF S As Successor-in-Interest to BOA Securities .24 6. BOA Corporation.24 7. The Individual Defendants.25 i B. The Defendants Failure To Conduct Proper Due Diligence.27 III. THE REGISTRATION STATEMENTS AND THE PROSPECTUS SUPPLEMENTS.29 A. Compliance With Underwriting Guidelines.29 B. Statements Regarding Occupancy Status of Borrower.31 C. Statements Regarding Loan-to-Value Ratios.33 D. Statements Regarding Credit Ratings.36 IV. THE FALSITY OF STATEMENTS IN THE REGISTRATION STATEMENTS AND PROSPECTUS SUPPLEMENTS. 38 A. The Statistical Data Provided in the Prospectus Supplements Concerning Owner Occupancy and LTV .