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Indeed, in an April 10, 2008 report, analysts at Defendant Citigroup Global Markets Inc.posited the liquidity crisis had created a situation where LIBOR at times no longer represents the level at which banks extend loans to others; specifically, the analysts concluded LIBOR may understate actual interbank lending costs by 20-30bp [basis points].By acting together and in concert to knowingly understate their true borrowing costs, Defendants caused LIBOR to be set artificially low. Defendants manipulation of LIBOR allowed them to pay unduly low interest rates to investors, on LIBOR-based financial instruments offered during the Class Period. Plaintiff Nathanial Haynes (Haynes) is a resident of Chicago, Illinois. is a federally chartered national banking association headquartered in Charlotte, North Carolina and an indirect, wholly owned subsidiary of Defendant Bank of America Corporation. (Citibank) is federally chartered national banking association headquartered in New York, New York and a wholly owned subsidiary of Defendant Citigroup, Inc. Defendant Citigroup is a Delaware corporation headquartered in New York, New York.30. Lloyds was formed in 2009 through the acquisition of Defendant HBOS plc (HBOS) by Lloyds TSB Bank plc.34.Investorswho until recently had no reason to suspect Defendants knowing suppression of LIBORjustifiably believed the financial instruments they were purchasing derived from a rate that was based on USD-LIBOR panel members honest and reasonable assessments of their borrowing costs. This Court has jurisdiction over this action pursuant to Section 22 of the CEA, 7U. Plaintiff Haynes traded on-exchange based products tied to LIBOR such as Eurodollar futuresand was harmed as a consequence of Defendants unlawful conduct. Bank of America Corporation is a Delaware corporation headquartered in Charlotte, North Carolina. Defendant Bank of America Corporation and Bank of America, N. are hereinafter referred to collectively as BAC)28. Defendant West LB AG (West LB) is a German joint stock company headquartered in Dusseldorf, Germany.Defendantsaffiliates actively traded in these markets, including and especially in the Eurodollar futures market on the CME. Additionally, Citigroup, which controlled Citibank and reaped significant financial benefit from the suppression of LIBOR, actively participated in the conspiracy During the Class Period, the following subsidiaries or other affiliates of Defendants joined and furthered the conspiracy by trading LIBOR-based financial instruments such as Eurodollar futures contracts at manipulated prices not reflecting fundamental supply anddemand, to the direct benefit of Defendants: (i) Credit Suisse Securities (USA) LLC; (ii) Bank of America Securities LLC; (iii) J. In light of those facts, Plaintiffs have reason to believe the dealer entities identified above materially aided or contributed to the manipulation of USD-LIBOR.Moreover, by understating their true borrowing costs, Defendants provided a false or misleading impression of their financial strength to investors and the rest of the market.15. DEFENDANTS SUPPRESSED LIBOR DURING THE CLASS PERIOD 45. 1 LIBOR is a reference interest rate used as the basis for the pricing of fixed income futures, options, swaps and other derivative products traded on the CME and the Chicago Board of Trade (CBOT).

4 Scott Peng, Chintan (Monty) Gandhi, & Alexander Tyo, Special Topic: Is LIBOR Broken?6 The Defendants are among the member banks of the BBA. The board is composed of senior executives from twelve banks, including Barclays Bank plc, Citibank NA, Credit Suisse, Deutsche Bank AG, HSBC Bank plc, J. Morgan Europe Ltd., and the Royal Bank of Scotland plc. No regulatory agency oversees the setting of LIBOR rates by the BBA and its members. During the Class Period, designated 6 last accessed on April 30, 2012.As the BBA itself concedes, it is not a regulatory body and has no regulatory function. The resultant rates are not filed with, or subject to the approval of, any regulatory agency. 7 last accessed on April 30, 2012 8 last accessed on April 30, 2012., April 10, 2008 (published by Citigroup Global Markets Inc.The BBA describes itself on its website as the leading trade association for the UK banking and financial services sector, claiming that it speak[s] for over 200 member banks from 60 countries on the full range of UK and international banking issues. It is governed by a board of member banks that meets four times each year. Dollars, Japanese Yen, pound sterling, the Australian dollar, the Canadian dollar, the New Zealand dollar, the Danish krone, the Euro, the Swiss Franc and the Swedish krone) isoverseen by a separate LIBOR panel created by the BBA.

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