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etween 1997 and 2001, and, as of November 2000, had averaged a 110% rate of return on its Enroninvestments. See Exam. IV, App. E at 15, 18. RBS was willing to participate in the transactions theInsiders used to manipulate Enron’s balance sheets because -- quite simply – those transactions paidmore than the bank’s ordinary Enron work. RBS recognized in connection with one suchtransaction: “Because this is balance sheet management, it pays better than straight Enron corporaterisk.” RBS 3112212 (quoted in Exam. IV, App. E at 82).632. Enron was such an important client that RBS occasionally participated in structuredfinance transactions it knew were suspect so it could secure Enron’s future business. For example,RBS was reluctant to extend the Nixon Prepay Transaction because, as one RBS analyst put it, “[t]hescale of financial period manipulation is exceedingly worrying.” RBS 3118862 (quoted in Exam.IV, App. E at 82). However, following what one RBS document describes as “intense pressure onrelationship grounds,” RBS agreed to the extension – but only because it could protect itself bypurchasing a credit derivative. See Exam. IV, App. E at 83.633. RBS’s longstanding and profitable relationship with Enron gave it inside access toEnron’s financial information. RBS had a much more accurate understanding of Enron’s financialcondition, including an understanding of Enron’s off-balance sheet liabilities, than could be gleanedfrom Enron’s financial statements alone. In November, 1998, the Head of Credit Risk for RBSrecognized that Enron “will remain heavily leveraged if one takes into account all their off-balancesheet liabilities . . . .” RBS 1117824-RBS 1117826 (quoted in Exam. III, App. G. at 21). AnotherRBS document noted “continuing moves by Enron to, not only transfer assets off-balance sheet[,]but also to leave Enron itself as little more than a provider of intellectual, hedging and otheroperational support.” RBS 3088396 (quoted in Exam. IV, App. E at 22) (emphasis in original). Inits 2000 “Rating Profile” of Enron, RBS stated that Enron’s “aggressive financial policy . . . resultsin massive off-balance sheet liabilities.” RBS 3088345 (quoted in Exam. IV, App. E at 27). Top604041v1/007457-217-

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