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earn higher fees, then selling the debt to other banks, insurance companies and other investors.See ENA Exam. at 103.688. Notwithstanding RBC’s concerns about the “transparency” of Enron’s financials andthe results of its comprehensive analysis of Enron’s off-balance sheet liabilities and other creditrisks, RBC entered into Alberta and Hawaii, as well as numerous other Enron financings, fromSeptember 2000 through the Petition Date. Even as RBC was pocketing the fees from theseoff-balance sheet financings, RBC was protecting its bottom line with syndications, sell-downs,assignments, reduced credit limits and purchased credit derivations on the Enron name. By thePetition Date, RBC’s net exposure was approximately $211 million, down from $750 million in2000.5. The Bank Defendants Acted Together To Manipulate And Misstate Enron’sFinancial Condition.689. The Bank Defendants acted in concert with the Insiders and with each other tomanipulate and misstate Enron’s financial condition. Many of the Enron SPE transactions weredesigned, structured, implemented and/or financed by, or otherwise required the active participationof, more than one of the Bank Defendants. In each instance, each participating Bank Defendant wasaware that the Insiders were improperly recording the financial effects of the SPE transaction.690. Both Citigroup and Barclays facilitated the Roosevelt prepay transaction. Citigrouploaned $500 million to ENGM in the transaction, and Barclays served as the pass-through entity.691. Both Citigroup and Toronto Dominion facilitated the Truman prepay transaction.In two mirror-image prepays which closed on the same day, each loaned $250 million to Enron andeach served as the pass-through entity for the other’s loan.604041v1/007457-239-