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692. Both Citigroup and Toronto Dominion facilitated the Jethro prepay transaction. Intwo mirror-image prepays which closed on the same day, each loaned $337.5 million to Enron andeach served as the pass-through entity for the other’s loan.693. Citigroup, Barclays, RBS and Toronto Dominion facilitated the Nixon PrepayTransaction. Citigroup loaned Enron $104 million, RBS loaned Enron $110 million, and Barclaysloaned Enron $110 million. Toronto Dominion served as the pass-through entity for each of theseloans.694. Both Toronto Dominion and Chase facilitated the December 1998 PrepayTransaction. Toronto Dominion loaned Enron $250 million, and Chase served as the pass-throughentity.695. Toronto Dominion, RBC and Chase facilitated the Alberta Prepay Transaction. Intwo mirror-image prepays which closed on the same day, Toronto Dominion and RBC each loanedEnron Can$147.4 million. Chase served as the pass-through entity for each of these loans.696. Citigroup and Chase facilitated the forest products SPE transactions – Fishtail,Bacchus and Sundance Industrial. In Fishtail, Chase, working with LJM2, supported the so-called“equity” investment, even though that “equity” was not at risk due to support from the Insiders.Chase also provided the Insiders with an inflated valuation of Enron’s pulp and paper tradingbusiness, valuing the assets at more than twice the value being carried on Enron’s books and therebygiving the Insiders an ostensible basis for improperly recognizing a huge gain on the sale of thisbusiness. In Bacchus, Citigroup – based upon the inflated valuation from Chase -- enabled theInsiders to recognize a gain of $112 million, and to report $200 million as cash flow fromoperations, from the sale of Enron’s pulp and paper trading business. Citigroup provided the“equity” investment for Bacchus, knowing that it was not at risk due to assurances of full repaymentfrom Fastow. In Sundance Industrial, Salomon Holding, a Citigroup subsidiary, made an “equity”604041v1/007457-240-

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