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its ability to deploy [structured finance] accounting techniques to manage these key credit ratios.”Exam. II at 36 (emphasis added). Similarly, the Bank Defendants’ participation with the Insiders’private investment partnerships was critical to their formation and success. Without the knowinginvolvement of the Bank Defendants in these vehicles for self-dealing, the Insiders would not havebeen able to obtain tens of millions of dollars at the company’s expense.700. The transactions in which each Bank Defendant participated materially alteredEnron’s financial condition. The Citigroup prepay transactions, alone, materially affected Enron’s1999 statement of cash flow from operations, causing it to artificially increase from $293 millionto over $1.2 billion, an increase of over 300%. The group of Citigroup transactions challengedherein allowed the Insiders to improperly record more than $5 billion of cash flows from operatingactivities, improperly record approximately $132 million in income, and understate Enron’s debtby billions of dollars during the relevant period. Similarly, the Chase prepay transactions, alone,assisted the Insiders in overstating Enron’s cash flow from operations by $2.6 billion fromDecember 1997 through September 2001. Without these transactions, Enron’s operating cash flowwould have been 28% lower in 1999 and 21% lower in 2000, and Enron’s debt would have been16% higher in 1999 and 23% higher in 2000. Focusing specifically on the prepay transactions, theEnron Examiner found that for 1999 and 2000 Enron “almost certainly” would have had lower creditratings had these transactions not occurred.701. More than half of Enron’s net income reported for 1998 was provided by threeFAS 140 transactions with CIBC. Those same transactions provided 45% of Enron’s reported cashflow from operations that year. During 1999, 13% of Enron’s reported net income and 67% of itscash flow from operations were based upon FAS 140 transactions with CIBC. The improper taxtransactions that Deutsche Bank facilitated contributed over $518 million to Enron’s net income,most of which occurred during the relevant period. The Nigerian Barge and 1999 Electricity604041v1/007457-242-