Third Amended Complaint - Lehman Brothers Securities Litigation

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COUNT VI Violations Of Section 20A Of The Exchange Act AgainstDefendant Fuld ...................................................................................................... 90PRAYER FOR RELIEF ................................................................................................................ 91-iii-
GLOSSARY OF TERMSAICPA:ALCO:Alt-A:Aurora:ASB:AU:AU § 110:AU § 230:AU § 311:AU § 312:AU § 316:AU § 336:AU § 411:AU § 561:AU § 722:AU § 9336:BNC:Cap * 105:Cash Capital Surplus:CDO:American Institute of Certified Public Accountants.Asset Liability Committee.Alternative A-paper.Aurora Loan Services LLC.Auditing Standards Board.Statements on Auditing Standards issued by the ASB.Responsibilities and Functions of the Independent Auditor.Due Professional Care in the Performance of Work.Planning and Supervision.Audit Risk and Materiality in Conducting an Audit.Consideration of Fraud in a Financial Statement Audit.Using the Work of a Specialist.The Meaning of Present Fairly in Conformity with Generally AcceptedAccounting Principles.Subsequent Discovery of Facts Existing at the Date of the Auditor’sReport.Interim Financial Information.Interpretation of AU Section 336, Using the Work of a Specialist.BNC Mortgage LLC.A method <strong>Lehman</strong> used to assign value to the collateral underlying itsPTG assets.A measure of the excess of long-term funding sources over long-termfunding requirements.Collateralized Debt Obligation.-iv-
Page 2 and 3: TABLE OF CONTENTSI. NATURE OF ACTIO
Page 6 and 7: CEO:CFO:CLO:CMBS:Commercial Portfol
Page 8 and 9: SFAS 133:SFAS 140:SFAS 157:Financia
Page 10 and 11: disclose that (i) it simultaneously
Page 12 and 13: C. Defendants8. At all relevant tim
Page 14 and 15: can only be ascertained through app
Page 16 and 17: A. The Offering Materials Were Mate
Page 18 and 19: 105 transactions, “[c]onsequently
Page 20 and 21: Table 3 - Repo 105 Transactions and
Page 22 and 23: financial condition and operations
Page 24 and 25: were temporarily removed from Lehma
Page 27 and 28: purpose to the transactions. Indeed
Page 29 and 30: management policies and systems ena
Page 31 and 32: 76. Indeed, in order to engage in r
Page 33 and 34: Lehman’s stress tests “meaningl
Page 35 and 36: 3. The Offering Materials Contained
Page 37 and 38: with regard to Level 3 inputs, SFAS
Page 39 and 40: and other boom markets, focused on
Page 41 and 42: specifically carved out “all [of
Page 43 and 44: Lehman had already committed to fin
Page 45 and 46: derivative component of the investm
Page 47 and 48: generally accepted accounting princ
Page 49 and 50: 119. After Lehman’s bankruptcy, i
Page 51 and 52: misleading. The Securities Act Defe
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A. Repo 105 Transactions1. Lehman U
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our governments businesses around t
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154. As the Examiner stated with re
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162. The Insider Defendants knew an
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169. Rather than disclose to the in
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setting of risk limits.” These st
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exceeded its risk appetite limits b
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most part that are in-the-money”
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y the Company on June 9, Callan sta
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198. The 2Q08 10-Q reported that th
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cover lending positions. Jane Buyer
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upon their conversation, McDade und
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(e) Lehman was motivated to manage
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c. On July 20, 2007, Nagioff emaile
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sell assets, and that the distresse
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accordance with the standards of th
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E&Y’s contemporaneous notes demon
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obligations when auditing and revie
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240. AU §§ 336 and 9336 address a
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A delinquencies and loss expectatio
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on behalf of Plaintiffs and other m
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involvement in the day-to-day opera
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(b)(c)(d)(e)(f)Awarding Plaintiffs
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APPENDIX ACOMMON STOCK/PREFERRED ST
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APPENDIX AISSUE DATEApril 4, 2008(t
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APPENDIX AISSUE DATEAugust 1, 2007A
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APPENDIX AISSUE DATEDecember 21,200
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APPENDIX AISSUE DATEFebruary 27,200
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APPENDIX AISSUE DATEMay 9, 2008May
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APPENDIX B
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APPENDIX BISSUE DATESECURITY(CUSIP)
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APPENDIX C1. CW1, an underwriter in
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7. CW7 and CW8, investigators in Au
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Third Amended Complaint - Lehman Brothers Securities Litigation

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