Sunday, May 2, 2010

GoldmanSachs4Show_ECF_Jury

SECURITIES AND EXCHANGE

COMPLAINT

COMMISSION,

[Securities Fraud]

Plaintiff,

10-CV-___________ ( )

v.

ECF CASE

GOLDMAN SACHS & CO. and

Jury Trial Demanded

FABRICE TOURRE,

Defendants.

Plaintiff, the United States Securities and Exchange Commission ("Commission"), alleges as follows against the defendants named above:

OVERVIEW

  1. The Commission brings this securities fraud action against Goldman, Sachs & Co. ("GS&Co") and a GS&Co employee, Fabrice Tourre ("Tourre"), for making materially misleading statements and omissions in connection with a synthetic collateralized debt obligation ("CDO") GS&Co structured and marketed to investors. This synthetic CDO, ABACUS 2007AC1, was tied to the performance of subprime residential mortgage-backed securities ("RMBS") and was structured and marketed by GS&Co in early 2007 when the United States housing market and related securities were beginning to show signs of distress. Synthetic CDOs like ABACUS 2007-AC1 contributed to the recent financial crisis by magnifying losses associated with the downturn in the United States housing market.
  2. GS&Co marketing materials for ABACUS 2007-AC1 – including the term sheet, flip book and offering memorandum for the CDO – all represented that the reference portfolio of

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