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Table Of Contents

NATURE OF ACTION
PARTIES
Plaintiff and the GSEs
Defendants
Morgan Stanley Defendants
Non-MS Defendants
Individual Defendants
Non-Party Originators
JURISDICTION AND VENUE
FACTUAL ALLEGATIONS
I. FACTUAL ALLEGATIONS APPLICABLE TO ALL CLAIMS
A. The Securitizations
1. Residential Mortgage-Backed Securitizations Generally
2. Securitizations At Issue In This Case
3. Securitization Process
b. The Trusts Issued Securities Backed by the Loans
1. Defendant MS
2. Defendant SCI
3. Defendants MSMC and SFM
4. Defendants MSAC, MSC, and SASC
5. Defendant MS&Co
6. Non-MS Defendants
7. Individual Defendants
C. STATEMENTS IN THE PROSPECTUS SUPPLEMENTS
1. Compliance With Underwriting Guidelines
2. Occupancy Status of Borrower
3. Loan-to-Value Ratios
4. Credit Ratings
a. Owner-Occupancy Data was Materially False
b. Loan-to-Value Data was Materially False
i. New Century Violated Its Underwriting Guidelines
ii. WMC Violated Its Underwriting Guidelines
iii. IndyMac Violated Its Underwriting Guidelines
iv. Wilmington Violated Its Underwriting Guidelines
II. ADDITIONAL FACTUAL ALLEGATIONS
FIRST CAUSE OF ACTION
SECOND CAUSE OF ACTION
THIRD CAUSE OF ACTION
FOURTH CAUSE OF ACTION
FIFTH CAUSE OF ACTION
SIXTH CAUSE OF ACTION
SEVENTH CAUSE OF ACTION
NINTH CAUSE OF ACTION
TENTH CAUSE OF ACTION
PRAYER FOR RELIEF
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FHFA 2011-09-02 Final Complaint v MS

FHFA 2011-09-02 Final Complaint v MS

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Published by: mortgagefrauds2772 on Sep 26, 2011
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09/26/2011

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