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James Kwak

James Kwak

Posted: April 16, 2010 11:44 AM

SEC Charges Goldman With Fraud

What's Your Reaction:

Press release here. Complaint here. The allegation is that Goldman failed to disclose the role that John Paulson's hedge fund played in selecting residential mortgage-backed securities that went into a CDO created by Goldman. Here's paragraph 3 of the complaint:

In sum, GS&Co arranged a transaction at Paulson's request in which Paulson heavily influenced the selection of the portfolio to suit its economic interests, but failed to disclose to investors, as part of the description of the portfolio selection process contained in the marketing materials used to promote the transaction, Paulson's role in the portfolio selection process or its adverse economic interests.

The problem is that the marketing documents claimed that the securities were selected by ACA Management, a third-party CDO manager, when in fact the selection decisions were influenced by Paulson's fund. Goldman had a duty to disclose that influence, especially since Paulson was simultaneously shorting the CDO. (According to paragraph 2 of the complain, he bought the credit default swaps from Goldman itself. I used to wonder about this; if he bought the CDS from another bank, then Goldman could claim it didn't know he was shorting the CDO, implausible as that claim might be. But in this case Goldman must have known.)

It seems like the key will be proving that Paulson influenced the selection of securities enough that it should have been in the marketing documents. Paragraphs 25-35 include quotations from emails showing that Paulson was effectively negotiating with ACA over the composition of the CDO, so it's pretty clear he had influence. The defense will presumably be that ACA had final signoff on the securities, and Paulson was just providing advice, so Paulson's role did not need to be disclosed. (I don't know what kind of standard will be applied here.)

The complaint also alleges that Goldman misled ACA into thinking that Paulson had a long position in the CDO via the equity tranche, while in fact Goldman knew all along that he would short the debt tranches. It seems pretty clear that that's what ACA believed. The implication is that had ACA realized that Paulson was shorting the CDO, they would not have gone along with the deal.

One of the things I say now and then that most annoys people is that the financial crisis was not caused by criminal behavior. (Note: The "Prayer for the Relief" at the end of the complaint only asks for civil penalties, but I suppose this does not preclude a criminal action -- someone who's a real lawyer could answer that.) My general line is that I'm sure there was some bad behavior that rose to the level of criminal liability -- like lying in disclosure documents -- but that it wasn't necessary for the crisis, and we could have had the crisis without any criminal activity at all. (For example, since most investors weren't even reading the disclosure documents, Goldman could have said that Paulson was involved in the security selection, and then everything would have been hunky-dory.)

And I don't think this action contradicts my general point. I would love it if the SEC could nail banks for some of the CDOs they created, but I'm still betting that the vast majority will not create legal liability for them.

The type of transaction involved -- in which a hedge fund makes a CDO as toxic as possible in order to then short it -- is similar to the Magnetar trade, which I discussed earlier. One thing we learn from paragraph 5 is that Paulson sure knew how to pick 'em:

The deal closed on April 26, 2007. Paulson paid GS&Co approximately $15 million for structuring and marketing ABACUS 2007-AC1. By October 24, 2007, 83% of the RMBS in the ABACUS 2007-AC1 portfolio had been downgraded and 17% were on negative watch. By January 29, 2008, 99% of the portfolio had been downgraded. As a result, investors in the ABACUS 2007-AC1 CDO lost over $1 billion. Paulson's opposite CDS positions yielded a profit of approximately $1 billion for Paulson.

And once again, no doubt to the annoyance of many, I don't blame Paulson. It's Goldman that had the duty to its investors, not Paulson.

Fabrice Tourre of Goldman, however, who is named as a defendant? Well, he will forever be identified by the email quoted in paragraph 18, whatever it means:

At the same time, GS&Co recognized that market conditions were presenting challenges to the successful marketing of CDO transactions backed by mortgage-related securities. For example, portions of an email in French and English sent by Tourre to a friend on January 23, 2007 stated, in English translation where applicable: 'More and more leverage in the system, The whole building is about to collapse anytime now...Only potential survivor, the fabulous Fab[rice Tourre]...standing in the middle of all these complex, highly leveraged, exotic trades he created without necessarily understanding all of the implications of those monstruosities!!!' Similarly, an email on February 11, 2007 to Tourre from the head of the GS&Co structured product correlation trading desk stated in part, 'the cdo biz is dead we don't have a lot of time left.'

Originally posted on the Baseline Scenario.

 
 
 
 
 
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11:42 PM on 04/18/2010
If I were a Republican, instead of the tea party nonsense, I would constantly put up Obama's quote that Goldman CEO Lloyd Blankfein is a savvy businessman, while pointing out the fraud that Goldman commited.
06:54 PM on 04/18/2010
Many of us who were critics of Goldman Sachs and JP Morgan for a long time are feeling vindicated today because it seems like everyone can now smell the awful rotten stinch in our 'financial refigerater' and it's Goldman Sachs.

As soon as Goldman Sachs SHUTS DOWN like Enron, World Com, Lehman Bros., and countless others, there will be a sigh of relief around the world.

CNBS and all of these silly financial shows have duped mom-n-pop into playing along the game of suckers that Wall Street/City of London loves to use a as a vaccum to loot the public.

Many of my family and friends will pop champaigne bottles when we read "Goldman Sachs No More' and the world will join us in jubilation and celebration much like the 'fall-of-communism'.

I imagine even tears of joy will come accross the faces of people in every nation as justice is finally served.
08:55 PM on 04/18/2010
I have to stop myself from getting too excited. I'm hoping for the best, but expect GS will shed its skin and emerge as something even more nasty.
KIampfbeobachter
Misanthropic economic and political shaman
01:16 PM on 04/18/2010
About a century ago Karl Fürstenberg, a famous German banker was asked by a visitor to the Berlin stock exchange: “Excuse me Sir where is the toilet here?”
His alleged answer
“Ham wa hier nich, hier bescheisst einer den anderen”

On request I will provide a translation’
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Dartwin
03:37 PM on 04/18/2010
Knüppelhart!
08:58 PM on 04/18/2010
We are waiting.
11:06 AM on 04/18/2010
Right now these are just allegations - I'll withhold judgment until the facts are all out during the trial. In the USA one is (still) presumed innocent until proven otherwise.

That said - it was the absolute wrong move for the government to bail out any financial companies. They should have let the market take its course and the firms go bankrupt if necessary. Bankruptcy would have freed us of the compensation contracts with the big bonuses but more importantly would have freed the capital to better managers and sent a strong message that there is a price to failure.
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Elbrando
The dream shall never die - Ted Kennedy
08:26 AM on 04/18/2010
The problem isn't that these people gambled with money. It is the fact that the business had such a large legitimate business that was connected to it.

Its like being on a very large boat and blowing a hole in it. most of the boat is good except the hole.

What we need to do is not patch the hole, but turn the boat into house. If the house has a big hole you can close the door and the rest of the house is still good.
05:42 PM on 04/17/2010
If an investment fund manager bought a series of old run down apartment buildings, insured them to the hilt and then rigged the furnaces to explode thus destroying the buildings so he could collect on the insurance, he would be guilty of arson for profit, insurance fraud and possibly a number of other felonies. I see very little difference between this and the criminal acts of Godman Sachs et.al.
The hedge fund managers, Goldman Sachs and everyone else who were involved in this criminal conspiracy need to be prosecuted to the full extent of the law. That is why we have RICO statures. Clearly we have here an organized conspiracy to commit securities fraud, grand theft, while the perpetrators get to award themselves obscene bonuses for their sopisticated business savvy. Now that Goldman Sachs is a person under the Constitution, it along with its CEO, CFO COO, and all the rest of this nest of econterrorists should be arrested for fraud and their assets forfeited. That would pay off the deficit handsomely. I would love to see Lloyd Blankenfeld's head literally explode when he arrives to work only to find the building padlocked and under the guard of U.S. marshalls, and then finds out there isn't anything he can do about it.
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vernbvb
05:19 PM on 04/17/2010
I am reading over and over that these are only civil charges and don't do much. I beg to differ. These civil charges leave Goldman Sachs and the rest of the financial industry exposed. I believe that there will be many other charges, both civil and criminal, to follow for many in the financial industry.
12:12 PM on 04/17/2010
Well it is easy to hate lawyers. But in this case of massive fraud, what America needs is a dedicated group of trust busting lawyers, much like the trust busters of the early 1900's, and really go after the top banksters. Except this time around, there should be no holds barred - fraud cannot be committed by companies - fraud is committed by people, the fraudsters. Each and every one of them, from CEO on down to the salesmen level, should be sued for everything he or she is worth, and more. Fraud recoveries are not dischargeable in bankruptcy.

Perhaps a RICO (organized crime) claim or two would stir things up - American banksters are more powerful and control Washington much more than the scariest of gangsters ever did. Many of the individual CDS programs are difficult to prosecute, if only because the defense is going to be "the other guys did it too." Only by putting all the bad conduct together would it make sense, that the ENTIRE series of conduct was fraudulent, and SHOULD subject the banksters to both trebled damages and punitive damages.

To these financial crooks who care not a whiff about the American people, throwing them in jail is good, but taking away their money serves justice best.
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11:45 AM on 04/17/2010
Well done sir!!!
DenverJJ
11:25 AM on 04/17/2010
The SEC sends Goldman Sachs a "WELLS NOTICE" last JULY, informing them they were being investigated for a lack of disclosure. For the last two quarters and in their annual report just two weeks ago, they did not disclose the WELLS NOTICE !!!!!!!!!!!!!!!!!!!!!!!!!!!!

Do I smell a cover up????
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Tom Matlack
Man, Husband, Dad, Writer, Venture Capitalist
11:10 AM on 04/17/2010
Okay so let me get this straight: we bailed out the major investment banks (including Goldman) with hundreds of billions of tax-payer money. A year later their profits have soared, bonuses have continued to rise, and it turns out they knowingly created synthetic packages of toxic mortgages that they sold to investors with no disclosure?

On NPR yesterday I heard about how the door men on Park Avenue (who make on average $60k) are threatening to strike and were picketing specifically because the tenants in their buildings are making tens of millions in bonuses and they refuse to give them a pay raise.

Makes me think of Rome...and Marx. What happened to a capitalist system that is fair and open? Where merit and honestly actually leads to economic growth and increased prosperity for all? Our system is broken. The financial crisis didn't hurt the investment banks, it massively helped them. It reduced competition and proved these banks, which are really just massive hedge funds, can take huge risks without actually taking any risk at all because you and I are backstopping them.
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Dukedraven
11:36 AM on 04/17/2010
Yup.
03:09 AM on 04/18/2010
I agree with most of your post.
However, I would point out that there never was a Capitalist system that was fair and open. Capitalism is not about merit or honesty either.
It is about making the rich richer and pushing ever more people into poverty, it is about the survival of the fittest (i.e. the already wealthy).
What you are looking for is some kind of 'regulated Capitalism', but regulation that makes Capitalism fair and open, introduces honesty and merit, in essence does away with Capitalism and you will move on to an other economic system.
I think the failure of so many people to realise the true nature of Capitalism is part of the problem.
11:16 AM on 04/18/2010
I do not think you really understand capitalism. Capitalism is about people freely entering into contracts to to exchange goods and services and investing their saved wealth to create additional wealth - all without the use of force or fraud. Essentially the only regulation needed is defense from the use of force or fraud for capitalism to work.

If your assertion that it's about the rich getting richer and the poor getting poorer being a key to capitalism were true then the people of Venezuela would not be so poor now, would they? The poorest in the USA live better than the middle class in communist countries for a reason - capitalism improvesopportunities for all to improve their standard of living. Sadly you have this completely backwards.
11:08 AM on 04/17/2010
The SEC charged Bank of America with commiting billions of dollars of fraud in connection with its merger with Merrill Lynch. It ended up fining them $30 million dollars (the judge said it was not enough, so they increased it to $150 million, if my memory is correct). Basically, a slap on the wrist, Why does anyone think this will end any differently?
03:11 AM on 04/18/2010
It is not even a slap on the wrist. Shareholders will have to pay for that - by a reduced dividend. The perpetrators of these acts don't pay anything at all. There are just no consequences for them, meaning they will be doing it again.
10:13 AM on 04/17/2010
I'm looking forward to seeing Lloyd Blankfein in an orange jump suit with a number on his back.
10:01 AM on 04/17/2010
If you oppose Wall Street reform you are a Republican.
01:58 PM on 04/18/2010
If you let Wall Street criminals off the hook, you are a Democrat. Remember the immortal words of Richard Durbin concerning the Senate: "(the bankers) own the place."
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RonK Michigan
Half of the people you know are below average
09:49 AM on 04/17/2010
God must truly love the Republican Party - LOL. First McCain says "The economy is sound" the day before it tanks and now the entire party signs a letter stating that "Wall Street doesn't need regulation" the day before this happens.
Shazam!!!!!
Yup - THAT'S IT - All of the sex scandals have turned God away - how will they EVER get him back?????

Ronk’s Steven Wright Quote Du-Jour:
“If going to church makes you a Christian, then standing in a garage makes you a car”