t Bear Steams' risk control models were severely flawed and not up-to-date. Moreover, Cayne knew, or was reckless in not knowing that, according to the SEC Inspector General, Bear Stearns' own risk managers did not have an 113 EFTA00316841 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 129 of 347 expertise