rime mortgages. The 2006 Form 10-K stated that: 159 EFTA00316887 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 175 of 347 members of the Controllers and Risk Management Departments perform analysis of internal valuations, typically on a monthly basis but often on an intra-month basis as well. These departments are independent

-K mislead investors with respect to the models it used to value mortgage-backed assets and assess risk. The 2007 Form 10-K stated that: Members of the Controllers and Risk Management Departments perform analysis of internal valuations, typically on a monthly basis but often on an intra-month basis as well. These departments are independent