Volume 4 of 9

Total Page:16

File Type:pdf, Size:1020Kb

Volume 4 of 9 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ x : In re : Chapter 11 Case No. : LEHMAN BROTHERS HOLDINGS INC., : 08‐13555 (JMP) et al., : : (Jointly Administered) Debtors. : ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ x REPORT OF ANTON R. VALUKAS, EXAMINER Jenner & Block LLP 353 N. Clark Street Chicago, IL 60654‐3456 312‐222‐9350 919 Third Avenue 37th Floor New York, NY 10022‐3908 212‐891‐1600 March 11, 2010 Counsel to the Examiner VOLUME 4 OF 9 Section III.A.5: Secured Lenders Section III.A.6: Government EXAMINER’S REPORT TABLE OF CONTENTS (SHORT‐FORM) VOLUME 1 Introduction, Sections I & II: Executive Summary & Procedural Background Introduction...................................................................................................................................2 I. Executive Summary of the Examiner’s Conclusions......................................................15 A. Why Did Lehman Fail? Are There Colorable Causes of Action That Arise From Its Financial Condition and Failure?.....................................................15 B. Are There Administrative Claims or Colorable Claims For Preferences or Voidable Transfers?......................................................................................................24 C. Do Colorable Claims Arise From Transfers of LBHI Affiliate Assets To Barclays, or From the Lehman ALI Transaction? ....................................................26 II. Procedural Background and Nature of the Examination ..............................................28 A. The Examiner’s Authority...........................................................................................28 B. Document Collection and Review..............................................................................30 C. Systems Access..............................................................................................................33 D. Witness Interview Process...........................................................................................35 E. Cooperation and Coordination With the Government and Parties......................37 Section III.A.1: Risk III. Examiner’s Conclusions......................................................................................................43 A. Why Did Lehman Fail? Are There Colorable Causes of Action That Arise From Its Financial Condition and Failure?.....................................................43 1. Business and Risk Management..........................................................................43 a) Executive Summary .......................................................................................43 i b) Facts..................................................................................................................58 c) Analysis .........................................................................................................163 VOLUME 2 Section III.A.2: Valuation 2. Valuation ..............................................................................................................203 a) Executive Summary .....................................................................................203 b) Overview of Valuation of Lehman’s Commercial Real Estate Portfolio .........................................................................................................215 c) Senior Management’s Involvement in Valuation....................................241 d) Examiner’s Analysis of the Valuation of Lehman’s Commercial Book................................................................................................................266 e) Examiner’s Analysis of the Valuation of Lehman’s Principal Transactions Group......................................................................................285 f) Examiner’s Analysis of the Valuation of Lehman’s Archstone Positions.........................................................................................................356 g) Examiner’s Analysis of the Valuation of Lehman’s Residential Whole Loans Portfolio.................................................................................494 h) Examiner’s Analysis of the Valuation of Lehman’s RMBS Portfolio .........................................................................................................527 i) Examiner’s Analysis of the Valuation of Lehman’s CDOs ....................538 j) Examiner’s Analysis of the Valuation of Lehman’s Derivatives Positions.........................................................................................................568 k) Examiner’s Analysis of the Valuation of Lehman’s Corporate Debt Positions ...............................................................................................583 l) Examiner’s Analysis of the Valuation of Lehman’s Corporate Equities Positions .........................................................................................594 ii Section III.A.3: Survival 3. Lehman’s Survival Strategies and Efforts........................................................609 a) Introduction to Lehman’s Survival Strategies and Efforts.....................609 b) Lehman’s Actions in 2008 Prior to the Near Collapse of Bear Stearns............................................................................................................622 c) Actions and Efforts Following the Near Collapse of Bear Stearns .......631 VOLUME 3 Section III.A.4: Repo 105 4. Repo 105................................................................................................................732 a) Repo 105 – Executive Summary.................................................................732 b) Introduction ..................................................................................................750 c) Why the Examiner Investigated Lehman’s Use of Repo 105 Transactions ..................................................................................................764 d) A Typical Repo 105 Transaction ................................................................765 e) Managing Balance Sheet and Leverage ....................................................800 f) The Purpose of Lehman’s Repo 105 Program Was to Reverse Engineer Publicly Reported Financial Results.........................................853 g) The Materiality of Lehman’s Repo 105 Practice ......................................884 h) Knowledge of Lehman’s Repo 105 Program at the Highest Levels of the Firm .....................................................................................................914 i) Ernst & Young’s Knowledge of Lehman’s Repo 105 Program..............948 j) The Examiner’s Conclusions ......................................................................962 iii VOLUME 4 Section III.A.5: Secured Lenders 5. Potential Claims Against Lehman’s Secured Lenders .................................1066 a) Introduction and Executive Summary....................................................1066 b) Lehman’s Dealings With JPMorgan ........................................................1084 c) Lehman’s Dealings With Citigroup.........................................................1224 d) Lehman’s Dealings With HSBC ...............................................................1303 e) Lehman’s Dealings With Bank of America ............................................1375 f) Lehman’s Dealings With Bank of New York Mellon............................1376 g) Lehman’s Dealings With Standard Bank................................................1382 h) Lehman’s Dealings With the Federal Reserve Bank of New York .....1385 i) Lehman’s Liquidity Pool...........................................................................1401 Section III.A.6: Government 6. The Interaction Between Lehman and the Government..............................1482 a) Introduction ................................................................................................1482 b) The SEC’s Oversight of Lehman ..............................................................1484 c) The FRBNY’s Oversight of Lehman ........................................................1494 d) The Federal Reserve’s Oversight of Lehman .........................................1502 e) The Treasury Department’s Oversight of Lehman ...............................1505 f) The Relationship of the SEC and FRBNY in Monitoring Lehman’s Liquidity....................................................................................1507 g) The Government’s Preparation for the “Lehman Weekend” Meetings at the FRBNY .............................................................................1516 iv h) On the Evening of Friday, September 12, 2008, the Government Convened a Meeting of the Major Wall Street Firms in an Attempt to Facilitate the Rescue of Lehman ..........................................1523 i) Lehman’s Bankruptcy Filing ....................................................................1535 VOLUME 5 Section III.B: Avoidance Actions B. Are There Administrative Claims or Colorable Claims for Preferences or Voidable Transfers....................................................................................................1544 1. Executive Summary ..........................................................................................1544 2. Examiner’s Investigation of Possible Administrative Claims Against LBHI (First Bullet) .............................................................................................1546
Recommended publications
  • Download Pdf 707.34 KB
    NOT FOR DISTRIBUTION IN OR INTO OR TO ANY PERSON LOCATED OR RESIDENT IN THE UNITED STATES, ITS TERRITORIES AND POSSESSIONS, ANY STATE OF THE UNITED STATES OR THE DISTRICT OF COLUMBIA (INCLUDING PUERTO RICO, THE U.S. VIRGIN ISLANDS, GUAM, AMERICAN SAMOA, WAKE ISLAND AND THE NORTHERN MARIANA ISLANDS) OR IN OR INTO OR TO ANY PERSON LOCATED OR RESIDENT IN ANY OTHER JURISDICTION WHERE IT IS UNLAWFUL TO DISTRIBUTE THIS DOCUMENT. EXOR N.V. ANNOUNCES FINAL RESULTS OF ITS TENDER OFFERS Amsterdam, 20 January 2021. EXOR N.V. (the Company) hereby announces the final results of its invitations to eligible Noteholders of its €750,000,000 2.125 per cent. Notes due 2 December 2022, ISIN XS1329671132 (of which €750,000,000 is currently outstanding) (the 2022 Notes) and its €650,000,000 2.50 per cent. Notes due 8 October 2024, ISIN XS1119021357 (of which €650,000,000 is currently outstanding) (the 2024 Notes, and together with the 2022 Notes, the Notes and each a Series) to tender their Notes for purchase by the Company for cash up to an aggregate maximum acceptance amount of €400,000,000 in aggregate nominal amount (the Maximum Acceptance Amount) (such invitations, the Offers and each an Offer). The Offers were announced on 12 January 2021 and were made on the terms and subject to the conditions set out in the tender offer memorandum dated 12 January 2021 (the Tender Offer Memorandum) prepared in connection with the Offers, and subject to the offer and distribution restrictions set out in the Tender Offer Memorandum.
    [Show full text]
  • The Corporate Governance Lessons from the Financial Crisis
    ISSN 1995-2864 Financial Market Trends © OECD 2009 Pre-publication version for Vol. 2009/1 The Corporate Governance Lessons from the Financial Crisis Grant Kirkpatrick * This report analyses the impact of failures and weaknesses in corporate governance on the financial crisis, including risk management systems and executive salaries. It concludes that the financial crisis can be to an important extent attributed to failures and weaknesses in corporate governance arrangements which did not serve their purpose to safeguard against excessive risk taking in a number of financial services companies. Accounting standards and regulatory requirements have also proved insufficient in some areas. Last but not least, remuneration systems have in a number of cases not been closely related to the strategy and risk appetite of the company and its longer term interests. The article also suggests that the importance of qualified board oversight and robust risk management is not limited to financial institutions. The remuneration of boards and senior management also remains a highly controversial issue in many OECD countries. The current turmoil suggests a need for the OECD to re-examine the adequacy of its corporate governance principles in these key areas. * This report is published on the responsibility of the OECD Steering Group on Corporate Governance which agreed the report on 11 February 2009. The Secretariat’s draft report was prepared for the Steering Group by Grant Kirkpatrick under the supervision of Mats Isaksson. FINANCIAL MARKET TRENDS – ISSN 1995-2864 - © OECD 2008 1 THE CORPORATE GOVERNANCE LESSONS FROM THE FINANCIAL CRISIS Main conclusions The financial crisis can This article concludes that the financial crisis can be to an be to an important important extent attributed to failures and weaknesses in corporate extent attributed to governance arrangements.
    [Show full text]
  • Lehman Brothers Inc. and Barclays Agree to End Litigation and Resolve Claims Wind-Down of Estate Continues
    Lehman Brothers Inc. and Barclays Agree to End Litigation and Resolve Claims Wind-Down of Estate Continues New York, June 5, 2015 – James W. Giddens, Trustee for the liquidation of Lehman Brothers Inc. (LBI) under the Securities Investor Protection Act (SIPA), and Barclays Capital Inc. and Barclays Bank PLC today agreed to resolve certain claims and end all ongoing and potential litigation between them. The agreement is consistent with past orders and judgments entered in the litigation and is subject to approval by U.S. Bankruptcy Judge, the Honorable Shelley C. Chapman. “It has always been our duty to prudently and diligently pursue every avenue of recovery for assets we believe belong to the estate, and we did so on behalf of creditors by taking the Barclays litigation all the way to the Supreme Court,” Giddens said. “This agreement ends years of litigation and achieves the best result under the circumstances as winding-down and closing out the estate continues in earnest.” Barclays purchased Lehman’s brokerage business following a hearing in Bankruptcy Court that began on September 19, 2008. Immediately after the purchase, the Trustee set in motion the transfer to Barclays of more than 110,000 customer accounts representing more than $92 billion in customer property. At the same time, the Trustee and Barclays engaged in complex and lengthy litigation over certain disputed assets. The Trustee was successful in Bankruptcy Court after 34 days of trial in a case that presented complex and novel legal issues. Subsequently, various appeals court rulings sided with Barclays. The litigation is now concluded as part of this agreement.
    [Show full text]
  • The Immediate and Lasting Impacts of the 2008 Economic Collapse—Lehman Brothers, General Motors, and the Secured Credit Markets
    DO NOT DELETE 4/22/2011 11:28 AM THE IMMEDIATE AND LASTING IMPACTS OF THE 2008 ECONOMIC COLLAPSE—LEHMAN BROTHERS, GENERAL MOTORS, AND THE SECURED CREDIT MARKETS Edward J. Estrada * I. INTRODUCTION Following the economic meltdown that began in the spring of 2008, immediate and longer term ramifications began to ripple through all aspects of the economy. Clearly, these tremors have not yet subsided, and continued fallout will be felt in the coming years. Importantly, even those companies and industries that have seemingly passed through the most immediate wave of im- pacts will be susceptible to the ongoing struggle to achieve sus- tainable growth. Many such companies may experience future de- faults, largely dependent upon the strength and vitality of economic growth in the coming year and their industry perfor- mance in that timeframe. In 2008, as the financial giants of the world began to struggle and collapse, some in the course of a few days, it was widely be- lieved that the credit markets, and in turn the global economy, would completely seize up, causing an economic catastrophe un- paralleled in modern history.1 While tumultuous, what did in fact happen was something far less dramatic, but it had a lasting negative impact, nevertheless. As often happens in crises, some impacts were to be expected and other events were complete surprises. For example, the re- sulting flight from risk by investors (both corporate and individu- * Partner in the Commercial Restructuring and Bankruptcy Group of the New York office of Reed Smith LLP. The author would like to thank Aaron Bourke, an associate in the Commercial Restructuring and Bankruptcy Group of the New York office of Reed Smith LLP, for his contributions to the article.
    [Show full text]
  • Citi Acquisition of Wachovia's Banking Operations
    Citi Acquisition of Wachovia’s Banking Operations September 29, 2008 Transaction Structure Transaction Citi acquires Wachovia’s retail bank, corporate and investment bank and private bank Details businesses – Citi pays $2.2 billion to Wachovia in Citi common stock – Citi assumes substantially all of Wachovia’s debt; preferred stock excluded – Wachovia remains a publicly-traded holding company consisting of its retail brokerage and asset management businesses Capital Citi expects to raise $10 billion in common equity from the public markets Citi issues preferred stock and warrants to FDIC with a fair value of $12 billion at closing, accounted for as GAAP equity with full Tier 1 and leverage ratio benefit Quarterly dividend reduced to $0.16 per share immediately Regulatory capital relief on substantially all of the $312 billion of loss protected assets Risk Mitigation Citi enters loss protection arrangement with the FDIC on $312 billion of loss protected assets; maximum potential Citi losses of $42 billion – Citi is responsible for the first $30 billion of losses, recorded at closing through purchase accounting – Citi is responsible for the next $12 billion of losses, up to a maximum of $4 billion per year for the next three years – FDIC is responsible for any additional losses – Citi issues preferred stock and warrants to FDIC with a fair value of $12 billion at closing Approvals FDIC approved; subject to formal Federal Reserve approval and Wachovia shareholder approval Closing Anticipated by December 31, 2008 1 Terms of Loss Protection
    [Show full text]
  • Bear Stearns High Grade Structured Credit Strategies Fund
    Alter~(lv~ Inv<!'Stment M.I~i(,lIlenl AsSO<.iaUon AlMA'S ILLUSTRATIVE QUESTIONNAIRE FOR DUE DILIGENCE OF Bear Stearns High Grade Structured Credit Strategies Fund Published by The Alternative Investment Management Association Limited (AlMA) IMPORTANT NOTE All/any reference to AlMA should be removed from this document once any amendment is made of any question .or information added· including details of a company/fund. Only AlMA can distribute this questionnaire in its current form to its member companies and institutional investors on its confidential database. AlMA's Illustrative Questionnaire for Due Diligence Review of Hedge Fund Managers ~ The Alternative Investment Management Association Limited (AlMA), 2004 1 of 25 Confidential Treatment Requested by JPMorgan BSAMFCIC 00000364 AlMA's Illustrative Questio~naire for Due Diligence Review of HEDGE FUND MANAGERS This due diligence questionnaire is a tool to assist investors when considering a hedge fund manager and a hedge fund. Most hedge fund strategies are more of an investment nature than a trading activity. Each strategy has its own peculiarities. The most important aspect is to understand clearly what you plan to invest in. You will also have to: • identify the markets covered, • understand what takes place in the portfolio, • understand the instruments used and how they are used, • understand how the strategy is operated, • identify the sources of return, • understand how ideas are generated, • check the risk control mechanism, • know the people you invest wIth professionally and, sometimes, personally. Not all of the following questions are applicable to aU managers but we recommend that you ask as many questions as possible before making a dedsion.
    [Show full text]
  • Appendix E: Occ Supervision of Citibank, Na
    APPENDIX E: OCC SUPERVISION OF CITIBANK, N.A. I. OCC’s Supervision of Large National Banks The foundation of the OCC’s supervision of the largest national banks is our continuous, on-site presence of examiners at each of our 15 largest banking companies. Citibank is one of the banks in our Large Bank Program. These 15 banking companies account for approximately 89 percent of the assets held in all of the national banks under our supervision. The resident examiner teams are supplemented by subject matter experts in our Policy Division, as well as Ph.D. economists from our Risk Analysis Division trained in quantitative finance. Since 2005, the resident examiner team at Citibank averaged approximately 50 resident examiners, supplemented by the subject matter experts and economists mentioned above, and additional examiners as needed on specific targeted examinations. Our Large Bank Program is organized with a national perspective. It is highly centralized and headquartered in Washington, and structured to promote consistency and coordination across institutions. The onsite teams at each or our 15 largest banks are led by an Examiner-In-Charge (“EIC”), who reports directly to one of the Deputy Comptrollers in our Large Bank Supervision Office in Washington, DC. This enables the OCC to maintain an on- going program of risk assessment, monitoring, and communication with bank management and directors. Resident examiners apply risk-based supervision to a broad array of risks, including credit, liquidity, market, compliance, and operational risks. Supervisory activities are based on supervisory strategies that are developed for each institution that are risk-based and focused on the more complex banking activities.
    [Show full text]
  • Hsi 12.31.20
    HSBC SECURITIES (USA) INC. Statement of Financial Condition December 31, 2020 2 HSBC Securities (USA) Inc. STATEMENT OF FINANCIAL CONDITION December 31, 2020 (in millions) Assets Cash................................................................................................................................................................... $ 285 Cash segregated under federal and other regulations ....................................................................................... 609 Financial instruments owned, at fair value (includes $9,072 pledged as collateral, which the counterparty has the right to sell or repledge)..................................................................................................................... 9,153 Securities purchased under agreements to resell (includes $4 at fair value)..................................................... 20,643 Receivable under securities borrowing arrangements....................................................................................... 11,758 Receivable from brokers, dealers, and clearing organizations.......................................................................... 4,154 Receivable from customers................................................................................................................................ 269 Other assets (include $13 at fair value)............................................................................................................. 295 Total assets.......................................................................................................................................................
    [Show full text]
  • Maneerut Anulomsombat, Senior Associate – Investment Banking, the Quant Group
    Maneerut Anulomsombat, Senior Associate – Investment Banking, The Quant Group. [email protected] Maneerut is a Senior Associate Director at The Quant Group – Investment Banking, she graduated magna cum laude in Industrial Engineering from Chulalongkorn University and an MBA from Stanford University. May 2008 Smackdown - The Fight for Financial Hegemony Last night I switched on the cable and World Wrestling Championship was on. I’ve never really watched wrestling before but for the five minutes that I did, it seemed like the fight was between two greasy large muscular male slamming their heads at each other surrealistically and theatrically slapstick. Amidst this fight another large muscular male came out from backstage, jumped into the ring and dropped-kick one wrestler who fell off the stage then turned around and slammed the other wrestler while the referee bounced around the ring ineffectively. Apparently this is a common scene on “Smackdown”. I don’t know what it is exactly but this made me think about the fights for the hegemony in global deal-making between the three giants: Private Equity Funds (PE), Hedge Funds (HF), and Sovereign Wealth Funds (SWF). And while the authorities and senate banking committees don’t always wear striped black and white referee shirts, they seem to be bouncing around not quite certain what to do as well. And here's how the giants compare by size. The Asset Under Management (AUM) of PE by the end of year 2007 was around US$1.16 trillion. The AUM of SWFs rose from US$500 Million in 1990 to US$3.3 trillion in 2007, overshadowing the US$1.7 trillion of AUM thought to be managed by HFs in year 2007 (up from $490 billion in year 2000).
    [Show full text]
  • As Parex Banka
    AS PAREX BANKA ANNUAL REPORT FOR THE YEAR ENDED 31 DECEMBER 2008 TOGETHER WITH INDEPENDENT AUDITORS’ REPORT Table of Contents Management Report 3 Management of the Bank 7 Statement of Responsibility of the Management 8 Financial Statements: Statements of Income 9 Balance Sheets 10 Statements of Changes in Equity 11 Statements of Cash Flows 13 Notes 14 Auditors’ Report 80 AS Parex banka Smilšu 3, Riga, LV-1522, Latvia Phone: (371) 67010 000 Facsimile: (371) 67010 001 Registration number: 40003074590 2 AS Parex banka Management Report The year 2008 brought major change to Parex banka , including substantial changes in shareholders structure and the management of the bank in the last months of 2008. This report has been prepared by the new Management Board and Supervisory Council of the Bank and they are committed to leading the Bank into a new phase of development. Financial crisis and its implications on Parex banka The year of 2008 brought unprecedented challenges for the financial sector both in Latvia and worldwide. The global credit crunch, starting in the United States of America, caused a chain reaction all over the world and intensified the economic difficulties in Latvia. The financial sector in Latvia has been affected in a number of ways, mostly through reduced availability of funding and liquidity from international financial markets, a weakening economy and the resulting decline of asset quality. The crisis has necessitated the adoption of new approaches to the financial sector and has led to a thorough reconsideration of its practices. Parex banka itself experienced a severe impact from the crisis of 2008.
    [Show full text]
  • Kevin Bonebrake Joins Lazard As a Managing Director in Oil and Gas Financial Advisory
    KEVIN BONEBRAKE JOINS LAZARD AS A MANAGING DIRECTOR IN OIL AND GAS FINANCIAL ADVISORY NEW YORK, January 11, 2017 – Lazard Ltd (NYSE: LAZ) announced today that Kevin Bonebrake has joined the firm as a Managing Director, Financial Advisory, effective immediately. Based in Houston, he will advise companies in the oil and gas sector on mergers and acquisitions and other financial matters. “As the energy industry continues to undergo transformative change, Lazard has been advising clients on a growing number of both strategic transactions and restructuring assignments,” said Matt Lustig, head of North American Investment Banking at Lazard. “Kevin will be a strong addition to our Houston team and enhance our ability to advise our energy clients worldwide.” Mr. Bonebrake has more than 12 years of energy-sector advisory experience, with a focus on North American independent exploration & production companies, majors and national oil companies. He joins Lazard from Morgan Stanley, where he was most recently a Managing Director in the firm’s Global Natural Resources practice within the Investment Banking Division. Between 2003 and 2009 he worked for Salomon Smith Barney/Citigroup as a member of its Global Energy Investment Banking team. About Lazard Lazard, one of the world’s preeminent financial advisory and asset management firms, operates from 42 cities across 27 countries in North America, Europe, Asia, Australia, Central and South America. With origins dating to 1848, the firm provides advice on mergers and acquisitions, strategic matters, restructuring and capital structure, capital raising and corporate finance, as well as asset management services to corporations, partnerships, institutions, governments and individuals.
    [Show full text]
  • Citigroup Inc. (Exact Name of Registrant As Specified in Its Charter)
    UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 10-K ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the fiscal year ended December 31, 2010 Commission file number 1-9924 Citigroup Inc. (Exact name of registrant as specified in its charter) Delaware 52-1568099 (State or other jurisdiction of (I.R.S. Employer incorporation or organization) Identification No.) 399 Park Avenue, New York, NY 10043 (Address of principal executive offices) (Zip code) Registrant’s telephone number, including area code: (212) 559-1000 Securities registered pursuant to Section 12(b) of the Act: See Exhibit 99.01 Securities registered pursuant to Section 12(g) of the Act: none Indicate by check mark if the Registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes X No Indicate by check mark if the Registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes X No Indicate by check mark whether the Registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the Registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. X Yes No Indicate by check mark whether the Registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the Registrant was required to submit and post such files).
    [Show full text]