The Complaint alleges that Defendants and their unnamed co-conspirators engaged in a combination and conspiracy in an unreasonable and unlawful restraint of trade. During the Class Period, Defendants controlled the supply of Fannie and Freddie bonds (“FFBs available to investors and were horizontal competitors in the FFB market). The combination and conspiracy consisted of a continuing agreement, understanding and concerted action between and among Defendants and their co-conspirators in furtherance of which Defendants fixed, maintained, and charged artificial prices for FFBs to investors. Defendants’ collusion enabled them to collect supra-competitive profits on every transaction of FFBs with Plaintiffs and the Class. At the same time, it caused Plaintiffs and the Class to pay more (in the case of FFB purchases) and receive less (in the case of FFB sales) on their FFB transactions with Defendants.

On behalf of all persons and entities who or which entered into a GSE Bond Transaction with one or more Defendants or a direct or indirect parent, subsidiary, affiliate, or division of a Defendant during the Settlement Class Period.

The Plan of Distribution categorizes GSE Bond Transactions into 31 categories based on the remaining years until maturity when the bond was purchased, sold, or otherwise transacted. For each maturity category, a “Risk Number,” which is a widely accepted measure of the sensitivity of a bond’s price to changes in yield, and a Multiplier based on the Risk Number has been assigned. ISS SCAS clients can see more details within the RecoverMax platform.