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April 24, 2010


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Steve Diamond

Kim, Did you notice the risk factor in the OC explaining that the housing market was in trouble? I remain baffled by the suggestion of civil violations here much less criminal.

Kim Krawiec

Good catch, Steve! I didn't even see that my first time through. There is really quite a bit of info in the Offering Circular beyond what was in the flip book (as one would expect, of course -- it's nearly twice as long). But some of the disclosures, including the risk factor you identify, seem to go directly to the SEC case. Like you, unless they have new information not disclosed publicly, I can't imagine how a criminal case could be successful.

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