GSE Bonds Antitrust Litigation

ATTENTION:The Settlement Hearing for the Deutsche Bank, FTN, Goldman Sachs, Barclays and Group Defendants Settlements on June 9, 2020 – at 3:30pm – will be held telephonically. The telephone dial-in information for the Settlement Hearing is the following:

USA Toll-Free: (888) 363-4735 and when prompted enter the access code: 1086415

-OR-

USA Caller Paid/International Toll: (215) 446-3657 and when prompted enter the access code: 1086415

Please dial in at least a five minutes prior to the start time for the hearing. If you have not filed an appearance in the case, please remain on mute for the call's duration in order to minimize background noise.

ATTENTION: For all Class Members, the deadline for you to file claims for the Barclays and Group Settling Defendants is May 12, 2020.

********Additional Settling Defendants********

Plaintiffs entered into additional $337 million Settlements with Barclays Capital Inc. (“Barclays”); BNP Paribas Securities Corp. (“BNP Paribas”); Cantor Fitzgerald & Co. (“Cantor Fitzgerald”); Citigroup Global Markets Inc. CGMI, Credit Suisse Securities (USA) LLC (“Credit Suisse”); HSBC Securities (USA) Inc. (“HSBC”); J. P. Morgan Securities LLC (“J. P. Morgan”); Merrill Lynch, Pierce, Fenner & Smith Inc. (“Merrill Lynch”); Morgan Stanley & Co., LLC (“Morgan Stanley”); Nomura Securities International, Inc. (“Nomura”); SG Americas Securities LLC (“SG Americas”); TD Securities (USA) LLC (“TD Securities”); and UBS Securities LLC (“UBS”) (together, “Newly-Settling Defendants”).

Plaintiffs previously entered into separate $49.5 million Settlements with Goldman Sachs & Co. LLC (“Goldman Sachs”), Deutsche Bank Securities Inc. (“Deutsche Bank”), and First Tennessee Bank, N.A., and FTN Financial Securities Corp. (together, “FTN”) (the “Previous Settlements”).

IF YOU ALREADY SUBMITTED A TIMELY AND VALID CLAIM IN CONNECTION WITH THE PREVIOUS SETTLEMENTS, THAT CLAIM WILL AUTOMATICALLY BE APPLIED TO BOTH THOSE SETTLEMENTS, AND THESE SETTLEMENTS. YOU DO NOT NEED TO TAKE ANY FURTHER ACTION.

The information contained on this website is only a summary. You may download copies of the Deutsche Bank and FTN Notice by clicking here, the Goldman Sachs Notice by clicking here, the Newly Settling Defendants Notice by clicking here, and the Proof of Claim Form by ("Claim Form") clicking here. Because this website is just a summary, you should review the Notices for additional details.

Please Check This Website Regularly. Documents, Dates and Other Information May Change and Any Updates Will Be Posted on this Website.

The Settlement Class:
The Court has preliminarily approved the Settlement Class consisting 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
(January 1, 2009 through and including January 1, 2019).

Defendants are Barclays Capital Inc.; BNP Paribas Securities Corp.; Citigroup Global Markets Inc.; Credit Suisse Securities (USA) LLC; Deutsche Bank Securities, Inc.; First Tennessee Bank, N.A.; FTN Financial Securities Corp.; Goldman Sachs & Co. LLC; J. P. Morgan Securities LLC; Merrill Lynch, Pierce, Fenner & Smith Inc.; TD Securities (USA) LLC; Nomura Securities International, Inc.; HSBC Securities (USA) Inc.; Cantor Fitzgerald & Co.; SG Americas Securities LLC; Morgan Stanley & Co., LLC; and UBS Securities LLC.

“GSE Bond Transaction” means any purchase, sale, or other transaction in the secondary market with respect to any GSE Bond.

“GSE Bond” means any and each unsecured bond or debt instrument (i.e., senior debt, subordinated debt, and junior subordinated debt) regardless of currency or credit quality, issued by Federal National Mortgage Association, Federal Home Loan Mortgage Corporation, Federal Farm Credit Banks, and Federal Home Loan Banks.

“Settlement Class Period” means the period from January 1, 2009 through and including January 1, 2019.

The Settlements Size and Benefits:
Deutsche Bank has agreed to pay a total of $15 million, FTN has agreed to pay a total of $14.5 million, Goldman Sachs has agreed to pay a total of $20 million, Barclays has agreed to pay a total of $87 million, and BNP Paribas, Cantor Fitzgerald, CGMI, Credit Suisse, HSBC, J. P. Morgan, Merrill Lynch, Morgan Stanley, Nomura, SG Americas, TD Securities, and UBS (the “Group Settling Defendants”) have agreed to pay a total of $250 million for the benefit of the proposed Settlement Class (together, the “Settlement Fund”).

If the Settlements are approved, the Settlement Fund, plus interest earned from the date it was established, less any Taxes, any Notice and Administration Costs, any Court-awarded attorneys’ fees and Litigation Expenses, and any other costs or fees approved by the Court (the “Net Settlement Fund”) will be divided among all Settlement Class Members who file valid and timely Claim Forms. If you are a member the Settlement Class and do not exclude yourself, you may be eligible to share in the Net Settlement Fund. The deadline to exclude yourself from the Previous Settlements has passed. The Court in charge of this case must decide whether to approve the Settlements. Payments will be made if the Court approves the Settlements and, if there are any appeals, after appeals are resolved.

For all details of the Settlements, read the Stipulation of Settlement with Deutsche Bank, Stipulation of Settlement with FTN, Stipulation of Settlement with Goldman Sachs, Stipulation of Settlement with Barclays and Stipulation of Settlement with Group Settling Defendants.

What is this case about?

The Action alleges that Defendants conspired to fix prices of GSE Bond Transactions issued by Federal National Mortgage Association, Federal Home Loan Mortgage Corporation, Federal Farm Credit Banks, and Federal Home Loan Banks in the secondary market in violation of Section 1 of the Sherman Antitrust Act, 15 U.S.C. §1. The Defendants deny any and all allegations of misconduct alleged by Plaintiffs, and deny having engaged in any wrongdoing whatsoever.

IMPORTANT DATES REGARDING SETTLEMENTS WITH DEUTSCHE BANK, FTN, AND GOLDMAN SACHS

February 28, 2020

Claim Filing Deadline. Claim Forms must be completed and filed no later than 11:59 PM eastern on February 28, 2020, to be eligible for a payment from the Settlements with Deutsche Bank, FTN, or Goldman Sachs.

If you cannot complete the Claim Form online, please mail a completed Claim Form so that it is received no later than February 28, 2020, to:

GSE Bonds Antitrust Litigation
c/o A.B. Data, Ltd.
P.O. Box 173084
Milwaukee, WI 53217

June 9, 2020 at 3:30 p.m.

The Settlement Hearing. The Settlement Hearing will be held on June 9, 2020, at 3:30 p.m., before the Honorable Jed S. Rakoff at the Daniel Patrick Moynihan United States Courthouse, 500 Pearl St., New York, NY 10007, Courtroom 14B. The Court will consider the fairness, reasonableness, and adequacy of the proposed Settlements with Deutsche Bank, FTN, and Goldman Sachs, the proposed Plan of Distribution, and the application for attorneys’ fees, and reimbursement of Litigation Expenses at the Settlement Hearing.

x IMPORTANT DATES REGARDING SETTLEMENTS WITH NEWLY SETTLING DEFENDANTS xx
May 12, 2020	Claim Filing Deadline. Unless you already submitted a timely and valid Claim in connection with the Previous Settlements, the only way to receive your share of the Net Settlement Fund is to complete and file a timely and valid Claim by no later than May 12, 2020. If you cannot complete the Claim Form online, please mail a completed Claim Form so that it is received no later than May 12, 2020, to: GSE Bonds Antitrust Litigation c/o A.B. Data, Ltd. P.O. Box 173084 Milwaukee, WI 53217
April 22, 2020	Exclusion Deadline. To exclude yourself from the Newly-Settling Defendants Settlement Class, you must submit a written request for exclusion so that it is received no later than April 22, 2020 in accordance with the instructions in the Notice .
April 22, 2020	Objection Deadline. Any objections to the proposed Settlements with the Newly-Settling Defendants, the proposed Plan of Allocation, and/or the request for attorneys’ fees, reimbursement of Litigation Expenses, and any service awards for Plaintiffs must be filed no later than April 22, 2020, in accordance with the instructions in the Notice.
June 9, 2020 at 3:30 p.m.	The Settlement Hearing. The Settlement Hearing will be held on June 9, 2020, at 3:30 p.m., before the Honorable Jed S. Rakoff at the Daniel Patrick Moynihan United States Courthouse, 500 Pearl St., New York, NY 10007, Courtroom 14B. The Court will consider the fairness, reasonableness, and adequacy of the proposed Settlements with the Newly Settling Defendants, the proposed Plan of Distribution, and the application for attorneys’ fees and reimbursement of Litigation Expenses at the Settlement Hearing.