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590 Notes to Chapter 10

37. Michael Burry, interview by FCIC, May 18, 2010.
38. Paulson, interview.
39. Burry, interview.
40. FCIC Hedge Fund Survey. See FCIC website for details.
41. John Geanakoplos, written testimony for the FCIC, Forum to Explore the Causes of the Financial
Crisis, day 1, session 3: Risk Taking and Leverage, February 26, 2010, p. 16.
42. OCC, “Subprime CDO Valuation and Oversight Review—Conclusion Memorandum,” memoran-
dum from Michael Sullivan, RAD, and Ron Frake, NBE, to John Lyons, Examiner-in-Charge, Citibank,
NA, January 17, 2008, p. 6; Paul, Weiss, Citigroup’s counsel, letter to FCIC, June 23, 2010, “Responses of
Nestor Dominguez.”
43. Richard Bookstaber, interview by FCIC, May 11, 2010.
44. “RMBS and Citi-RMBS as a Percentage of Citi-CDO Portfolio Notionals,” produced by Citi for the
FCIC.
45. Federal Reserve Bank of New York, Federal Reserve Board, Office of the Comptroller of the Cur-
rency, Securities and Exchange Commission, U.K. Financial Services Authority, and Japan Financial
Services Authority, “Notes on Senior Supervisors’ Meetings with Firms,” November 19, 2007, p. 3.
46. FCIC staff estimates, based on analysis of Moody’s CDO EMS database.
47. Paul, Weiss, Citigroup’s counsel, letter to FCIC, March 1, 2010, in re the FCIC’s second supple-
mental request, “Response to Interrogatory no. 7”; Paul, Weiss, letter to FCIC, March 31, 2010, updated
response to interrogatory no. 7, p. 5.
48. Nestor Dominguez, interview by FCIC, March 2, 2010; Paul, Weiss, letter of March 31, 2010, pp.
3–6.
49. Corporate Library Analyst Report for Citigroup Inc., April 16, 2007.
50. SEC staff (Sam Forstein, Tim McGarey, Mary Ann Gadziala, Kim Mavis, Bob Sollazo, Suzanne
McGovern, and Chris Easter), interview by FCIC, February 9, 2010.
51. Comptroller of the Currency, memorandum, Examination of Citigroup Risk Management
(CRM), January 13, 2005, p. 3.
52. Ronald Frake, Comptroller of the Currency, letter to Geoffrey Coley, Citibank, N.A., December
22, 2005.
53. Federal Reserve, “New York Operations Review, May 17–25, 2005,” p. 4.
54. Federal Reserve Bank of New York Bank Supervision Group, “Operations Review Report,” De-
cember 2009.
55. Federal Reserve Bank of New York, “Summary of Supervisory Activity and Findings, Citigroup
Inc., January 1, 2005–December 31, 2005,” April 10, 2006; Federal Reserve Bank of New York, “Summary
of Supervisory Activity and Findings,” Citigroup Inc., January 1, 2004–December 31, 2004,” April 5,
2005.
56. Citigroup Inc., Form 8-K, April 3, 2006, Exhibit 99.1.
57. Federal Reserve Board, memo to Governor Susan Bies, February 17, 2006.
58. The board reversed a 15% reduction that had been implemented when the issues began and then
added a 5% raise. Citigroup, 2006 Proxy Statement, p. 37.
59. Comptroller of the Currency, letter to Citigroup CEO Vikram Pandit (Supervisory Letter 2008-
05), February 14, 2008; quotation, p. 2.
60. Federal Reserve Bank of New York, letter to Vikram Pandit and the Board of the Directors of Citi-
group, April 15, 2008, pp. 6–7.
61. Timothy Geithner, testimony before the FCIC, Hearing on the Shadow Banking System, day 2,
session 1: Perspective on the Shadow Banking System, May 6, 2010, transcript, p. 128.
62. Gene Park, interview by FCIC, May 18, 2010.
63. Andrew Forster, email to Gary Gorton, Alan Frost, et al., July 21, 2005.
64. Park, interview.
65. Gorton, interview.
66. Park, interview.
67. Gene Park, email to Joseph Cassano, February 28, 2006.
68. Park, interview.