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Notes to Chapter 13 599

70. Martin Sullivan, interview by FCIC, June 17, 2010; Steve Bensinger, interview by FCIC, June 16,
2010; Robert Lewis, interview by FCIC, June 15, 2010; Kevin McGinn, interview by FCIC, June 10, 2010;
Andrew Forster, Elias Habayeb, and Steve Bensinger, testimony before the FCIC, Hearing on the Role of
Derivatives in the Financial Crisis, day 2, session 1: American International Group, Inc. and Goldman
Sachs Group, Inc., July 1, 2010, transcript, pp. 11, 61–62.
71. Clarence K. Lee, former managing director for Complex and International Organizations, Office
of Thrift Supervision, testimony before the FCIC, Hearing on the Role of Derivatives in the Financial
Crisis, day 2, session 2: Derivatives: Supervisors and Regulators, July 1, 2010, transcript, pp. 232–35.
72. Alan Frost, interview by FCIC, May 11, 2010.
73. Joseph Cassano, interview by FCIC, June 25, 2010.
74. “Information Pertaining to the Multi-Sector CDS Portfolio,” produced by AIG, with FCIC staff
calculations.
75. Andrew Davilman, email to Alan Frost, subject: “Sorry to bother you on”; Frost, email to Davil-
man, subject: “Re: Sorry to bother you on”; Davilman, email to Frost, subject: “Re: Sorry to bother you
on”—all July 26, 2007.
76. Goldman Sachs International, Collateral Invoice to AIG Financial Products Corp., July 27, 2007,
produced by Goldman Sachs.
77. AIG hedges, January 2006–December 2008, produced by Goldman Sachs.
78. Andrew Forster, interview by FCIC, June 23, 2010.
79. Daniel Sparks, interview by FCIC, May 11, 2010.
80. “Valuation & Pricing Related to Initial Collateral Calls on Transactions with AIG,” produced by
Goldman Sachs.
81. Jon Liebergall and Andrew Forster, telephone conversation, July 30, 2007, transcript, pp. 402–4.
82. David Viniar, written testimony for the FCIC, Hearing on the Role of Derivatives in the Financial
Crisis, day 2, session 1: American International Group, Inc. and Goldman Sachs Group, Inc., July 1, 2010,
p. 2.
83. Liebergall and Forster, telephone conversation, July 30, 2007, transcript, p. 407.
84. Tom Athan, email to Andrew Forster, August 1, 2007.
Chapter 13
1. Henry Paulson, quoted in Kevin Carmichael and Peter Cook, “Paulson Says Subprime Rout Doesn’t
Threaten Economy,” Bloomberg, July 26, 2007.
2. Moody’s Investors Service, “Moody’s ABCP Program Index: CP Outstanding as of 06/30/2007.”
3. Moody’s Investors Service, “Moody’s Performance Overview: Rhineland Funding Capital Corpora-
tion,” June 30, 2007.
4. As noted, in the United States, there was a minimal capital charge for liquidity puts equal to 10% of
the base 8%, or 0.8%. Staff of Bundesanstalt fur Finanzdienstleistungsaufsicht (the Federal Financial
Services Supervisory Authority, Germany’s bank regulators), interview by FCIC, September 8, 2010. See
also Office of the Comptroller of the Currency, “Interagency Guidance on the Eligibility of Asset-Backed
Commercial Paper Liquidity Facilities and the Resulting Risk-Based Capital Treatment,” August 4, 2005.
For example, Citigroup would have held $200 million in capital against potential losses on the $25 billion
in liquidity put exposure that it had accumulated on CDOs it had issued.
5. IKB, 2006/2007 Annual Report, June 28, 2007, p. 78.
6. Securities Fraud Complaint, Securities and Exchange Commission v. Goldman Sachs & Co. and
Fabrice Tourre, no. 10-CV-3229 (S.D.N.Y. April 15, 2010), p. 6.
7. IKB staff, interview by FCIC, August 27, 2010; Securities and Exchange Commission (plaintiff)
v. Goldman Sachs & Co. and Fabrice Tourre (defendants), Securities Fraud Complaint, 10-CV-3229,
United States District Court, Southern District of New York, April 15, 2010, at 17, paragraph 58.
8. “Preliminary results for the first quarter (1 April-30 June 2007),” IKB press release, July 20, 2007.
9. IKB staff, interview; IKB, clarification of interview by FCIC, November 15, 2010; IKB, restated
2006/2007 Annual Report, p. 5.
10. Steven Meier, testimony before the FCIC, Hearing on the Shadow Banking System, day 2, session
3: Institutions Participating in the Shadow Banking System, May 6, 2010, transcript, p. 307.