MEMORANDUM

To: Managing Partner, Compliance Team

From: Mark James Bradley, Esq.

Date: September 11, 2009

Re: SEC Deposition of V.L.

_____________________________________________________________________________
_

INTRODUCTION

Defendant V.L. (“V.L.”), who had been Managing Director (“MD”) of Product Development &
Support at Defendant Corporation (“DEFENDANT CORPORATION”) was deposed by the
SEC on August 7, 2008. Succinctly, V.L.’s role and the function of Product Development and
Support was to monitor the mortgage loan market (including sub-prime) for competitive
disparities, make mortgage loan product recommendations designed to maintain competitive
parity if not advantage, coordinate any changes through project management and implement any
updates in the requisite software architecture. Throughout his deposition, V.L. seemed unsure of
basic dates of policy/culture changes and whether he was present at certain meetings. Although
he could describe the changes in the sub-prime policy and the mechanics of mortgage loan
alteration, V.L. could not confidently cite the source for these actions or define the dispositive
characteristics of a sub-prime loan. His testimony did not reveal any apparent concern other than
a vague awareness of sub-prime risk within DEFENDANT CORPORATION during the crucial
2004-2006 period. He is even ambivalent about his role within DEFENDANT
CORPORATION during this time, describing his function as a neutral, disinterested,
administrative fact finder while his word choices and occupational self description imply an
executive or at least advisory capacity. The SEC deposition reveals that V.L. is an excellent
source of background information but has little information of litigative, “smoking–doc” caliber.
The limited testimony that is helpful to our theory of the case is subject to numerous
qualifications, revisions and inconsistencies. His value as a witness ranges from moderately
helpful to equivocal.

Primarily due to his 18-year tenure at DEFENDANT CORPORATION, V.L. is a comprehensive

source of the mechanics and the corporate culture (if not the underlying motive) of loan product
implementation and modification. However this knowledge of process is without any apparent
macroscopic insight into the risk to DEFENDANT CORPORATION, the mortgage market or
the economy as a whole. Quite to the contrary, there seemed to be a de facto checks and
balances system with Product Leadership lobbying to maximize sub-prime participation and
Product Management arguing for risk based restraints. If this quasi-adversarial system was not
sufficiently suspect, Product Management may have had a super veto that could overrule credit
risk concerns. This system was later modified (V.L. was uncertain as to when) to allow
stalemates between the two groups to be decided by the President of DEFENDANT
CORPORATION as a tiebreaker. V.L. does remember that the President at the time of this
change was S.D., hardly a champion of mortgage loan moderation.

V.L. should be an intermediate priority deponent. Although he seems to possess a large amount
of institutional knowledge of DEFENDANT CORPORATION and occupied a crucial position
at a critical time to this litigation, he is an uncertain and indecisive witness. This indecision and
uncertainty is particularly evident when recounting the dates of specific events and the official
status of sub-prime initiatives. In addition, every time the SEC elicited an apparent inconsistency
or potentially damaging concession, V.L. had a highly technical, but non-incriminating
explanation or was allowed to qualify his statement to the extent of making it valueless from a
litigative standpoint. In short, he has a finite ability to confirm or deny our theory of the case.
Due to the technical nature of this deposition, it is recommended that relevant experts in the
respective fields of residential mortgages, finance, and project management (Six Sigma) be
consulted. Also, if undertaken, any subsequent deposition should focus on fleshing out and
locking down the dates of particular sub-prime events of interest, the official status of the
DEFENDANT CORPORATION policy behind them, and the nature of V.L.’s role in their
execution.

CURRICULUM VITAE AND DEPONENT’S ROLE AT DEFENDANT CORPORATION

In 1990, V.L. received a Bachelor of Science with a major in Business Marketing from
California State University, Northridge (D. 15). He began work at Defendant Corporation in
1993 as a Funder-Writer (In-House Loan Officer) and has been there continuously in several
professional capacities. In 1995, V.L. became Sales Marketing Manager in the Home Equity
Lending Division, where his responsibility was to develop and promote the new line of home
equity products throughout the field offices and branches of Defendant Corporation. He was
also responsible for the operational readiness of loan product systems platforms & data/software
population. In 2000, V.L. was promoted to Senior Vice President of Product Development &
Support (“PDS”), the successor entity to the Home Equity Lending Division. During this time,
V.L. became responsible for the expansion & contraction of company prime lending products.

In 2005, V.L. was responsible for the expansion and contraction of all mortgage product
guidelines to include nonconforming (“NC”) and sub-prime loans. During this time, the role of
V.L. and PDS was expanded to include market surveillance and the achievement of competition
parity in terms of mortgage product offerings & guidelines (D. 18). V.L. stated that he would
recommend product changes and produce justifications for these changes (D. 19). If the
recommendations received credit approval, V.L. and PDS would implement these changes in the
software guidelines and automated data systems (D. 19, 20). V.L. & PDS were also responsible
for communicating/disseminating these changes to the sales force at DEFENDANT
CORPORATION (D. 20). In this position, he reported consecutively and respectively to R.B.
and B.K. (D. 25, 29). V.L. stated that in 2007 his title changed to Managing Director of Product
Development & Support and he reported to M. E. Currently, V.L. is a First Mortgage Product
Executive at Successor Corporation and reports to H.E. (D. 39).

SUMMARY OF LITIGATION ISSUES

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The SEC Deposition of V.L. touches on several issues of litigation interest. These issues are not
mutually exclusive and there is thematic overlap. To accommodate these aspects of the
deposition structure, some litigation issues have been combined, omitted or truncated.

Culture Change

According to V.L., DEFENDANT CORPORATION’s perception of sub-prime disparity in the

loan mortgage market and the decision to embrace and maximize participation in this product as
both remedy and goal, took place more in mid 2005 rather than in 2003. During the deposition,
V.L. admitted that prior to 2005 there was less compulsion to match competitors1 (D. 32). The
philosophy during this time was to look at the market as a whole rather than reactive
brinkmanship (D. 32).

However in early 2005, V.L. stated that there was an expansion of sub-prime lending. Also, the
appearance of new entrants and investors led to Wall Street publishing mortgage loan guidelines
to brokers & correspondent lenders and the “aggregation of the market” (D. 32). It was the
period of early 2005 to the end or midway of 2007 that V.L. said the perception of competition
became “fierce”(D. 32). V.L. reiterates that it was 2005 in which there was an increasing
emphasis and pressure to monitor the market and competitors and to offer a broad and
competitive product line by DEFENDANT CORPORATION; but he rejects the email assertion
of J.M. (“J.M.”) about Product Leadership and the guidelines process as “pushing for whatever
we can get” (D. 32, 33, 209). However, when prompted by the SEC, V.L. revised his timeline
and agreed that 2003 was the year DEFENDANT CORPORATION desired to stay competitive
(maybe even extremely competitive) by matching appropriate loan programs in the field of
nonconforming Jumbo & Super Jumbo Adjustable Rate Mortgages and in all appropriate
origination product sectors (D. 72, 73). This competitive desire was reflected in a policy by
which V.L. would survey the market competition and DEFENDANT CORPORATION would
mirror or match mortgage loan products offered by other lenders (D. 28). V.L. is uncertain as to
whether this “policy” was written or official. He is also unaware of how he came to know of this
policy or who had communicated it to him (D. 28, 29). V.L. was only certain of the fact that
DEFENDANT CORPORATION had a “basic paradigm” in which it would be a “fast follower
to market changes” in the loan products area (D. 28).

Accounting/Loan Underwriting

At DEFENDANT CORPORATION, accounting issues directly determined the types of

mortgage product loans that could be offered. V.L. made product recommendations based on his
monitoring of the market to Product Management which would evaluate the risks and either
accept, decline or make a counter-offer. Initially, the decision of Product Management could be
overruled by Product Leadership and then eventually the President of DEFENDANT
1
This pressure resulted in a three competitor rule: That DEFENDANT CORPORATION
would match a loan program once three other lenders were offering it (D. 37). V.L. is uncertain
of the date this rule came into effect and agreed that as early as 2002 it was possible that DEFENDANT
CORPORATION might match a program offered by only one other competitor (D. 32, 37).

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CORPORATION, D.S. Also, the type of loans that could be offered was limited by what the
secondary market was willing to buy or what DEFENDANT CORPORATION was willing to
retain for investment purposes. As a consequence, these two litigation issues merge and overlap.
V.L. described his role at DEFENDANT CORPORATION as consisting of market surveillance,
project management/facilitation, and software programming. He also seems to have had an
advisory/advocacy function but he is highly resistant to this suggestion throughout the
deposition.

Market Surveillance

V.L. views his market surveillance function as that of a neutral fact finder and not a decision
maker. The deponent’s word-selection in his discussion of his professional responsibilities belie
this facilitative assertion and instead indicate an executive capacity as an advisor or advocate in
the promotion of new loan products or aggressive alterations to existing ones.

Throughout his testimony, V.L.’s incongruent use of language brings his assertion of non-
advocacy at DEFENDANT CORPORATION into question. He claims to be “laying out the
facts”, but then describes a more stringent loan product alteration as “not unreasonable” (D. 172-
173) (clearly a value judgment). V.L. maintains this semantic dissonance between making
subjective evaluations of product changes while claiming the occupational identity as neutral
reporter throughout his testimony: “Take what the field was saying in regards to sub-prime and
validate it” (D. 95). “I would characterize our function as stating the facts. Here’s what we-
here’s what we are here’s what production wants. How do we take what production wants and
show what the facts are ….” (D. 99). Of course the facts of the market were always presented
subject to a "paradigm of being competitive with the market place” (D. 99). “The competitors
either expanded or contracted. And Credit would say we’re having performance issues we need
to contract. That would come down to us and then we would run through our process” (D. 105).

A productive line of questioning of V.L. might involve the teasing out of this
advocate/activist/advisory capacity using the V.L. hot documents discovered by Plaintiffs’
Counsel as well as how his training and experience in sales might compromise his neutrality in
market surveillance and loan product development. Lastly, V.L. claims that there was no covert
market surveillance of competitors, merely a “deep understanding of their underwriting details”
(D. 29). However, the author of this Memorandum recollects emails found during Plaintiffs’
Discovery that indicate that the employees of competing mortgage banks were providing,
presumably confidential and proprietary, underwriting information or “color” to DEFENDANT
CORPORATION personnel to curry favor and perhaps future employment.

Project Management/Software Programmer

This is the area that V.L. has the most potential for useful information because it details the
conflict between the interests or risk management as represented by Product Management and
profit maximization as advocated by V.L. and Product Leadership. Unfortunately it is also the
most complicated, confusing and acronym laden. The SEC asked V.L. to explain the significance
of an internal DEFENDANT CORPORATION Audit, which stated that DEFENDANT
CORPORATION policy allows for the Defendant Corporation Home Loan (“CHL”) Division
Production Officer to override the concerns elevated by the DEFENDANT CORPORATION

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Chief Credit Risk Officer (D. 80). This audit finding was an apparent contradiction of prior
testimony that production development would submit product parameters to the Credit
Secondary Lending Risk department and they would either accept, reject, or offer a counter (D.
34, 80, 81). V.L. contends that what the audit is referring to is an escalation process (an
exception) rather than the product development process (the rule) (D. 81). V.L. was then asked
whether this audit/internal governance document called “Product Development Process as of
June 21, 2005” indicated that prior to this date the Production Officer could override the
decision of the Credit Risk Officer (D. 82). During this part of the deposition, Deponent’s
counsel objects and V.L. states that without the policy referred to by the internal audit document,
he cannot say for certain (D. 83). However V.L., when further questioned, did not dispute the
correctness of the internal audit document and its description of a pre June 21, 2005
DEFENDANT CORPORATION policy allowing the Chief Production Officer to veto the
concerns of the Chief Credit Officer (D. 84). The Deponent said this policy was further
refined to allow the President of the company to be a tiebreaker (D.210). In March 2007 this
would have been D.S. Lastly, V.L. claims there was no automatic mirroring of competitor’s
underwriting standards but a selective adoption of the rival loan program if it made sense from a
DEFENDANT CORPORATION business perspective (D. 37). This process eventually lead to a
three lender rule which meant that three major lenders in the market had to be offering the same
program or better to motivate a new loan program offering or an alteration of an existing one to
match. According to V.L. this took place early to mid 2006 (D. 37, 38).

Accounting: Risk Models

Risk modeling was done by the Product Management Group (also called the Credit Risk Group
by V.L.), which received product change requests from V.L.’s Product Leadership Group (D.
23). Product Management would then analyze those change requests in terms of past
performance, comparison with existing portfolio products and theoretically made the final
decision if a particular change would be placed in a particular loan guideline. The credit risk
concerns expressed by Product Management would trump the decision of Product Leadership.
(D. 23, 24). V.L. may have contradicted this statement later in the deposition but there is
confusion whether it is an exception or a request for an exception called an “escalation” (D. 209,
210).

Liquidity & Capital

Besides knowing that there were growing concerns (within DEFENDANT CORPORATION,
the industry, and the market) about the viability of sub-prime mortgage loan products, there is
little that V.L. can add about the liquidity issues and capital concerns in DEFENDANT
CORPORATION. Since his position at DEFENDANT CORPORATION was essentially
concerned with marketing, promotion, and sales of the new residential mortgage products, his
focus was externally oriented and his interaction with Product Management and the credit risk
professionals was limited to submitting initiatives, variances, and exceptions for the loans his
department, Product Leadership, wanted to offer at what price and under what restrictions (D.
23).

Loan Products

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Pay Option Arms (“POA”): V.L. stated that DEFENDANT CORPORATION did not adopt the
same underwriting standard on the Payment Option Loan that Bear Stearns was using on a
competing Payment Advantage Loan that would increase profitability at the borrower’s expense:
“There was tremendous pressure from the field to match the Bear product and we didn’t. So we
kept to our product that was more restrictive than the Bear Stearns product” (D. 158). Even an
incriminating sounding POA term of art elicited an unexceptional explanation by V.L.:
“Payment Shock is what happens to a loan when it adjusts” (D. 162). V.L. indicates that
HSBC’s large scale rejection and return of sub-prime mortgages to DEFENDANT
CORPORATION, combined with the tightening of sub-prime credit in the secondary market,
created concern for the sub-prime seconds originated by DEFENDANT CORPORATION. He
also states that although he has no specific recollection, it was possible that A.M. (“A.M.”)
wanted to sell the POAs in the DEFENDANT CORPORATION held for investment (“HFI”)
portfolio (D. 165, 166). V.L. also testified that between late 2006-early 2007, during the time of
the requirement to repurchase and reassume the sub-prime loans sold by DEFENDANT
CORPORATION to HSBC, D.S. was aware of the mounting problems with sub-prime loans as
he was routinely being emailed market updates and reactions to changes in the sub-prime market
(D. 170, 171).

Loan Products: Appraisal: The concept of appraisal and appraisal shopping, particularly by
Landsafe (a subsidiary of DEFENDANT CORPORATION) is of particular interest and
importance to the Plaintiffs’ Case. Once again V.L.’s testimony appears to be of limited value.
During the deposition Value Grid, an appraisal platform, is discussed. Although V.L. does not
think that DEFENDANT CORPORATION actually adopted Value Grid as an appraisal
mechanism, the May 2005 email discussion between V.L. and J.M. is instructive in general of
DEFENDANT CORPORATION’s curative approach to approving sub-prime loans (D. 121).
V.L. has a plausible if incomplete explanation as to Value Grid’s superior efficacy and probity as
an appraisal system. First it is more accurate and does not have the lag time in house market
prices and could not be used to manipulate an artificially higher house value “bumped
up”(D.122, 123). Also, although Landsafe would be in charge of the decision to request an
additional appraisal, the actual work would be done by a third party (D. 125). V.L. states that
since the Value Grid is a more accurate valuation device, it cannot be used by an unscrupulous
loan officer to take advantage or “arb” DEFENDANT CORPORATION (D. 124). V.L. then
cites the superior quality of Value Grid and employs circular logic to assert that the concern in
J.M.’s email over appraisal bumps is proof that there was no need for concern (D. 126). The
SEC did not explore the possibility of any other discretionary appraisal protocols or policies,
which would have led to more relevant disclosures. In addition, it did not contemplate the
consequence of a discretionary upgrade (even to a more accurate and stringent appraisal system)
that could have a long shot pay-off. To apply game theory, a borrower or loan officer has nothing
to lose by taking an alternative appraisal chance when presented with a clearly nonviable loan.

Loan Products: Loosening of Standards & Exception Loans: V.L.’s job description at
DEFENDANT CORPORATION did not entail the making of individual loans. However,
through his interaction and the interaction between Product Leadership and Product
Management, the policies and protocols determining what kind of individual sub-prime loans
could be offered was determined. V.L. was also privy to concerns and complaints from those
seeking exceptions to individual loans or asking for general loan policy alterations for
DEFENDANT CORPORATION to match its competitors (There were also requests from

6
DEFENDANT CORPORATION internal loan divisions to be consistent with one another in the
types of loans offered).

V.L.’s testimony concerning exception loans has the effect of clarifying nomenclature while
leaving the underlying concepts uncertain. He does not clearly explain the demarcation between
exception to policy and policy change. Also V.L. blurs the distinction between policy, project
management, and the updating of programming. This may be the result of an inadvertent lack of
clarity, the context heavy nature of business communication, or an attempt to distance himself
from the acts in question. A subsequent deposition might benefit from having V.L. fill in a blank
policy flow chart with a name, responsibility, date, and function. However, it is clear an
exception is needed when there is a problem or deficiency on the part of the loan structure,
borrower, or property, but an exception to a loan could become the new guideline “if it fits that
criteria” (D. 197-200). In addition, the layering of exceptions, the aggregation or bundling of
different deficiencies in a single mortgage loan, was prohibited at divisional level by the
February 2006 80/20 Exception Policy Summary and required Structured Lending Desk (“SLD”)
approval (D. 111). V.L.’s testimony, although indecisive and conflicted, seems to indicate that
prior to this date it was allowable to layer exceptions at the divisional level (D. 112).

Also, according to V.L., there was sometimes a lag between the decision to make guidelines
more or less restrictive and the actual upgrade of the underwriting software to reflect this. For
instances where the guidelines were loosened, it was allowable to use the exceptions process to
approve loans which would no be approved with the software at the time, but would be approved
under the new guidelines (D. 91, 92).

It should be noted that V.L. claimed that in 2007 DEFENDANT CORPORATION attempted to
loosen its credit restrictions on loan products yet again because it had over-tightened them in
relation to the competition (D. 197).

Prime/Sub-prime Distinction:

In providing the distinguishing characteristics between prime and sub-prime mortgages, V.L.’s
testimony is, once again, equivocal in terms of our theory of the case. V.L. stated that email
header or loan program code was the only way to identify a sub-prime loan at DEFENDANT
CORPORATION (D. 184). He also maintained that there were no institutionalized or definitive
rules that defined a prime/sub-prime product at DEFENDANT CORPORATION or in the
mortgage loan industry (D. 183-185). Instead there were a constellation of factors that seemed to
have variable “situation dependent” weights. Some of these sub-prime factors were borrower
dependent: Fair Issac Credit Organization (“FICO”) score, income statement, bankruptcy
allowances, and payment delinquencies (D. 184). Others were based on the type, size, location
of property and type of appraisal (D. 184). Loan structure such as Loan To Value (“LTV”) and
Combined Loan To Value (“CLTV”) and competitor behavior also played a role (D. 184, 185).
However, V.L. also states that no agency, including the government sponsored entities (“GSE”),
had a hard FICO cut-off score in their definition of sub-prime mortgage products (D. 184, 185).
But when asked the meaning of the “big four”, V.L. defined them as LTV, CLTV, FICO score
and loan amount (D. 186).

CONCLUSION AND TOPICS FOR FURTHER DEVELOPMENT

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As stated at the beginning of this memorandum, V.L. is a witness of
indeterminate value. Despite his lengthy tenure at DEFENDANT
CORPORATION and his senior position in a critical area of litigative interest,
V.L. seems to possess only general institutional background and some minor
culture change information (albeit later and of less use) of DEFENDANT
CORPORATION. On almost every litigative issue of interest, the testimony
of V.L., far from dispositive, is vague, technical, fragmentary, and uncertain.
His basic premise (as exemplified in his responses from the 2006 HSBC
rejection of the 80/20 Piggy Back Loans, basically a zero money down
purchase option (D. 101-104), to the 2006 Asset Securitization Forum
(“ASF”) Conference that was concerned with the same loans but blamed the
rating agencies and “layered risk” (D. 116-117) was that there was a
general acceptance that the sub-prime market was in distress but no specific
knowledge that DEFENDANT CORPORATION was at risk. Based upon the
SEC transcript alone, and if V.L.’s testimony is taken at face value, there
appears to be little reason for an additional deposition of V.L. This
statement is subject to certain procedural and substantive caveats,
qualifications and suggestions.2

Expert Consultation:

The appropriate subject matter experts in mortgage finance, financial

software and project management/Six-Sigma should be retained to review
the SEC transcript of Deponent V.L. The testimony of this deponent is
exceedingly complicated and technical. Experts will be better able to tell
whether V.L.’s use of technocratic language and IT idiom is an accurate
depiction of events or an attempt to obfuscate and distance himself from the
issues of litigative interest.

Culture Change:

This section is arguably the most helpful to our case. While deponent’s
testimony is strong on Kipling’s “what” and “how”, it is correspondingly weak
on the “who” and “when.” V.L. presents a respectable narrative of
DEFENDANT CORPORATION’s aggressive expansion into the sub-prime
market and the mechanics by which it was accomplished. But when it comes
to the dates of these events and their authors, he is vague and uncertain
thereby removing much of the value of his corporate cultural narrative. If
V.L. is deposed again, he should be made to commit to timelines and
2
While the positivist function of depositions focuses on the expansion, enhancement
and reinforcement of statements beneficial to the theory of the case, V.L.’s comments are
ambivalent and equivocal which require that testimonial gaps be probed, inconsistencies
explored and contradictions examined.

8
principals by discrete, specific, date/issue bracketed emails (taken from SEC
exhibits and Plaintiff’s Firm discovery). Using this issue/date/actor
combination will prevent V.L. from qualifying his way out of definitive and
damaging admissions through uncertainty or vagueness. Lastly, on several
occasions V.L. contradicts himself, inconsistently restates previous
testimony or gives incomplete answers as documented by this
memorandum. The SEC did not adequately examine these inconsistencies.
Plaintiff’s Firm could use the incomplete SEC deposition as a chart to fill in
the remaining litigative gaps of V.L.’s testimony in respect to his true role at
the company and those dates when the events of interest actually took
place.

Appraisal:

The SEC gives surprisingly short shrift to the issue of appraisal (D. 121-126). It barely examines
the role of Landsafe in discretionary, alternative appraisals and devotes the majority of the time
to discussing an appraisal platform, Value Grid that may have never been used at DEFENDANT
CORPORATION. The appropriate deposition tactic should be to ask deponent about all
appraisal systems at use at DEFENDANT CORPORATION, how they worked, when they were
used and who the responsible decision makers were. Also the full role of Landsafe in all
appraisals should be fleshed out in terms of dates, policy, and the names of the policy makers.

Lowering of Loan Guidelines & Exception Loans (Layering of Risk & Exceptions):

There is a purposeful vagueness when V.L. discusses Loan Product

Guidelines, exceptions to these guidelines, and when the exceptions become
part of the guidelines and loan product development. It is also uncertain if
V.L. stated that the Chief of Product Leadership could systematically
override the decision/reservation of the Chief of Credit Risk or had to make a
“case by case” appeal or “escalate” to the next highest decision maker. The
nature of this statement needs to be fleshed out because an administrative
appeal is much less helpful to our theory of the case than a super veto in
favor of issuing a sub-prime loan or lowering the requirements to qualify for
one. Also, the possibility that prior to February 2006 the Layering of
Exceptions at the Division level was allowable should be explored and V.L.
should be asked to define the concept of Layering of Risk mentioned at the
ASF conference and ask how it relates to the Layering of Exceptions.

J.M.:

Throughout V.L.’s deposition, J.M proved to be an excellent stalking horse for issues of
litigative interest as well as an honest broker with good credibility and a genuine concern about
the risks DEFENDANT CORPORATION was taking in the realm of sub-prime lending (D. 98,
120-124, 148, 149, 208-210). In addition to being interviewed in his own right, McMurray
should be a reference point in any subsequent interview with V.L. Disputes or disagreements

9
between V.L. and J.M. or J.M. and other DEFENDANT CORPORATION personnel
concerning sub-prime loans or other relevant issues that deponent is aware of could be a “target
rich” environment” in terms of deposition.

Thematic bullet: “This is a potential goldmine”(D. 156):

This is a reference to a 100% LTV, no Mortgage Insurance required Community Reinvestment

Act sponsored program with a 620 FICO minimum that V.L. says gets DEFENDANT
CORPORATION much better pricing or “From the pricing we are seeing (will verify with the
bank) this is a potential gold mine” (D. 156). This quote is in reference to a sub-prime loan
designed to give poor to moderate income borrowers a chance at the “American Dream” of home
ownership. In all likelihood this statement, regardless of context, would have a very powerful
effect on a jury.

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