COMPLAINT | National Credit Union Administration Board v. Credit Suisse Group AG

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

NATIONAL CREDIT UNION ADMINISTRATION BOARD, as Liquidating Agent of U.S. Central Federal Credit Union, Western Corporate Federal Credit Union, Members United Corporate Federal Credit Union, Southwest Corporate Federal Credit Union, and Constitution Corporate Federal Credit Union, Plaintiff, v. CREDIT SUISSE GROUP AG; JP MORGAN CHASE & CO.; JPMORGAN CHASE BANK, NATIONAL ASSOCIATION; BARCLAYS BANK PLC; LLOYDS BANKING GROUP PLC; WESTLB AG; WESTDEUTSCHE IMMOBILIENBANK AG; UBS AG; THE ROYAL BANK OF SCOTLAND GROUP PLC; COÖPERATIEVE CENTRALE RAIFFEISEN BOERENFLEENBANK B.A.; THE NORINCHUKIN BANK; THE BANK OF TOKYO-MITSUBISHI UFJ, LTD.; HBOS PLC; SOCIÉTÉ GÉNÉRALE S.A; ROYAL BANK OF CANADA, Defendants.

COMPLAINT

Plaintiff, National Credit Union Administration Board (“NCUA”), brings this action in its capacity as Liquidating Agent of U.S. Central Federal Credit Union (“U.S. Central”), Western Corporate Federal Credit Union (“WesCorp”), Members United Corporate Federal Credit Union (“Members United”), Southwest Corporate Federal Credit Union (“Southwest”), and Constitution Corporate Federal Credit Union (“Constitution”) (collectively the “Credit Unions”) against certain members of the panel of banks that set the London Interbank Offered Rate (“LIBOR” or “Libor”) for the U.S. Dollar. From at least January 2005 through December 31, 2010 (“the Relevant Period”) Defendants conspired to suppress LIBOR in violation of the Sherman Act, 15 U.S.C. § 1 et seq., the Clayton Act, 15 U.S.C. § 12 et seq., and state antitrust laws.

The allegations set forth herein are based on corporate knowledge and documents and information in NCUA’s possession, and upon information and belief developed through investigation by NCUA and by counsel that included a review of publicly available documents, including legal actions brought against Defendants, regulatory and criminal settlements of LIBOR manipulation charges, documents that appear to have been drafted in whole or in part by certain Defendants, Defendants’ press releases and filings with the Securities and Exchange Commission (“SEC”), news articles, scholarly articles, and court documents submitted in LIBOR-related proceedings.

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