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1. Citi’s “Due Diligence” And Early Discovery Of The Risks Of Possible Fraud

61. During the course of Citi’s 2005 initial “due diligence,” and as part of negotiating the final terms of the Prime Fund loan transaction, Citi learned, among other things, that Tremont received only paper copy trade confirmations approximately five (5) days conducted the alleged trading – a practice rife with the possibility for fraud due to the ability of the brokerage firm to backdate or manufacture trading activity with no ability on the customer’s part to check that the trades actually took place.

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