UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ALFRED SINGLETON, Individually and On
Behalf of All Others Similarly Situated, ) CIVIL ACTION NO.
Plaintiff i
vs. ; CLASS ACTION COMPLAINT
) FOR VIOLATIONS OF
FEDERAL HOME LOAN MORTGAGE CORP., ) FEDERAL SECURITIES LAWS
DAVID GLENN, LELAND C. BRENDSEL, and >
VAUGHN CLARKE
; JURY TRIAL DEMANDED
Defendants. 1
Plaintiff, Alfred Singleton, ("Plaintiff `) individually and on behalf of all
similarly situated, by his undersigned attorneys, for his complaint against defendants,
following based upon personal knowledge as to himself and his own acts, and information and
as to all other matters, based upon, inter alia, the investigation conducted by and
attorneys, which included, among other things, a review of the defendants' public
conference calls and announcements made by defendants, United States Securities and
Commission ("SEC") filings, wire and press releases published by and regarding Federal Home
Mortgage Corp. ("FreddieMac" or the "Company"), securities analysts' reports and
the Company, and information readily obtainable on the Internet. Plaintiffbelieves
evidentiary support will exist for the allegations set forth herein after a reasonable
discovery.
NATURE OF THE ACTION
1. This is a federal Class Action brought by the Plaintiffon behalfofhimself
consisting of all other persons who purchased the publicly traded securities of Federal
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similarly situated, by his undersigned attorneys, for his complaint against defendants,
wire and press releases published by and regarding Federal Home Loan
Mortgage Corp., securities analysts' reports and advisories about
Mortgage Corp. (NYSE: FRE), between, April 18, 2000 to June 6, 2003 inclusive (the "Class
Defendant Freddie Mac Freddie Mac is a stockholder-owned corporation chartered
Company's Chairman and Chief Executive Officer until he retired on June 9,2003.
operations, management, and the intrinsic value of Freddie Mac securities and caused
Among the questions of law and fact common to the Class
retained portfolio growth,
Net interest income on earning assets totaled $667 million in first quarter 2000, compared to
The average balance of the retained portfolio grew by $5.5 billion, or 2 percent during first
On a fully taxable equivalent (FTE) basis, the net interest yield on earning assets
Management and guarantee fee income totaled $366 million in first quarter 2000, compared to
During first quarter 2000, the average balance of Total PCs increased $9.7 billion, or 1
"Strong total portfolio growth and excellent credit results produced solid earnings this
"Cur total mortgage portfolio surpassed $900 billion during the third quarter.
Additionally, charge-offs declined to less than half of last year's third quarter level while
today announced operating earnings for first quarter 2001 of $719 million, compared to $608
Freddie Mac's operating earnings and operating earnings per share exclude certain accounting
*Net retained portfolio growth of $35 billion, representing 36 percent
Freddie Mac's operating revenues reached $1.247 billion in first
Record new business purchase volume of $126 billion, up 180 percent from $45 billion for
Freddie Mac's total mortgage portfolio grew at a 22 percent annualized rate from $994 billion
Operating revenues include operating net interest income but exclude SFAS 133-related changes
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