--- title: "Citigroup and J.P. Morgan Chase: prepays, structured finance and settlements" language: en canonical: https://dossiertwist.com/dossiers/enron/citigroup-jpmorgan-structured-finance/ as_of: 2026-10-14 keywords: ["Enron Corp.","Andrew Fastow","Kenneth Lay","Jeffrey Skilling","Richard Causey","LJM2 Co-Investment","Chewco","Raptors","special purpose entities","prepay transactions","Arthur Andersen","J.P. Morgan Chase","Citigroup","Merrill Lynch","CIBC","Powers Committee","bankruptcy examiner","Enron Task Force","California energy crisis","Newby class action"] --- # Citigroup and J.P. Morgan Chase: prepays, structured finance and settlements **Question.** What did Citigroup and J.P. Morgan Chase do for Enron, what did investigators find and how were the official proceedings against the two banks resolved? **Answer.** Citigroup and J.P. Morgan Chase & Co. financed Enron through prepay transactions, many of them run through special purpose entities the banks had caused to be formed (Mahonia for Chase, Delta for Citigroup), which according to the bankruptcy examiner let Enron report what were in substance loans as operating cash flow and price risk management liabilities. A December 2002 staff report of the Senate Permanent Subcommittee on Investigations found that both banks actively aided Enron in four structured finance transactions of December 2000 to June 2001, and the examiner concluded that a fact-finder could find that each bank aided and abetted Enron officers’ breaches of fiduciary duty; these are investigative conclusions, not court judgments. On July 28, 2003 both banks settled SEC proceedings without admitting or denying the allegations, J.P. Morgan Chase paying $135 million and Citigroup $120 million, and entered into agreements with the New York County District Attorney’s Office and written agreements with the Federal Reserve Bank of New York. J.P. Morgan and Salomon Smith Barney committed to Enron’s November 2001 secured credit lines, and Citigroup and J.P. Morgan Chase arranged its debtor-in-possession financing after the bankruptcy filing. ## The banks’ Enron relationships and the examiner’s overall conclusion - Analysis: In his third interim report of June 30, 2003, the court-appointed bankruptcy examiner Neal Batson reported on six financial institutions with the most significant involvement in Enron’s special purpose entity (SPE) transactions and the largest claims against the estates. They were, ordered by apparent claim size, Citigroup, JPMorgan Chase, Barclays, BT/Deutsche (Deutsche Bank AG), CIBC and Merrill Lynch; three other institutions and two accounting firms were left to the separate examiner in the Enron North America case. Batson concluded that a fact-finder could find that certain of the six knew of Enron officers’ wrongful conduct, gave substantial assistance and aided and abetted breaches of fiduciary duty. That is an examiner’s conclusion about what a fact-finder could find, not a court judgment. He noted that, because Enron’s officers participated in the wrongful conduct, the institutions may assert either that Enron lacks standing to bring such claims or that the doctrine of in pari delicto defeats them. [src-067] - Analysis: The examiner’s third interim report, an account drawn from bank and Enron records and testimony rather than a court finding, states that Enron regarded Citigroup as a Tier 1 bank for at least the five years before the petition date. In that period Citigroup completed more than sixty transactions with Enron as lender, arranger, syndicator, underwriter, financial adviser and investor and received approximately $188 million in revenue from Enron transactions in 1997–2001; in the Yosemite I–IV prepays, Citigroup’s SPE Delta served as conduit for funds, raised through private placements of credit-linked notes, that ultimately totaled approximately $2.4 billion lent to Enron. Enron consistently held, until the bankruptcy, JPMorgan Chase’s highest-priority “Blue” client status, reserved for accounts that could generate $5 million or more in deal revenues over an eighteen-month period. By 1999 Enron was the most significant corporate finance relationship of the bank’s Global Oil and Gas Group, generating annual fees of more than $15 million and total revenues of $17 million; relationship revenues in 2000 totaled $29.8 million. [src-067] ## Prepays through Mahonia and Delta - Analysis: The examiner reported that Andersen required a substantive third party in Enron’s prepay transactions and that in the SPE prepays this party was created by a bank: JPMorgan Chase caused Mahonia to be formed for the Mahonia prepays, and Citigroup caused Delta to be formed for the Yosemite prepays and the June 2001 Citigroup prepay. He found that both were SPEs, owned by charitable trusts, with no employees or operations and minimal assets; Delta, owned by a Cayman Islands charitable trust and set up at Citigroup’s direction, served as conduit or swap counterparty in six Citigroup prepays. According to the examiner, Enron used its prepay transactions to record a total of $4 billion of borrowings as price risk management liabilities rather than debt and to increase operating cash flow by $1.5 billion in its 2000 financial statements, while its Financial Accounting Standards (FAS) 140 transactions produced more than $350 million of reported net income and more than $1.15 billion of reported cash flow in 2000 and masked more than $1.3 billion of repayment obligations. He concluded that Enron’s disclosure of these transactions was materially misleading. These are examiner’s conclusions that a fact-finder could so find, not court judgments. [src-067] - Analysis: A table compiled from bank documents by the Senate Permanent Subcommittee on Investigations in July 2002 listed twelve prepay transactions between Enron and Chase from December 1992 to September 2001 totaling $3,717.9 million (Chase’s commitment $3,552.9 million), of which $1,564.7 million was outstanding at the bankruptcy, and prepay and credit-linked note transactions with Citigroup from 1994 to June 2001 totaling $4,927.4 million (Citigroup’s commitment $1,745.0 million), with $2,621.0 million outstanding; the combined total was $8,645.3 million, of which $4,185.7 million was outstanding. The table notes that Chase reported a different amount for one transaction. According to the examiner, the nine prepay transactions that Citigroup completed with Enron between 1997 and 2001 totaled more than $4.6 billion gross, some refinancing earlier ones, as the $675 million Jethro prepay did the $500 million Truman prepay. He concluded that a fact-finder could find that Citigroup knew that Enron transferred no commodities or price risk, that the transactions were effectively debt, and that Enron reported them as operating cash flow without footnote or management’s discussion and analysis (MD&A) disclosure; the prepays represented 76% of Enron’s net reported operating cash flow in 1999. [src-023] [src-067] - Analysis: In Citigroup’s Yosemite I and II prepays, funded by Enron credit-linked notes, the examiner found that the equity certificate holders of the note-issuing SPEs had entered into total return swaps, so the SPEs lacked independent 3% equity at risk and should have been consolidated with Enron; by not doing so Enron failed to report an additional $1.1 billion of debt, and the evidence suggested the swaps were not disclosed to Andersen. A senior Citigroup accountant had concluded that Enron should consolidate the note issuer, but Citigroup proceeded, describing the issue as “the customer’s risk to accept or reject”. This too is the examiner’s conclusion of what a fact-finder could find, not a court judgment. [src-067] ## Year-end 1999 and Nahanni - Analysis: The examiner’s account, based on bank and Enron records and testimony, is that in the last two weeks of 1999 Enron closed at least eleven transactions that together generated $114 million of reported net income and more than $1.2 billion of operating cash flow while keeping the repayment obligations off the balance sheet or outside reported debt. His timeline named the counterparties, including Citigroup (the Nixon prepay and Nahanni), CIBC (three FAS 140 transactions), Merrill Lynch (the Nigerian barge and the 1999 electricity trades), Royal Bank of Canada, Bear Stearns, West LB and the related parties Whitewing and LJM2. In Nahanni, a minority interest transaction completed in December 1999, the minority investor contributed $500 million of Treasury securities to an Enron subsidiary; Enron sold them, reported the proceeds as operating cash flow and repaid the debt in mid-January 2000. The examiner concluded that a fact-finder could find that Citigroup designed the structure and recommended the use of Treasury securities, that the transaction had no rational business purpose and represented 41% of Enron’s reported 1999 operating cash flow, and that Citigroup itself acknowledged Enron had used Nahanni “only for year-end window dressing”. In its settled order of July 28, 2003 the SEC found that in Project Nahanni Citigroup knowingly helped Enron generate operating cash flow by selling Treasury bills bought with the proceeds of a loan; Citigroup consented without admitting or denying the findings. [src-067] [src-025] ## Fishtail and Bacchus: the Senate Subcommittee’s account - Analysis: A staff report of the U.S. Senate Permanent Subcommittee on Investigations dated December 11, 2002 examined four structured finance transactions, Fishtail, Bacchus, Sundance and Slapshot, that Enron carried out between December 2000 and June 2001 in connection with its pulp and paper trading venture; all four were financed primarily by Citigroup’s Salomon Smith Barney unit or by JPMorgan Chase & Co. The Subcommittee concluded that both banks actively aided Enron despite knowing that the transactions used deceptive accounting or tax strategies, in return for substantial fees and favorable consideration in other business. It characterized Fishtail, Bacchus and Sundance, taken together, as a disguised six-month loan from Citigroup: Enron moved its pulp and paper trading assets into a sham joint venture (Fishtail); a shell entity in Bacchus borrowed $200 million from Citigroup to “purchase” Enron’s Fishtail interest without disclosure that Enron guaranteed the full price; Enron used the sale to add $112 million to its year-end 2000 earnings; and the $200 million was quietly returned to Citigroup six months later through Sundance. These are congressional staff findings, not judicial determinations. In its settled order of July 28, 2003 the SEC found that Project Bacchus was in substance a $200 million financing from Citigroup because Citigroup was not at risk for its equity investment; Citigroup consented without admitting or denying the findings. [src-011] [src-025] - Analysis: According to the Subcommittee, Enron, LJM2 Co-Investment, L.P. and JPMorgan Chase took part in the Fishtail joint venture formed on December 19, 2000. LJM2, through an affiliate, formed the SPE Annapurna LLC; Enron, acting through Enron North America, and Annapurna each held 50 percent of Fishtail’s voting shares, so the venture was not consolidated. The Subcommittee called Fishtail a sham joint venture that should have been consolidated, a congressional staff finding rather than a judicial determination; Chase’s $42 million commitment was never funded, yet Chase was paid $500,000 in fees. Enron and Chase contended that the $115 million value assigned to Enron’s soft assets in Fishtail was the product of an unbiased third-party analysis; the Subcommittee said it came from a Chase affiliate supporting Enron’s own assessment. [src-011] - Analysis: On or about December 26, 2000, in a transaction Enron called Bacchus, Enron “sold” its Class C interest in Fishtail for $200 million to the Caymus Trust, a Delaware business trust Enron had established. The trust was capitalized with a $194 million loan from Citigroup and a $6 million equity “investment” from FleetBoston Financial. According to the Subcommittee’s account, based on bank and Enron documents and interviews, the risk on FleetBoston’s $6 million had been passed to Citigroup through a total return swap, and Enron in turn gave Citigroup a total return swap supporting the $194 million loan. The Subcommittee found that Enron, although accounting standards barred it from doing so, also guaranteed the $6 million equity through an undisclosed oral agreement with Citigroup. Citigroup’s credit approval memorandum stated that the equity component would be “based on verbal support as committed by Andrew S. Fastow”. A senior Citigroup official told the Subcommittee that before closing he met Fastow in Houston to obtain Enron’s “verbal support” and that Fastow assured him Enron would take “whatever steps necessary” to ensure Citigroup suffered no loss on the $6 million; the same official denied to Subcommittee staff that Enron had verbally guaranteed the equity investment. This account is not a judicial determination. [src-011] - Analysis: Citigroup’s internal documents, as quoted by the Subcommittee, showed that it took part in Bacchus partly as an accommodation to Enron. A November 2000 email called the transaction “mission critical” for Enron at year-end and a “must” for Citigroup; another, a week after closing, noted that Citigroup had made “a lot of exceptions to our standard policies” and urged colleagues to “collect this iou when it really counts”; a later email warned that Enron generated substantial revenue for Citigroup’s GCIB unit ($50 million in 2000). The Subcommittee calculated that the $112 million Bacchus gain represented more than 11 percent of Enron’s total net income for 2000 and the $200 million about 6 percent of its cash flow from operations, suggesting that Enron would otherwise likely have missed Wall Street’s earnings projections. Citigroup was paid a $500,000 fee for Bacchus, earned $5 million in interest on the $200 million debt and obtained a further $450,000 yield on the $6 million “equity investment”. Citigroup told the Subcommittee that its personnel had been unaware that Bacchus would generate material earnings for Enron and denied knowing at the time that Enron had recorded them, although its personnel agreed that the $112 million finally reported was material. The Subcommittee’s conclusions are congressional staff findings, not judicial determinations. [src-011] - Analysis: The bankruptcy examiner’s third interim report also addressed Bacchus. He found that Enron effectively borrowed $200 million from Citigroup over the 2000 year-end, recognizing a $112 million gain and $200 million of operating cash flow. Citigroup obtained a total return swap from Enron covering $194 million of the debt and verbal support from Andrew Fastow that Enron would repay the remaining $6 million, which was meant to represent the required 3% independent equity. Andersen testified that it was unaware of any such verbal support and that it would have invalidated Enron’s accounting. The finding is the examiner’s conclusion that a fact-finder could so find, not a court judgment. [src-067] ## Sundance and Slapshot - Analysis: Sundance Industrial Partners, formed about six months after Bacchus to hold Enron’s pulp and paper assets off balance sheet, was structured as a 50-50 joint venture between Enron and Citigroup capitalized at a 4:1 ratio under Arthur Andersen’s joint-venture guidelines. Enron contributed about $750 million; Citigroup appeared to contribute $8.5 million in cash, shares valued at $20 million and a $160 million unfunded commitment. The Subcommittee found, as a congressional staff finding rather than a judicial determination, that Sundance gave only the appearance of a second investor and should have been consolidated; Enron’s $208 million cash contribution was used to buy back the Fishtail interests, and the Caymus Trust used the proceeds to repay Citigroup’s $194 million loan. Citigroup was unable to tell the Subcommittee who gave final approval of Sundance or to locate the signed approvals its policy required, and the head of risk management for its investment bank said he could recall virtually nothing about his objections to the transaction. [src-011] - Analysis: When questions arose about Enron’s solvency, Citigroup invoked Sundance’s protective provisions and terminated the partnership on or about November 30, 2001, two days before Enron filed for bankruptcy. It required Enron to buy out its interest for the $28.5 million it had contributed in cash and stock, recovered that amount plus a return, and ended its $160 million funding commitment. The Subcommittee reported that Citigroup received $725,000 in upfront fees and a $1.1 million return on Sundance, plus $1.5 million in “breakage costs” when Sundance funded early repayment of the $194 million Bacchus loan. The examiner found that Enron used Sundance Industrial to move all its forest products assets into a nonconsolidated partnership, and that Citigroup knew its $28.5 million, 3% equity investment had to be at risk for that purpose but structured it with so many protections that it was actually debt; Citigroup also believed its obligation to fund up to a further $160 million was not at risk, since the documents were “hardwired” to require the partnership to lose almost $750 million before drawing on it. He also found that Citigroup used $20 million of its investment to buy an interest in an Enron SPE, Sonoma, enabling Enron to record $20 million of income. The staff report and the examiner’s conclusions are not judicial determinations. [src-011] [src-067] - Analysis: The Subcommittee described Slapshot, completed on June 22, 2001, as a sham $1 billion loan structure that Chase designed and presented to Enron to produce up to $60 million in Canadian tax benefits and up to $65 million in financial-statement benefits. Chase set up Flagstaff Capital Corporation as a wholly owned Delaware SPE and organized a consortium of itself, the Royal Bank of Scotland, the Industrial Bank of Japan and the Bank of Tokyo-Mitsubishi, each providing an equal share of a $375 million loan to refinance the Stadacona paper mill in Quebec, which Enron had bought in March 2001 for about $350 million and owned through Compagnie Papier Stadacona, a Nova Scotia unlimited liability company. Chase advanced the loan to Flagstaff on June 22, 2001. In the Subcommittee’s account the legitimate $375 million loan was cloaked inside a $1.4 billion sham loan from the Chase-controlled SPE, funded by a $1 billion Chase “daylight overdraft”; Enron funded the required $1 billion escrow through a separate daylight overdraft from Citigroup and entered into derivatives with Flagstaff that in essence guaranteed repayment. Chase received fees and other remuneration totaling $5.6 million. In an interview Enron contended that one business purpose was that the Chase and Enron affiliates profited from the loans they exchanged; the Subcommittee, whose findings are not judicial determinations, answered that the interest rates differed by only 0.01 percent between Enron affiliates. [src-011] ## The examiner’s conclusions on Citigroup and JPMorgan Chase - Analysis: The examiner found that in substantially all of Enron’s FAS 140 transactions, and in other SPE transactions such as J.T. Holdings, Andrew Fastow and Ben Glisan gave the banks verbal assurances, recorded in the banks’ own files, that Enron would repay the face amount and yield of the required 3% outside equity regardless of the value of the SPE’s assets. He identified such assurances in substantially all of the FAS 140 transactions with CIBC, in Bacchus with Citigroup and in Nikita with Barclays, found that they violated the 3% equity test of generally accepted accounting principles (GAAP), and said the evidence suggested they were not disclosed to Andersen. Witnesses from the financial institutions and from Enron testified that the assurances were not intended to and did not constitute enforceable agreements, and certain institutions maintained that their 3% equity was therefore at risk; the examiner found this testimony inconsistent with much of the documentary evidence and noted denials by certain bank witnesses. His findings are conclusions that a fact-finder could so find, not court judgments. [src-067] - Analysis: The examiner concluded that in many of Enron’s SPE transactions Citigroup appeared to have violated or ignored its own “appropriateness” guidelines for structured finance, and that there was sufficient evidence for a fact-finder to conclude that Citigroup had actual knowledge of Enron officers’ wrongful conduct, gave them substantial assistance and aided and abetted their breaches of fiduciary duty. He also found sufficient evidence of inequitable conduct for Citigroup’s claims of approximately $2.4 billion to be equitably subordinated to those of other creditors. These are conclusions about what a fact-finder could find, not a court judgment. Citigroup employees testified that groups other than its Global Capital Structuring group considered similar matters when deciding whether to engage in transactions. Citigroup agreed on June 10, 2005 to pay $2 billion to settle the Newby securities class action, a settlement the court approved in May 2006 together with those of CIBC and JPMorgan Chase, according to lead plaintiffs’ counsel and press reports summarized by a class-action case database. Citigroup declined in August 2005 to comment on Enron’s MegaClaims suit, according to a press report summarized by the same database, and it remained a defendant in that suit in October 2006, according to a press report. [src-067] [src-056] [src-036] [src-105] - Analysis: The examiner found that JPMorgan Chase created the Mahonia structure and sold Enron $3.717 billion of prepay transactions from December 1992 through September 2001, knowing that they were in substance loans that Enron reported as price risk management liabilities and operating cash flow without adequate disclosure, and that there was evidence it helped Enron make misleading representations to Andersen about Mahonia’s independence. He concluded that a fact-finder could find that JPMorgan Chase aided and abetted Enron officers’ breaches of fiduciary duty and that its claims of $1.8 billion could be equitably subordinated; this is an examiner’s conclusion, not a court judgment. J.P. Morgan Chase consented to the SEC’s July 2003 final judgment over its Enron prepay transactions without admitting or denying the SEC’s allegations. In June 2005 JPMorgan Chase said it would pay $2.2 billion to settle the Newby class action’s allegations, a settlement approved in May 2006, and in August 2005 it agreed to pay Enron $350 million and effectively waived some of its claims to settle the MegaClaims suit, according to press reports summarized by a class-action case database and to lead plaintiffs’ counsel. [src-067] [src-025] [src-056] [src-036] ## The July 28, 2003 settlements and written agreements - Analysis: On July 28, 2003 the SEC instituted and settled enforcement proceedings against J.P. Morgan Chase & Co. and Citigroup Inc. over their roles in Enron’s manipulation of its financial statements. J.P. Morgan Chase consented, in a civil injunctive action in federal court in Texas, to a final judgment permanently enjoining it from violating the antifraud provisions and ordering it to pay $135 million in disgorgement, penalty and interest. Citigroup consented to an administrative cease-and-desist order and agreed to pay $120 million, of which $101 million related to Enron and $19 million to Dynegy Inc. Both banks settled without admitting or denying the SEC’s allegations or findings; in settling with Citigroup the SEC took into account its cooperation with the investigation and its timely efforts to resolve the matter. The SEC intended to direct $236 million to Enron fraud victims. It stated that it had brought both actions in coordination with the New York County District Attorney’s Office, which entered into settlement agreements with both banks on the same day. With these two cases the SEC had brought six separate Enron-related actions in the twenty months since the bankruptcy, against three major financial institutions, Enron’s former chief financial officer and eight other former senior executives, and had obtained $324 million for the victims. [src-025] - Analysis: According to the SEC, both banks helped Enron present what were essentially loan proceeds as operating cash flow. J.P. Morgan Chase’s prepays passed commodity price risk from Enron to a Chase-sponsored special purpose vehicle, then to Chase and back to Enron, leaving Enron with fixed repayments of principal and interest; Citigroup’s prepays worked the same way. The Citigroup order also covered Project Nahanni, in which Enron generated operating cash by selling Treasury bills bought with loan proceeds, and Project Bacchus, in substance a $200 million financing because Citigroup was not at risk on its $6 million equity. These are the SEC’s allegations and findings, which the banks neither admitted nor denied; the proceedings were settled the day they were brought, through J.P. Morgan Chase’s $135 million final judgment and Citigroup’s cease-and-desist order and $120 million payment, and the Federal Reserve Bank of New York and other bank regulators entered into written agreements with both banks the same day. [src-025] - Analysis: On July 28, 2003 the Federal Reserve Bank of New York entered into written agreements with J.P. Morgan Chase & Co. (jointly with the New York State Banking Department) and with Citigroup Inc., which also reached a separate agreement with the Office of the Comptroller of the Currency. The agreements followed reviews of the banks’ transactions with Enron in the four years before its bankruptcy, including structured finance transactions with SPEs and prepaid commodity forwards, which raised concerns that the banks had not adequately assessed their goals, purposes, results and risks. Within 60 days each bank had to submit a revised credit risk management program and a legal and reputational risk management program; the agreements are enforceable as orders under section 8 of the Federal Deposit Insurance Act. [src-022] [src-025] [src-024] ## Lending in November and December 2001 and Chase’s later claims - Analysis: On November 1, 2001 Enron announced that J.P. Morgan and Salomon Smith Barney had executed commitment letters to provide $1 billion of secured credit lines supported by the assets of its Northern Natural Gas Company and Transwestern Pipeline Company, according to a Congressional Research Service chronology of Enron-related events. On December 3, 2001, the day after its Chapter 11 filing, Enron announced up to $1.5 billion of debtor-in-possession (DIP) financing arranged by Citigroup and J.P. Morgan Chase, to be syndicated and secured by substantially all of its assets. The DIP credit agreement of December 3, 2001 was amended and restated on June 14, 2002 and again on May 9, 2003; under it JPMorgan Chase Bank (JPMCB) and Citicorp USA, Inc. acted as co-administrative agents, Citicorp as paying agent and JPMCB as collateral agent, with Enron as borrower and its subsidiaries party to it as guarantors. [src-108] [src-048] - Analysis: A May 29, 2007 opinion of the U.S. Bankruptcy Court for the Southern District of New York recorded that in the Choctaw structure Choctaw Investors B.V., controlled by JPMorgan Chase Bank, N.A., and the Choctaw lenders held all preferred interests in Cherokee Finance V.O.F., whose common equity Enron held, and that a Chase-controlled entity, Zephyrus, held the Class C interests in Enron Finance Partners, LLC. Under the May 2004 Choctaw/Zephyrus settlement, Cherokee’s claim against Enron was allowed at $796.5 million and the two Enron Finance Partners claims at $135 million and $280.5 million, all assigned to Chase. In the dispute over the subordination provisions, Chase argued that it need not show the underlying notes had been ‘sold’, reading the TOPRS indentures’ phrase ‘sold for money borrowed’ as qualifying only securities, and maintained that Enron Finance Partners was not an Enron ‘Subsidiary’ under the 1987 indenture. The court held that these claims benefited from the subordination provisions of the 1993 and 1994 loan agreements but not from those of the TOPRS indentures. [src-042] - Analysis: The same opinion recorded that Chase’s letter-of-credit claims against Enron arose in part from a $500 million syndicated Letter of Credit and Reimbursement Agreement of May 14, 2001 among Enron, Chase and other financial institutions, under which beneficiaries drew approximately $373.7 million between November 28, 2001 and May 22, 2002, and from a bilateral agreement of June 16, 1995, under which approximately $61.8 million was drawn between November 30, 2001 and January 31, 2002. Enron had not paid these reimbursement obligations. Chase argued that Enron’s reimbursement obligations were absolute rather than contingent obligations or indirect guarantees, and that the reimbursement agreements were ‘bonds’ qualifying as Senior Indebtedness. On May 29, 2007 the court held that the letter-of-credit reimbursement claims were not Senior Indebtedness and were excluded from the benefit of the subordination provisions of the 1987 and TOPRS indentures. [src-042] ## Sources - [src-067] Court record source · src-067 - [src-023] Appendix E: Summary of Enron "Prepays" with J.P. Morgan Chase and Citigroup, U.S. Senate Permanent Subcommittee on Investigations, 2002-07 - [src-025] SEC Settles Enforcement Proceedings against J.P. Morgan Chase and Citigroup (press release 2003-87), U.S. Securities and Exchange Commission, 2003-07-28 - [src-011] Fishtail, Bacchus, Sundance, and Slapshot: Four Enron Transactions Funded and Facilitated by U.S. Financial Institutions (staff report), U.S. Senate Permanent Subcommittee on Investigations, 2002-12-11 - [src-056] Research source · src-056 - [src-036] Other source · src-036 - [src-105] Media source · src-105 - [src-022] Written Agreement among J.P. Morgan Chase & Co., the Federal Reserve Bank of New York and the New York State Banking Department, Board of Governors of the Federal Reserve System, 2003-07-28 - [src-024] Written Agreement between Citigroup Inc. and the Federal Reserve Bank of New York, Board of Governors of the Federal Reserve System, 2003-07-28 - [src-108] Research source · src-108 - [src-048] Memorandum Opinion and Order Approving Plan of Reorganization under PUHCA (Release No. 35-27810), U.S. Securities and Exchange Commission, 2004-03-09 - [src-042] Memorandum decision, In re Enron Creditors Recovery Corp., No. 01-16034 (AJG), Doc. 31034 (Bankr. S.D.N.Y.), U.S. Bankruptcy Court for the Southern District of New York (via GovInfo), 2007-05-29