EFTA Document EFTA01386110

AGP LP 519 Alpha Group Capital Paul Barrett penalty, and $6.62 million prejudgment interest; and Merrill and BOAMS consented to permanent injunctions against violations of Securities Act §5(b)(1). With respect to the Securities Act §17(a)(2) and (3), the SEC alleged that BANA, BOAMS and Merrill (1) underwrote a prime RMBS ("BOAMS 2008-A") and failed to comply with its representation that each underlying mortgage complied with Respondents' underwriting guidelines; (2) did not disclose the p