All persons and entities who, directly or through an agent, entered into stock loan transactions with Bank of America, Goldman Sachs, Morgan Stanley, Credit Suisse, JP Morgan, or UBS in the United States from January 7, 2009 through the present (the Class Period).  Excluded from the Class are Defendants, their employees, parents, subsidiaries, and coconspirators, whether or not named in this Complaint.

Bank of America, Goldman Sachs, Morgan Stanley, Credit Suisse, JP Morgan, or UBS stock loan transactions.

The complaint alleges that  in order to protect their profits, the Prime Broker Defendants,  have been conspiring since at least 2009 through a company called EquiLend, which they control, to prevent participants from accessing marketplaces where they could benefit from direct, all-to-all trading and thereby secure themselves the best prices. (All-to-all trading means that stock lenders can offer a stock to every other stock borrower in the market and select the best price.) Denying others this level of access forces trades in the market to go through their prime brokers, which is how the banks are able to reap tremendous financial benefit. In 2016, for example, these six institutions skimmed approximately 60 percent of the $9.15 billion in stock lending revenue alone, despite performing a service for which they bear virtually no risk. Any other arrangement would have substantially reduced the need for their services, and the premiums that they charge would have been untenable.

Class action on behalf of all persons and entities who from January 7, 2009, through the present (8/16/17) entered into stock loan transactions with Bank of America, Goldman Sachs, Morgan Stanley, Credit Suisse, JP Morgan, or UBS in the United States.