On August 1, 2011, Teachers Insurance and Annuity Association of America ("TIAA") filed a complaint against Deutsche Bank and certain of its affiliates for common law fraud, fraudulent inducement, aiding and abetting fraud, and negligent misrepresentation in the Supreme Court of the State of New York.  TIAA alleges that Deutsche Bank made several false representations regarding the quality of the loans contained in the subprime RMBS it securitized and sold to TIAA, despite the fact that members of Deutsche Bank's trading desk allegedly made disparaging internal statements concerning the quality of Deutsche Bank's RMBS and developed a short position against those securities.  According to TIAA, the loans underlying the RMBS were riskier than Deutsche Bank represented in several aspects, including originators' adherence to underwriting guidelines, loan-to-value ratios, credit ratings of the RMBS certificates, and status of title transfer.  Complaint.