On March 16th, the Southern District of New York held that the three-year statute of repose found in the Securities Act of 1933 cannot be equitably tolled. Two hedge funds that purchased mortgage-backed securities from Countrywide alleged that defendants made material misrepresentations and omissions in their offering documents. Granting defendants' motion for summary judgment, the Court held that because plaintiffs filed their claims more than three years after the sale of the securities, their claims were barred by the Securities Act's statute of repose, which is not subject to equitable tolling. Footbridge Ltd. Trust v. Countrywide Financial Corp.