On September 26, 2011, a shareholder derivative complaint was filed against Bank of America ("BAC") directors and officers ("Defendants") alleging that they knew about supposedly inadequate review and authorization of foreclosure documents and other activities that exposed BAC to potential liability.  Plaintiff alleges that, despite gaining detailed knowledge from extensive due diligence performed prior to BAC's acquisition of Countrywide Financial Corp., Defendants recklessly mismanaged the risks posed by the acquisition and exposed BAC to substantial liability by refusing to cooperate with government regulators investigating BAC's foreclosure practices, obtaining reimbursement on government guaranteed mortgages in violation of the False Claims Act, and other allegedly wrongful acts.  Plaintiff alleges violations of Sections 10(b) and 10b-5 of the Exchange Act, breach of fiduciary duty, and breach of the duty of candor.  Complaint.