On January 31, 2012, German bank DZ Bank AG filed a complaint in New York state court against HSBC North America Holdings, Inc. and others relating to the purchase of $122 million in RMBS certificates. DZ Bank alleges that HSBC misrepresented and omitted critical information in its offering documents regarding underwriting standards, the characteristics of the loans underlying the securities, and the securities’ credit ratings. The complaint brings claims for common-law fraud, fraudulent inducement, negligent misrepresentation, aiding and abetting fraud, breach of contract, and rescission. Complaint.