31.   The commission also found that Citron and Raabe had shifted money among various county accounts to manipulate the yield on the investment pool.

32.   The bond offering statements did not disclose any losses in the investment pool, whose value began falling in February after interest rates started to rise.

33.   The crisis hurt two American investment pools managed by Barings.

34.   The financial health of these debt offerings was related to a county investment pool, whose deteriorating condition, the government contends, was not disclosed to investors.

35.   The investment pools hold operating funds for the counties and local school districts.

36.   The losses resulted from highly leveraged, wrong-way bets on the future of interest rates that Citron made through a county investment pool.

37.   The notes financed the investment pool.

38.   The Roebling Fund was the first takeover investment pool to be set up by a U.S. bank with securities underwriting power.

39.   The SEC is looking into the actions of brokerage firms that underwrote Orange County bonds during the period when the investment pool was being filled with the securities.

40.   The state hopes to save money by issuing commercial paper, instead of borrowing from a state investment pool at higher rates, Fong said.