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14. Of the total number of those CIDs issued, the AGO issued about twenty-five in<br />

connection with joint investigations with other states, about thirty in connection with<br />

investigations involving the federal government, and several involving both other states and the<br />

federal government. CIDs issued pursuant to G.L. c. 93 A ("Chapter 93 A"), § 6, have addressed,<br />

among other things, foreclosure practices of banks, business practices in the pharmaceuticals<br />

industry, the marketing and sale of securities, and solicitations and transactions involving other<br />

products and services sold in the Commonwealth.<br />

15. Examples since 2013, which have become public through settlement with the<br />

target companies, include: investigations involving large multistate groups and the federal<br />

government (Chase Bank, Ocwen, and HSBC); investigations with small groups of states and the<br />

federal government (Citigroup, JP Morgan); a joint investigation with federal authorities<br />

(Oppenheimer); a joint investigation with another state (LPL Financial); and a joint investigation<br />

with a large multistate group (MoneyGram). Attached to this affidavit as Exhibit 11 (Chase<br />

Bank), Exhibit 12 (Ocwen), Exhibit 13 (HSBC), Exhibit 14 (Citigroup), Exhibit 15 (JP<br />

Morgan), Exhibit 16 (Oppenheimer), Exhibit 17 (LPL Financial), and Exhibit 18 (MoneyGram)<br />

are true and accurate copies of press releases issued by the Office in connection with those<br />

settlements.<br />

16. A very recent, visible example is the AGO's 2016 participation in a joint<br />

multistate investigation into Volkswagen's "clean diesel" deception, which has so far resulted in<br />

a partial settlement providing Massachusetts with nearly $100 million in Chapter 93 A civil<br />

penalties and environmental mitigation.<br />

17. Attached to this affidavit as Exhibit 19 is a true and accurate copy of an AGO<br />

press release announcing the partial settlement, "AG Healey Announces Major Award for More<br />

4

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