According to the complaint, Banco Bradesco provides banking and financial products and services to individuals, companies, and corporations and institutions.
The complaint alleges that throughout the Class Period, the defendants made false and/or misleading statements and/or failed to disclose that: (1) Banco Bradesco was engaged in a bribery scheme in collusion with the Brazilian Finance Ministry’s CARF; (2) Banco Bradesco executives were plotting to avoid an $828 million tax fine that was imposed by Brazil’s Internal Revenue Service; (3) Banco Bradesco’s CEO, Luiz Carlos Trabuco Cappi, and other executives, directors and employees of the company had engaged in bribery, money laundering, and corruption; (4) Banco Bradesco’s internal control over financial reporting and its disclosure controls and procedures were not effective; and (5) as a result, Banco Bradesco’s public statements were materially false and misleading at all relevant times.
The Class Period commences on April 30, 2012 when the company filed a Form 20-F for the fiscal year ended December 31, 2011 with the SEC, which provided the company’s year-end financial results and position and stated that the company’s internal control over financial reporting and disclosure controls and procedures were effective as of December 31, 2011.
According to the complaint, on March 27, 2015, Associated Press published an article entitled “Brazil police report massive tax fraud scheme”, stating that Brazil’s Federal Police agency brought legal proceedings against more than 50 companies. Following this news, shares of Banco Bradesco fell $2.19 per share or approximately 20% from its previous closing price to close at $8.86 per share on March 27, 2015.
Then, on May 31, 2016, Reuters published an article entitled “UPDATE 1-Bradesco stock slumps as CEO Trabuco indicted in Brazil tax probe”, stating that Brazil’s federal police indicted Banco Bradesco executives, including Defendant Cappi, on corruption-related charges, and that police accused the executives of plotting to avoid a 3 billion-real ($828 million) tax fine. Following this news, shares of Banco Bradesco fell $0.37 per share or approximately 6% from its previous closing price to close at $6.26 per share on May 31, 2016, damaging investors.
If you are a member of the class described above, you may no later than August 2, 2016 move the Court to serve as lead plaintiff of the class, if you so choose.
A lead plaintiff is a representative party that acts on behalf of other class members in directing the litigation. In order to be appointed lead plaintiff, the Court must determine that the class member’s claim is typical of the claims of other class members, and that the class member will adequately represent the class. Your ability to share in any recovery is not, however, affected by the decision whether or not to serve as a lead plaintiff. Any member of the purported class may move the court to serve as a lead plaintiff through counsel of their choice, or may choose to do nothing and remain an inactive class member.
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