Allegations
The Offering Documents were negligently prepared and, as a result, contained untrue statements of material facts or omitted to state other facts necessary to make the statements made not misleading, and were not prepared in accordance with the rules and regulations governing their preparation as the Offering Documents failed to disclose: (i) that GreenSky was transitioning away from the solar power market in favor of the elective healthcare market; (ii) foreseeable negative effects on GreenSky’s profits because of significant differences in transaction fees GreenSky charged to different classes of merchants; (iii) the primacy of the merchant mix as a driver of GreenSky’s transaction-fee revenue; (iv) the ongoing deterioration in GreenSky’s transaction-fee revenue, while touting GreenSky’s growth and financial performance; (v) the negative impacts of GreenSky’s changing merchant mix on EBITDA; (vi) the markedly lower transaction fees GreenSky charges to healthcare companies; and (vii) as a result of the foregoing, GreenSky’s Offering Documents were materially false and misleading at all relevant times.