Full opinion text
OPINION AND ORDER JESSE M. FURMAN, District Judge: The United States brings this civil fraud action against Defendant Wells Fargo Bank, N.A. (“Wells Fargo” or the “Bank”), alleging that the Bank engaged in misconduct in originating and underwriting government-insured home mortgage loans. The Government seeks damages and civil penalties, likely to total hundreds of millions of dollars, under the False Claims Act (the “FCA”), 31 U.S.C. §§ 3729 et seq.; the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIR-REA”), 12 U.S.C. § 1833a; and New York common law. Wells Fargo moves to dismiss the Amended Complaint pursuant to Rules 9(b) and 12(b)(6) of the Federal Rules of Civil Procedure, arguing that: (1) the Government released the claims at issue pursuant to a consent judgment entered by the United States District Court for the District of Columbia in a previous lawsuit; (2) many of the Government’s FCA and common law claims are time barred; (3) the Amended Complaint fails to satisfy the pleading requirements of Rule 9(b); and (4) the Amended Complaint fails to state a claim upon which relief can be granted. For the most part, Wells Fargo’s arguments are unavailing. As an initial matter, the consent judgment does not bar any of the Government’s claims. Furthermore, the claims are pleaded with sufficient particularity to satisfy Rule 9(b). In addition, the federal statutory claims are sufficient to allege a plausible basis for relief under Rule 12(b)(6). And, on the current record, there is no basis to dismiss any of the statutory claims as untimely. Therefore, all of the Government’s federal statutory claims may proceed. Many of the Government’s common law claims, however, must be, and are, dismissed. In particular, any tort claims that arose before June 25, 2009, are time barred. Additionally, the Government’s mistake of fact and unjust enrichment claims are dismissed in their entirety: Those arising before 2004 are untimely, and those arising thereafter are barred because the United States Department of Housing and Urban Development was aware of Wells Fargo’s misconduct at the time. Accordingly, as explained in more detail below, Wells Fargo’s motion is DENIED as to the Government’s federal statutory claims and GRANTED in part and DENIED in part with respect to the Government’s common law claims. BACKGROUND Unless otherwise stated, the following facts are taken from the Amended Complaint (Docket No. 22) and are assumed, for purposes of this opinion, to be true. See LaFaro v. N.Y. Cardiothoracic Grp., PLLC, 570 F.3d 471, 475 (2d Cir.2009). A. The Direct Endorsement Lender Program The United States Department of Housing and Urban Development (“HUD”), through the Federal Housing Administration (“FHA”), insures approved lenders against losses on certain home mortgage loans. (Am. Compl. ¶ 13). If a homeowner whose mortgage is FHA-insured defaults, HUD will pay the lender the balance of the loan as well as assume ownership of and manage any foreclosed property. (Id. ¶ 14). By protecting lenders against mortgage defaults, FHA insurance encourages lenders to make home loans to creditworthy borrowers to whom the lenders might not otherwise offer a mortgage. (Id.). One program through which FHA insures home mortgages is the Direct Endorsement Lender program. (Id. ¶ 15). Direct Endorsement Lenders (“lenders”) are authorized to evaluate the credit risk of potential borrowers, underwrite mortgage loans, and certify those loans for FHA mortgage insurance “without prior HUD review or approval.” (Id.). In doing so, these lenders are required to comply with regulations — including those found in HUD Handbooks and Mortgagee Letters — governing, among other things, the origination and underwriting of individual loans; the hiring, training, and compensation of underwriters; the monitoring and reporting of the quality of loans originated; and the submission of FHA claims for defaulted loans. (Id. ¶¶ 17-30, 37-43). Each lender is required to make an annual certification of compliance with the program’s requirements. (Id. ¶ 37). The claims at issue in this case arise from Wells Fargo’s participation in the Direct Endorsement Lender program. 1. Issuance of Individual Mortgages HUD requires Direct Endorsement Lenders to conduct due diligence before issuing FHA-insured mortgages. (Id. ¶¶ 19-20). In particular, when issuing a loan, an underwriter must “determin[e] a borrower’s ability and willingness to repay a mortgage debt,” and examine any “property offered as security for the loan to determine if it provides sufficient collateral.” (Id. ¶ 19 (citing 24 C.F.R. §§ 203.5(d), (e)(3))). HUD provides specific requirements for how underwriters are to evaluate a borrower’s credit risk and appraise mortgaged property. (Am. Compl. ¶¶ 21-23). These requirements specify, for example, the documents an underwriter must obtain from a potential borrower, the information the underwriter must request from the borrower, and the factors a lender is to consider in determining whether to issue a mortgage. (Id.). In making loan decisions, a Direct Endorsement Lender is required by law to “ ‘exercise the same level of care which it would exercise in obtaining and verifying information for a loan’ ” that was not FHA-insured — that is, a loan where the lender was “ ‘entirely dependent on the property as security to protect its investment.’ ” (Id. ¶ 19 (quoting 24 C.F.R. § 203.5(c))). After each loan is issued, the lender must make several certifications regarding its compliance with HUD regulations. For example, if the loan was underwritten using an FHA-approved automated underwriting system, the lender must certify to “the integrity of the data” inputted into the system “to determine the quality of the loan,” and it must certify “that a Direct Endorsement Underwriter reviewed the appraisal (if applicable).” (Am. Compl. ¶ 38 (internal quotation marks and brackets omitted)). If the loan was manually underwritten, the lender must certify that “the underwriter personally reviewed the appraisal report (if applicable), credit application, and all associated documents and has used due diligence in underwriting the mortgage.” (Id. (internal quotation marks and brackets omitted)). In all cases, the underwriter must certify that he or she has “personally reviewed the mortgage loan documents, closing statements, application for insurance endorsement, and all accompanying documents.” (Id.). The underwriter must also “make all certifications required for th[e] mortgage as set forth in HUD Handbook 4000.4.” (Id. ¶ 39 (internal quotation marks omitted)). And the lender must certify that the mortgage “complies with HUD rules and is eligible for HUD mortgage insurance under the Direct Endorsement program.” (Id. ¶ 38 (internal quotation marks omitted)). If HUD discovers that a loan endorsed for FHA insurance is, in fact, ineligible to be insured, “HUD seeks indemnification from the Direct Endorsement Lender that certified the loan via an indemnification agreement whereby the lender agrees to indemnify HUD should claims for FHA insurance be submitted on that loan.” (Id. ¶ 40). 2. Quality Control and Reporting In order to participate in the Direct Endorsement Lender program, lenders must implement a quality control system that is independent of the lender’s loan origination and servicing departments. (Id. ¶ 24). HUD’s quality control requirements mandate that, among other things, lenders review a random sample of loans each month to ensure they were underwritten in accordance with HUD requirements, and that they review all early payment defaults — that is, loans that default within the first six payments. HUD Handbook 4060.1 REV-2, ¶ 7-6. (See also Am. Compl. ¶ 24). HUD provides a rating system by which lenders may evaluate the loans they review. (Id. ¶ 26). Loans with only minor or no violations of HUD’s origination and servicing guidelines are rated low risk; those with violations, but none that is “material to creditworthiness, collateral security or insurability of the loan,” are considered acceptable; mortgages with “significant unresolved questions or missing documentation” are labeled a “moderate risk to the mortgagee and FHA”; and mortgages that contain “material violations of FHA or mortgagee requirements ... represent an unacceptable level of risk” and are labeled “material risk” loans. HUD Handbook 4060.1 REV-2, ¶7-4. (See also Am. Compl. ¶ 26). Lenders are required to report to FHA in writing any “material risk” mortgages they identify. HUD Handbook 4060.1 REV-2, ¶7-4. HUD also requires that lenders report any “ ‘[s]erious deficiencies, patterns of non-compliance, or fraud’” they discover “within 60 days.” (Am. Compl. ¶ 28 (quoting HUD Handbook 4060.1 REV-1, CHG-1, ¶ 6-13)). In addition to reporting these violations to HUD, quality control review findings must also be reported to lenders’ “ ‘senior management,’ ” which is required to “ ‘take prompt action to deal appropriately’ ” with the problems. (Id. ¶ 30 (quoting HUD Handbook 4060.1 REV-2, ¶ 7-3(1))). During the time period relevant to this case, Wells Fargo maintained a quality control program. (Id. ¶¶ 31-36). Through this program, the Bank conducted “monthly reviews of a random sample of loans originated ... within the prior 60 days,” as well as “at least some portion of its [early payment defaults].” (Id. ¶ 31). In reviewing its loans, Wells Fargo largely adopted the rating system provided by the HUD Handbook. (Id. ¶ 32). Although not identical to that provided in the Handbook, Wells Fargo’s definition of “material risk” loans “mirrored HUD’s in substance, and made clear that a loan with that rating contained unacceptable risk and was ineligible for FHA insurance.” (Id.). The findings of Wells Fargo’s quality control reviews were reported monthly to the Bank’s senior management. (Id. ¶ 34). B. Reckless Origination and Underwriting Allegations The Government alleges that between May 2001 and October 2005, “Wells Fargo engaged in a regular practice of reckless origination and underwriting of its [FHA-insured] loans and falsely certified to HUD that tens of thousands of those loans were eligible for FHA insurance.” (Id. ¶ 44). In particular, the Government alleges that beginning in 2000, Wells Fargo significantly increased its origination of FHA-insured mortgages. (Id. ¶ 46). To do so, the Bank relied on inadequately trained employees (id. ¶¶ 46, 86); impermissibly paid its underwriters a bonus based on the number of loans they approved (id. ¶ 47); “applied heavy pressure on loan officers and underwriters to originate, approve, and close loans” (id. ¶ 48); “required underwriters to make decisions on loans on extremely short turnaround times” (id.); and “employed lax and inconsistent underwriting standards and controls” (id.). As a result, “the quality of the bank’s [FHA-insured home mortgage] loans dropped precipitously.” (Id. ¶ 50). Underwriters were certifying as eligible for FHA insurance loans they knew or should have known were not so eligible. (Id. ¶ 140). Between May 2001 and January 2003, an average of 32.9% — that is, nearly a third — of the randomly sampled loans the Bank reviewed every month evidenced material violations of HUD regulations. (Id. ¶ 54). For several months during that time period, the material violation rate climbed to over forty percent. (Id.). Between February 2003 and October 2005, the monthly material violation rate of randomly reviewed loans averaged 16.4%. (See id. ¶ 89). Wells Fargo’s Quality Assurance department reported these findings to the Bank’s senior management. (Id. ¶ 50). The department warned the Bank’s management that “heavy volume, pressure to approve loans and meet acceptable turn[around] times[,] along with inexperienced staff are key contributing factors overall to the issues leading to material findings.” (Id. ¶ 85). Yet the Bank did almost nothing. (Id. ¶¶ 55, 85). It did not change its focus on high volume loan origination or its tactics for generating such volume; it did not prepare a written action plan to address the loans with material violations; it did little to no follow-up on these loans; it did not report the loans to HUD; and it did not document any corrective action that was taken. (Id. ¶¶ 55, 84-86). Despite knowing that a substantial portion — in some months, nearly half — of its loans issued between 2001 and 2005 evidenced material violations of HUD regulations, Wells Fargo nevertheless “certified its entire portfolio of retail FHA loans for insurance, and thereby falsely certified that thousands of retail FHA loans were eligible for insurance when they were not.” (Id. ¶ 140; see id. ¶¶ 54, 84, 89). Wells Fargo sold some of these FHA-insured loans to third parties “knowing” that those third parties would submit claims to HUD if the loans defaulted. (Id. ¶¶ 82, 117). But “for the vast majority of its retail FHA loans originated in this period,” the Bank “remained the holder of record,” and thus “was paid on claims for FHA insurance when those loans defaulted.” (Id. ¶ 82; see id. ¶ 117). C. Allegations Regarding Wells Fargo’s Failure To Self-Report Material Violations HUD requires — and throughout the time period relevant to this lawsuit, required — Direct Endorsement Lenders to report to the agency any loans the lenders identify as materially violating FHA regulations. (Id. ¶ 12 l). Wells Fargo was aware of this requirement and affirmed to HUD that it would comply. (Id. ¶¶ 122, 126). Between January 2002 and December 2010, the Bank identified 6,558 loans as materially violating HUD requirements. (Id. ¶ 132). Nevertheless, until October 2005, Wells Fargo did not report a single loan (id. ¶ 127), and between October 2005 and December 2010, the Bank reported only 238 loans (id. ¶ 132). Despite HUD requirements to the contrary, Wells Fargo thus failed to report 6,320 “material risk” loans to the agency. (Id.). An internal memo suggests that it did so, in part, to avoid having to indemnify HUD for these loans. (Id. ¶ 130). Of the 6,320 loans Wells Fargo failed to report, 1,443 defaulted. (Id. ¶ 135). Although a small fraction of these loans were sold to third parties, Wells Fargo was the holder of record for, and submitted claims for FHA insurance on, 97% of them. (Id.). The Government provides, as exhibits to its Amended Complaint, lists of the 6,320 “material risk” loans it alleges Wells Fargo failed to report; the 1,406 loans that defaulted and for which Wells Fargo submitted a claim for FHA insurance; and the 37 defaulted loans for which third parties submitted claims for FHA insurance. (Id. Exs. A-C). D. Relief Sought The Government alleges that, as a result of Wells Fargo’s reckless origination and underwriting, as well as the Bank’s failure to report to HUD loans it identified as materially violating FHA regulations, Wells Fargo submitted claims for FHA insurance on thousands of defaulted mortgage loans that Wells Fargo knew, or should have known, were ineligible for such insurance. (E.g., id. ¶¶ 140, 147, 152, 159). The Government seeks treble its damages and civil penalties pursuant to the FCA, civil penalties under FIRREA, and compensatory damages for its common law claims. (Id. ¶¶ 144, 149, 156, 162, 167, 183, 190, 196, 199, 204, a-g). The specific amount of damages is to be determined at trial, but would presumably total hundreds of millions of dollars. (See id. ¶¶ 3, 5, 83, 119,137). DISCUSSION Wells Fargo moves to dismiss the Amended Complaint on four grounds. First, it contends that the Government released the claims at issue here pursuant to a consent judgment entered in the United States District Court for the District of Columbia in a previous lawsuit. Second, the Bank asserts that many of the Government’s FCA and common law claims are time barred. Third, Wells Fargo argues that the Amended Complaint fails to satisfy the heightened pleading requirements of Rule 9(b) of the Federal Rules of Civil Procedure. And fourth, it contends that the Amended Complaint fails to state a claim upon which relief can be granted pursuant to Rule 12(b)(6). The Court will address each argument in turn. A. The Consent Judgment Wells Fargo argues first that the Government released the claims at issue here pursuant to a consent judgment entered on April 4, 2012, in the United States District Court for the District of Columbia. In that case, the Department of Justice (“DOJ”), forty-nine state attorneys general, and the attorney general for the District of Columbia sued several banks including Wells Fargo, alleging misconduct related to, among other things, the origination and servicing of FHA-insured mortgage loans. See United States v. Bank of America Corp., No. 12-361(RMC). As part of a settlement agreement, the Government and Wells Fargo agreed to the entry of a consent judgment, under which the United States released Wells Fargo from any civil claims under FIRREA or the FCA “where the sole basis for such claim or claims is that [Wells Fargo] ... submitted to HUD-FHA ... a false or fraudulent annual certification that the mortgagee had conformed to all HUD-FHA regulations necessary to maintain its HUD-FHA approval.” (Baruch Deck Ex. D, at F-17 (internal quotation marks and alteration omitted)). When the Government filed the present lawsuit, Wells Fargo sought an order from the D.C. District Court enjoining this suit as prohibited by the terms of the release. That Court denied Wells Fargo’s motion and rendered an interpretation of the consent judgment, see United States v. Bank of America, 922 F.Supp.2d 1 (D.D.C.2013), an interpretation the parties agree is binding in this case. (See Oral Arg. Tr. 3, 10, Apr. 17, 2013 (Docket No. 36)). The consent judgment, that Court held, is “clear and unambiguous.” Bank of America, 922 F.Supp.2d at 10. “[W]ith regard to liability based on false certifications,” the United States released: (1) Claims under FIRREA, FCA, and the Program Fraud Civil Remedies Act where the “sole basis” for such claims is that Wells Fargo submitted a false or fraudulent annual certification — without regard to whether any such loan contains a material violation of HUD-FHA requirements; and (2) Claims under FCA based on a false individual loan certification where the individual loan did not contain a material violation of HUD-FHA requirements. Id. at 9. The Court clarified that while the Government released Wells Fargo from claims based solely on the annual certifications themselves, it did not release claims based on the underlying conduct that is the subject of such certifications. See id. Having so construed the consent decree, the D.C. Court left it to this Court to interpret the Amended Complaint in this case and to decide whether the Government’s claims here are barred by the consent judgment. Given the D.C. Court’s construction of the consent decree, this Court easily concludes that the release does not bar the claims at issue here. The Amended Complaint’s allegations do not rely solely on the annual certifications. Indeed, the annual certifications are largely irrelevant to the Government’s claims. The claims in the Amended Complaint are primarily based on: Wells Fargo’s practices targeted at increasing loan origination, resulting in loans that the Government alleges Wells Fargo knew or should have known materially violated HUD regulations; the individual loan certifications the Government alleges Wells Fargo — because of its reckless encouragement of loan origination — knew or should have known were false; Wells Fargo’s failure to report to HUD loans it knew to be materially in violation of HUD’s regulations; and its subsequent submission of claims for defaulted loans. It is true that some of the conduct upon which the Government’s claims are based is conduct that underlies the annual certifications. But the D.C. Court explicitly held that claims based on such conduct were not released by the consent judgment. Accordingly, this lawsuit is not barred by the release. B. Timeliness Next, Wells Fargo contends that many of the Government’s FCA and state common law claims are untimely. The Bank is correct with respect to many of the Government’s common law claims, but there is no basis — at this stage of the case — to dismiss the Government’s FCA claims as time barred. As relevant here, FCA claims may be brought within three years of the date that DOJ learned of the relevant facts underlying the claims, so long as they are brought within ten years of the date of the violation. Furthermore, the Wartime Suspension of Limitations Act (the ‘WSLA”), 18 U.S.C. § 3287, which was amended in 2008, tolled the statute of limitations for any claims that were still live at the time of the amendment. The Government alleges that DOJ did not learn of the facts at issue here until 2011. Assuming this allegation to be true — as the Court must — all of the Government’s FCA claims were live as of 2008, were tolled by the WSLA at that point, and thus are timely now. By contrast, the Government’s common law tort claims are subject to a three year statute of limitations, and its quasi-contract claims are subject to a six year statute of limitations. The parties entered a tolling agreement that permits the Government to bring in this action any claims that were timely as of June 25, 2012. There is no other basis, however, to find that the statutes of limitations with respect to these common law claims was tolled. Accordingly, only those tort claims arising on or after June 25, 2009, and those quasi-contract claims arising on or after June 25, 2006, are timely. 1. The FCA Claims The Court will begin its analysis with the FCA claims. Title 31, United States Code, Section 3731(b) provides that a claim under the FCA “may not be brought”: (1) more than 6 years after the date on which the violation ... is committed, or (2) more than 3 years after the date when facts material to the right of action are known or reasonably should have been known by the official of the United States charged with responsibility to act in the circumstances, but in no event more than 10 years after the date on which the violation is committed, whichever occurs last. Citing Section 3731(b)(1), Wells Fargo argues that any FCA claims that accrued prior to June 25, 2006 — that is, six years before the parties’ tolling agreement — are time barred. The Government counters that its FCA claims are timely for two reasons: First, the Government argues, the FCA itself, in Section 3731(b)(2), extends the statute of limitations for claims where, as here, the Attorney General, or his designee within DOJ, is not, and has no reason to be, aware of the facts underlying those claims. Second, it contends that, pursuant to the WSLA, the statute of limitations was tolled for all FCA claims when Congress authorized the use of military force against those responsible for the September 11, 2001 terrorist attacks, see Authorization for Use of Military Force, Pub. L. No. 107-40, 115 Stat. 224 (2001), and in Iraq in 2002, see Authorization for Use of Military Force Against Iraq Resolution of 2002, Pub. L. No. 107-243, 116 Stat. 1498. (Gov’t Mem. 46-48 (Docket No. 30); Oral Arg. Tr. 39). Because the United States is still technically at war for purposes of the WSLA, the Government argues, the limitation periods remain tolled. (Gov’t Mem. 48). The Court will address each argument in turn. a. The Statute of Limitations Under the FCA With respect to its first argument, the Government contends that the Attorney General, or his designee within DOJ, is “the official of the United States charged with responsibility to act” on FCA claims. (Gov’t Mem. 40-42). The Amended Complaint alleges that DOJ was unaware of “the facts material to its claims against Wells Fargo” until “2011, the year in which the United States Attorney’s Office for the Southern District of New York ... commenced its investigation.” (Am. Compl. ¶ 118). Therefore, the Government argues, pursuant to Section 3731(b)(2), its FCA claims were timely so long as they were brought within three years of the time the investigation began and within ten years of the parties’ tolling agreement. (Gov’t Mem. 40). Wells Fargo, however, insists that the HUD Inspector General — who conducted an audit of Wells Fargo’s FHA mortgage loan origination practices in July of 2004 (Baruch Decl. Ex. F) — “certainly” has responsibility to act in the face of mortgage fraud. (Wells Fargo Mem. 15 (Docket No. 27)). Therefore, Wells Fargo argues, the Government was required to bring its FCA claims by July 2007 — three years after the Inspector General became aware of Wells Fargo’s purported misconduct— or six years after the claims arose, whichever is later. (Wells Fargo Mem. 13). Section 3731(b)(2) was adapted from Title 28, United States Code, Section 2416(c), which provides that the statute of limitations generally applicable to claims brought by the United States shall exclude any time during which “facts material to the right of action are not known and reasonably could not be known by an official of the United States charged with the responsibility to act in the circumstances.” 28 U.S.C. § 2416(c); see 132 Cong. Rec. 20,536 (1986) (statement of Sen. Charles Grassley) (stating that the FCA tolling provision “is adopted directly” from 28 U.S.C. § 2416(c)). Because the FCA has its own statute of limitations, it is not subject to the statute of limitations generally applicable to Government claims or the provisions, including Section 2416, tolling that statute of limitations. See 28 U.S.C. § 2415 (stating that the statute of limitations provided therein applies to claims of the United States “except as otherwise provided by Congress”). Therefore, Congress amended the FCA to provide for similar tolling. See, e.g., False Claims Act Amendments: Hearings Before the Subcomm. on Admin. Law and Governmental Relations of the H. Comm. on the Judiciary, 99th Cong. 159 (1986) (statement of Rep. Willard). Courts have repeatedly held that Section 2416(c) applies to officials other than those at DOJ. See, e.g., United States v. Bollinger Shipyards, Inc., No. 12-920, 2013 WL 393037, at *14 (E.D.La. Jan. 30, 2013); United States ex rel. Wilkins v. North Am. Constr. Corp., No. Civ. A. H-95-5614, 2001 WL 34109383, at *4 (S.D.Tex. Sept. 26, 2001); United States v. Stella Perez, 956 F.Supp. 1046, 1058 (D.P.R.1997). It does not necessarily follow, however, that Section 3731(b)(2), the FCA tolling provision, applies as broadly. Section 2416(c), after all, extends to all government claims (unless otherwise specified by Congress), including claims that may be brought by agencies other than DOJ. See Bollinger Shipyards, 2013 WL 393037, at * 13 (collecting cases). By contrast, the only official authorized to bring an FCA claim is the Attorney General (or his designee within DOJ). See 31 U.S.C. § 3730; 28 C.F.R. § 0.45(d); see also Martin J. Simko Constr., Inc. v. United States, 852 F.2d 540, 547 (Fed.Cir.1988) (“[T]he Attorney General is specifically authorized to administer [FCA] claims for the government. No other agency is empowered to act under the statute.”); United States ex rel. Barajas v. Northrop Corp., 65 F.Supp.2d 1097, 1102 (C.D.Cal. 1999) (similar); Ohio Hosp. Ass’n v. Shalala, 978 F.Supp. 735, 739 (N.D.Ohio 1997) (similar); Jana, Inc. v. United States, 34 Fed.Cl. 447, 451 n. 6 (Fed.C1.1995) (similar). Indeed, although other agencies are permitted to settle certain claims, they are expressly prohibited from compromising fraud claims. See 31 U.S.C. § 3711(b)(1). Furthermore, while Section 2416(c) provides for tolling until “an official ... charged with the responsibility to act” is apprised of the material facts, 28 U.S.C. § 2416(c) (emphasis added), Section 3731(b)(2) applies where “the official of the United States charged with responsibility to act” is reasonably unaware of the relevant facts, 31 U.S.C. § 3731(b)(2) (emphasis added). On its face, then, Section 3731(b)(2) contemplates only one relevant official. The law is clear that that official is the Attorney General. The majority of other courts that have considered this issue have reached the same conclusion. See, e.g., United States v. Carell, 681 F.Supp.2d 874, 881 (M.D.Tenn.2009); United States v. Tech Refrigeration, 143 F.Supp.2d 1006, 1009 (N.D.Ill.2001); Jana, Inc. v. United States, 34 Fed.Cl. 447, 451 n. 6 (1995); United States v. Incorporated Vill. of Island Park, 791 F.Supp. 354, 363 (E.D.N.Y.1992) (“Island Park”). For the contrary proposition, Wells Fargo cites United States ex rel. Kreindler & Kreindler v. United Techs. Corp., Ill F.Supp. 195 (N.D.N.Y. 1991), in which the district court held that senior army officials were officials “charged with responsibility to act” on claims that an army contractor had concealed a design defect in helicopters sold to the army in violation of the FCA. (Wells Fargo Mem. 16 n. 17). In that case, however, the relator argued that the statute of limitations ought to be tolled because the only official “charged with responsibility to act” on such claims was the contracting officer, and that officer was unaware of the fraud; the question of whether the Attorney General was the only official with responsibility to act was neither raised nor decided. Kreindler & Kreindler, 777 F.Supp. at 204-05. Additionally, although it did not specifically address the question at issue here, the Second Circuit reversed on appeal, holding both that the district court should not have reached the statute of limitations question at all and that its analysis on that issue was flawed. See United States ex rel. Kreindler & Kreindler v. United Technologies Corp., 985 F.2d 1148, 1155-57 (2d Cir.1993). Because it did not consider the arguments raised here and because it was reversed by the Second Circuit, the decision in Kreindler & Kreindler “is of limited precedential value.” Tech Refrigeration, 143 F.Supp.2d at 1010 n. 3. In sum, both the statutory text and the weight of authority support the conclusion that the only government “official ... charged with responsibility to act” under the FCA is the Attorney General (or his designee within DOJ). It follows that the Government’s FCA claims are timely so long as they are: (1) filed within either six years of the underlying violation or three years of the date DOJ knew or reasonably should have known of the facts material to the claim, whichever is later; and (2) filed no later than ten years from the date on which the underlying violation was committed. The Government alleges that DOJ was unaware of the material facts underlying this action until 2011. Given the purported widespread dissemination of the 2004 HUD audit of Wells Fargo and its subsequent report to Congress, Wells Fargo contends that the facts underlying this action “ ‘reasonably should have been known’ to the Justice Department” in 2004, even if DOJ did not have actual knowledge. (Wells Fargo Mem. 15-16 (quoting 31 U.S.C. § 3731(b)(2))). But the extent of the audit’s dissemination and, thus, the question of whether DOJ knew or should have known of its findings is a question of fact that is not properly resolved at this stage. See, e.g., United States v. BNP Paribas SA, 884 F.Supp.2d 589, 600 (S.D.Tex.2012) (holding that where the complaint alleges some basis for tolling, whether the material facts were known or should have been known by the responsible officials is a question of fact). Therefore, for purposes of this motion, the Court must assume the Government’s allegation regarding DOJ’s knowledge to be true. Based on this allegation, any FCA claims filed by 2014 — that is, three years from the date DOJ allegedly became aware of the material facts at issue here— are timely so long as they are also filed within ten years of the date of the underlying violation. As noted above, the parties entered a tolling agreement that permits the Government to bring any claims that were timely as of June 25, 2012. (Wells Fargo Mem. 13 n. 11) On the current record, then, any claims based on FCA violations arising after June 25, 2002 would appear to be timely. By contrast, any claims based on violations before that date would seem to be untimely, unless there was some basis to toll the statute of limitations. b. The WSLA That brings the Court to the WSLA. To the extent relevant here, the WSLA suspends the statute of limitations for offenses involving fraud against the United States when the country is at war or Congress has enacted a specific authorization for the use of the Armed Forces. See 18 U.S.C. § 3287. The Government argues that even if some of its FCA claims arose prior to June 25, 2002, they are nevertheless timely because the WSLA tolled the statute of limitations for claims that were live as of October 14, 2008, the date upon which the WSLA was amended to make clear that the Act applied to congressional authorizations for the use of force. (See Gov’t Mem. 46-48). The Court agrees. Because, as explained above, there is no reason at this stage to believe that the Attorney General knew or should have known of the facts at issue here until 2011, pursuant to Section 3731(b)(2), any claims that arose within ten years of October 14, 2008 — that is, all of the Government’s claims — were presumably live as of that date and thus tolled by WSLA. Prior to 2008, the WSLA provided as follows: When the United States is at war the running of any statute of limitations applicable to any offense (1) involving fraud or attempted fraud against the United States or any agency thereof in any manner, whether by conspiracy or not, or (2) committed in connection with the acquisition, care, handling, custody, control or disposition of any real or personal property of the United States, or (3) committed in connection with the negotiation, procurement, award, performance, payment for, interim financing, cancelation, or other termination or settlement, of any contract, subcontract, or purchase order which is connected with or related to the prosecution of the war, or with any disposition of termination inventory by any war contractor or Government agency, shall be suspended until three years after the termination of hostilities as proclaimed by the President or by a concurrent resolution of Congress. 18 U.S.C. § 3287 (2006). On October 14, 2008, Congress amended the Act, expanding its application to cover periods “[w]hen the United States is at war or Congress has enacted a specific authorization for the use of the Armed Forces.” 18 U.S.C. § 3287 (2011) (emphasis added). Additionally, the amended statute suspends the relevant statutes of limitations “until 5 years after the termination of hostilities as proclaimed by a Presidential proclamation, with notice to Congress, or by a concurrent resolution of Congress.” Id. In light of the 2008 amendment, there is no dispute that the WSLA is now in effect as to offenses “involving fraud or attempted fraud against the United States or any agency thereof.” After all, on September 18, 2001, Congress authorized the use of military force “against those responsible for” for the September 11, 2001 terrorist attacks, see Authorization for Use of Military Force, Pub. L. No. 107-40, 115 Stat. 224 (2001); and on October 16, 2002, Congress authorized the use of military force in Iraq, see Authorization for Use of Military Force Against Iraq Resolution of 2002, Pub. L. No. 107-243, 116 Stat. 1498. Additionally, there has been neither a Presidential proclamation, with notice to Congress, nor a congressional resolution suspending hostilities. Nevertheless, Wells Fargo argues that the WSLA should not be applied to the Government’s claims in this case for four reasons: (1) because the 2008 amendment may not be “retroactive[ ]”; (2) because the claims do not “involv[e] fraud” within the meaning of the WSLA; (3) because the WSLA applies only to criminal offenses, not civil claims; and (4) because the Act does not extend to claims that are unrelated to wartime contracting. (See Reply 8-9 (Docket No. 31); Oral Arg. Tr. 17-24). These arguments are unpersuasive. First, Wells Fargo suggests that “it is by no means clear” that the 2008 amendment “can be applied retroactively.” (Reply 9). “[W]here, as here,” however, a “new rule” does not “alter[] substantive rights,” but rather “announces a period of limitations, the conduct to which it refers is the plaintiffs conduct relating to the filing of the claim and not the defendant’s conduct giving rise to the claim.” Walsche v. First Investors Corp., 981 F.2d 649, 654 (2d Cir.1992). Therefore, “applying a new or amended statute of limitations to ... a cause of action filed after its enactment, but arising out of events that predate its enactment, generally is not a retroactive application of the statute.” Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 889 (2d Cir.1995). The applicable statute of limitations governing a lawsuit is thus that which is in effect at the time the lawsuit is filed. See id. As Wells Fargo conceded at oral argument (Oral Arg. Tr. 15), the 2008 WSLA amendment therefore applies to any claims for which the statute of limitations had not yet run at the time of its passage. See BNP Paribas SA, 884 F.Supp.2d at 607-8; see also United States v. Kozeny, 541 F.3d 166, 172 (2d Cir.2008) (“[A] district court can suspend the running of a statute of limitations ... only if the limitations period has not yet expired.” (internal quotation marks and brackets omitted)). Here, the earliest fraudulent conduct alleged by the Government occurred in 2001. As explained above, therefore, absent reason to revisit the issue following discovery, under Section 3731(b)(2), the earliest claim the Government could bring was live until 2011. All of the FCA claims were thus live on October 14, 2008, when the WSLA was amended. It follows that, if those claims otherwise fall within the ambit of WSLA, then the statute of limitations on those claims has been suspended by that Act, and the claims are therefore timely. Second, Wells Fargo argues that the offenses alleged by the Government do not “involve[e] fraud or attempted fraud against the United States” within the meaning of the WSLA. (Reply 9; Oral Arg. Tr. 19-20). Although its plain text suggests that the Act applies to all frauds, the Supreme Court has held otherwise. See Bridges v. United States, 346 U.S. 209, 73 S.Ct. 1055, 97 L.Ed. 1557 (1953). Under Bridges, the WSLA only applies to offenses: (1) of “a pecuniary nature or of a nature concerning property,” id. at 216, 73 S.Ct. 1055; (2) “in which defrauding or attempting to defraud the United States is an essential ingredient of the offense charged,” id. at 221, 73 S.Ct. 1055 (internal emphasis omitted). The fraud at issue here — the submission to HUD of false claims for payment — is certainly of a pecuniary nature. Wells Fargo, however, argues that “defrauding or attempting to defraud the United States” is not an “essential ingredient” of some of the Government’s FCA claims — in particular, those based on allegations that Wells Fargo encouraged the reckless origination of loans without regard to HUD regulations, knowing that such conduct would lead to the submission of loans to FHA that did not qualify for FHA insurance. (Oral Arg. Tr. 19-20). This argument is foreclosed by the Supreme Court’s decision in United States v. Grainger, 346 U.S. 235, 73 S.Ct. 1069, 97 L.Ed. 1575 (1953), which held that an FCA violation constitutes fraud within the meaning of the WSLA. Id. at 243, 73 S.Ct. 1069. In arguing otherwise, Wells Fargo contends that the mens rea requirement for FCA claims is now broader than it was when Grainger was decided. (Oral Arg. Tr. 19-20). At the time Grainger was decided, the FCA prohibited only those claims that were submitted “ ‘knowing such claim to be false, fictitious, or fraudulent.’ ” Grainger, 346 U.S. at 241, 73 S.Ct. 1069 (quoting 18 U.S.C. § 287 (1952)) (emphasis added). Such claims, the Grainger Court reasoned, “involv[e] the element of deceit that is the earmark of fraud.” Id. at 243, 73 S.Ct. 1069. The current version of the FCA also provides that a defendant who submits a false claim must do so “knowingly” to incur liability. 31 U.S.C. § 3729(a)(1). But whereas the version of the Act at issue in Grainger did not provide a statutory definition of the term knowingly, the FCA as currently enacted defines knowing and knowingly to include not only “actual knowledge” of fraud, but also “deliberate ignorance” and “reckless disregard of the truth or falsity of the information.” False Claims Amendments Act of 1986, Pub. L. No. 99-562, 100 Stat. 3153. Citing this change, Wells Fargo argues that false statements made in reckless disregard of the truth do not constitute “fraud against the United States” as defined by Bridges. (Reply 9). But the Bank does not cite — and the Court has not found — any authority that would support drawing a distinction between false statements made in reckless disregard for the truth and false statements made with actual knowledge of their falsity. Grainger itself did not make any such distinction. See Grainger, 346 U.S. at 242-43, 73 S.Ct. 1069 (holding that the “making of claims upon the Government for payments induced by knowingly false representations .... involves] the element of deceit that is the earmark of fraud” without specifying a particular definition of knowingly). And courts have repeatedly defined fraud to include not only false representations made with “knowledge of the falsity,” but also those made with “a reckless disregard for the truth.” Conn. Nat’l Bank v. Fluor Corp., 808 F.2d 957, 962 (2d Cir.1987); see, e.g., Cohen v. S.A.C. Trading Corp., 711 F.3d 353, 359 (2d Cir.2013); Caputo v. Pfizer, Inc., 267 F.3d 181, 191 (2d Cir. 2001); see also Grainger, 346 U.S. at 244, 73 S.Ct. 1069 (“The combination of either falsity, fiction or fraud with the claim is enough.”). Notably, Wells Fargo itself states that the claims against it “sound in fraud.” (Wells Fargo Mem. 17). The Government’s FCA claims thus constitute fraud within the meaning of the WSLA. Third, Wells Fargo contends that the WSLA applies only to criminal offenses. (Reply 8-9). As originally promulgated, the WSLA did indeed apply only to crimes. Specifically, it suspended the statutes of limitations for any “offenses involving the defrauding or attempts to defraud the United States ... now indictable under any existing statutes.” Dugan & McNamara, Inc. v. United States, 127 F.Supp. 801, 802 (Ct.C1.1955) (internal quotation marks omitted) (emphasis added); see Halliburton, 710 F.3d at 179. In 1944, however, the “indictable under any existing statutes” language was removed. See Halliburton, 710 F.3d at 179. As currently enacted, then, the statute applies to “any offense ... involving fraud or attempted fraud against the United States.” 18 U.S.C. § 3287 (emphasis added). As the Fourth Circuit recently held, this change indicates that Congress intended to broaden the statute’s application to civil, as well as criminal, offenses. See Halliburton, 710 F.3d at 179-80; see also United States v. Wiesner, 216 F.2d 739, 741 (2d Cir.1954) (holding in the context of a different statute that “any offense which by act of Congress is prohibited in the interest of the public policy of the United States, although not ... punishable by criminal prosecution, but only by suit for penalty, is ... an offense against the United States” (internal quotation marks omitted)). With the exception of a 1952 Northern District of Alabama case, all courts that have considered the issue have agreed with the Fourth Circuit and concluded that the WSLA now applies to civil claims. See, e.g., Halliburton, 710 F.3d at 180 (collecting cases); United States v. Stryker Corp., Civ. No. 11-0041, 2018 WL 2666346, at *15 (W.D.Mo. June 12, 2013); BNP Paribas SA, 884 F.Supp.2d at 604; United States v. Kolsky, 137 F.Supp. 359, 361 (E.D.Pa.1955); Dugan & McNamara, 127 F.Supp. at 802. This Court agrees with the weight of authority: The WSLA applies to both civil and criminal claims. Finally, Wells Fargo suggests that, even if the WSLA applies in the civil context to claims of the sort at issue here, it should not apply “to matters involving domestic mortgage loan practices, having nothing to do with wartime contracting.” (Reply 9). At oral argument, the Bank went even further, suggesting that the actual text of the WSLA might limit the statute to offenses related to the war. (Oral Arg. Tr. 22-23). Not so. By its plain terms, the WSLA applies to three kinds of offenses: (1) fraud against the United States; (2) offenses related to “any real or personal property of the United States”; and (3) offenses “committed in connection with ... any contract, subcontract, or purchase order which is connected with or related to the prosecution of the war or directly connected with or related to the authorized use of the Armed Forces, or with any disposition of termination inventory by any war contractor or Government agency.” 18 U.S.C. § 3287. Wells Fargo suggests that the phrase “which is connected with or related to the prosecution of the war” limits not just the third category of offenses to which WSLA applies, but also the two preceding categories. (Oral Arg. Tr. 23). Such an interpretation, however, would violate “the grammatical rule of the last antecedent,” Barnhart v. Thomas, 540 U.S. 20, 26, 124 S.Ct. 376, 157 L.Ed.2d 333 (2003) (internal quotation marks omitted), pursuant to which “a limiting clause or phrase ... should ordinarily be read as modifying only the noun or phrase that it immediately follows,” Decker v. Nw. Envtl. Def. Ctr., — U.S. -, 133 S.Ct. 1326, 1343, 185 L.Ed.2d 447 (2013) (internal quotation marks omitted). There is no basis to disregard that rule here. Among other things, applying the WSLA to all frauds against the United States, including those unrelated to the war, accords with the purpose of the Act. The WSLA serves not only to allow the Government to combat fraud related to wartime procurement programs, but also “to give the government sufficient time to investigate and prosecute pecuniary frauds” of any kind “committed while the nation [is] distracted by the demands of war.” Prosperi, 573 F.Supp.2d at 449; see United States v. Smith, 342 U.S. 225, 228, 72 S.Ct. 260, 96 L.Ed. 252 (1952) (explaining that one purpose of WSLA “is that offenses occurring prior to the termination of hostilities shall not be allowed legally to be forgotten in the rush of the war activities”). Courts, including the Supreme Court in Grainger, have routinely applied the WSLA to fraud having nothing to do directly with the prosecution of war or the military. See, e.g., Grainger, 346 U.S. at 237-38, 73 S.Ct. 1069; Stryker Corp., 2013 WL 2666346, at *15; BNP Paribas SA, 884 F.Supp.2d at 593. In short, “it makes no difference that the fraud in this case [was] ... unrelated to the Iraqi or Afghani conflicts. In the few cases since Grainger in which the government has successfully invoked the Suspension Act, the absence of a connection between the fraud and wartime procurement has played no part.” Prosperi, 573 F.Supp.2d at 442. In sum, the WSLA applies to the FCA claims in this case. Accordingly, any claims that were live as of October 14, 2008, when the WSLA was amended to apply to congressional authorizations for the use of military force, are timely. Given the Court’s holding above that the Government can, in the absence of contrary evidence developed during discovery, rely on the ten-year statute of limitations for FCA claims set forth in Section 3731(b)(2), it follows that there is no basis, at this stage of the litigation, to dismiss any of the FCA claims as untimely. 2. The Common Law Claims By contrast, many of the Government’s common law claims are time barred. The Government alleges tort claims (breach of fiduciary duty, negligence, and gross negligence) as well as quasi-contract claims (unjust enrichment and mistake of fact). As the Government concedes, the WSLA does not apply to these claims (nor, of course, do the statute of limitations provisions of the FCA). (See Oral Arg. Tr. 33). Instead, the statute of limitations for the Government’s tort claims is three years, and the statute of limitations for its quasi-contract claims is six years. See 28 U.S.C. § 2415. Thus, any of the Government’s breach of fiduciary duty, gross negligence, or negligence claims that arose prior to June 25, 2009 (three years before the tolling agreement) and any of its unjust enrichment or mistake of fact claims that arose prior to June 25, 2006 (six years before the tolling agreement) would appear to be time barred. In arguing otherwise, the Government relies on Title 28, United States Code, Section 2416(c), which, as noted above, exempts from the statute of limitations for claims brought by the Government “all periods during which ... facts material to the right of action are not known and reasonably could not be known by an official of the United States charged with the responsibility to act in the circumstances.” (Gov’t Mem. 64-65 n. 34). Based on this provision, the Government contends, the common law claims are timely “for the same reasons set forth with respect to the FCA claims.” (Id.). This argument does not survive scrutiny. As explained above, while the only relevant government official for purposes of the FCA’s tolling provision is the Attorney General, any number of officials may constitute “an official of the United States charged with the responsibility to act” within the meaning of Section 2416(c). As relevant here, the HUD Inspector General is plainly one such official. See, e.g., 5 U.S.C. app. 3 § 4 (charging “each Inspector General” with, among other things, “preventing and detecting fraud and abuse” and aiding in the “identification and prosecution of participants in such fraud and abuse”); Island Park, 791 F.Supp. at 372 (“As a general proposition, the responsible official would be the official who is also responsible for the activity out of which the action arose.” (internal quotation marks omitted)). Additionally, the 2004 audit report produced by the HUD Inspector General is plainly sufficient to demonstrate that the relevant facts underlying this action were known to him by 2004. Among other things, the HUD Inspector General examined seventy-four defaulted loans originated by Wells Fargo, and found that the Bank “did not adhere to HUD requirements and prudent lending practices when processing 61 of the 74 loans.” (Baruch Decl. Ex. F, at iii). In particular, the Inspector General found that the vast majority of the examined loans contained at least one of the following deficiencies: unsupported assets, unsupported income, inadequate qualifying ratios, inadequate documentation, unallowable fees charged to the borrowers, derogatory credit information, underreported liabilities, potential fraud indicators, and improper approval method followed when using an automated underwriting system.... The deficiencies occurred because Wells Fargo’s management did not take appropriate action to ensure that staff adhered to HUD/FHA requirements when originating FHA loans. (Id.). In other, words, the audit discovered precisely the sort of misconduct alleged in this lawsuit. At a minimum, therefore, the HUD Inspector General was privy to “sufficient critical facts to cause a reasonable person to investigate” the possibility of bringing common law claims. United States ex rel. Frascella v. Oracle Corp., 751 F.Supp.2d 842, 852 (E.D.Ya.2010) (internal quotation marks omitted). In short, Section 2416(c) provides no support for the Government’s arguments with respect to the timeliness of its common law claims. Accordingly, any and all of its tort claims that arose prior to June 25, 2009, and any and all of its quasi-contract claims that arose prior to June 25, 2006, are untimely and dismissed. C. Rule 9(b) Next, Wells Fargo argues that the Government’s fraud claims should be dismissed for failure to satisfy the requirements of Rule 9(b). That Rule provides that a party alleging fraud “must state with particularity the circumstances constituting fraud or mistake.” Fed.R.Civ.P. 9(b). Scienter (or knowledge), however, “may be alleged generally.” Id. “The purpose of Rule 9(b)’s specificity requirement is to provide the defendant with fair notice of a plaintiffs claim and adequate information to frame a response.” U.S. ex rel. Tiesinga v. Dianon Sys., Inc., 231 F.R.D. 122, 123 (D.Conn.2005); see Rombach v. Chang, 355 F.3d 164, 171 (2d Cir.2004). Generally, to satisfy Rule 9(b), a complaint must “(1) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent.” Rombach, 355 F.3d at 170. Whether a complaint complies with the Rule, however, depends “upon the nature of the case, the complexity or simplicity of the transaction or occurrence, the relationship of the parties and the determination of how much circumstantial detail is necessary to give notice to the adverse party and enable him to prepare a responsive pleading.” In re Cardiac Devices Qui Tam Litig., 221 F.R.D. 318, 333 (D.Conn. 2004) (internal quotation marks omitted). In particular, “where the alleged fraudulent scheme involved numerous transactions that occurred over a long period of time, courts have found it impractical to require the plaintiff to plead the specifics with respect to each and every instance of fraudulent conduct.” Id.; see United States ex rel. Bledsoe v. Cmty. Health Sys., 501 F.3d 493, 509-10 (6th Cir.2007); State Farm Mut. Auto. Ins. Co. v. James M. Liguori, M.D., P.C., 589 F.Supp.2d 221, 237 (E.D.N.Y.2008); United States ex rel. Taylor v. Gabelli, 345 F.Supp.2d 313, 326 (S.D.N.Y.2004); Cardiac Devices, 221 F.R.D. at 333 (collecting eases); United States ex rel. Franklin v. Parke-Davis, 147 F.Supp.2d 39, 47 (D.Mass.2001). Applying these standards here, the allegations in the Amended Complaint are sufficient to satisfy Rule 9(b). The Government in this case alleges that Wells Fargo engaged in two schemes involving thousands of false or fraudulent claims over a period of almost ten years: (1) ‘Wells Fargo’s reckless underwriting and certification of loans for FHA insurance from May 2001 through October 2005”; and (2) “the bank’s knowing failure to report to HUD as required FHA loans with material underwriting violations from 2002 through 2010.” (Gov’t Mem. 19; see Am. Compl. ¶¶ 45, 82, 147, 170). In these circumstances, it would be impractical, if not impossible, to require that the Government plead the details of each and every false claim. Instead, the Government may plead each scheme “with particularity, and provide!] examples of specific false claims submitted to the government pursuant to that scheme.” Bledsoe, 501 F.3d at 510; see also, e.g., United States v. Rogan, 517 F.3d 449, 453 (7th Cir.2008) (rejecting the argument that “the district judge had to address each of the 1,812 claim forms” at issue and holding that “[statistical analysis should suffice”); Assured Guar. Mun. Corp. v. Flagstar Bank, FSB, 920 F.Supp.2d 475, 512 (S.D.N.Y.2013) (holding that the plaintiff could use statistical sampling to prove liability). Such examples, however, “will support more generalized allegations of fraud only to the extent that [they] are representative samples of the broader class of claims.” Bledsoe, 501 F.3d at 510. If the examples are sufficiently representative, “the defendant will, in all likelihood, be able to infer with reasonable accuracy the precise claims at issue by examining the ... representative samples, thereby striking an appropriate balance between affording the defendant the protections that Rule 9(b) was intended to provide and allowing [plaintiffs] to pursue complex and far-reaching fraudulent schemes without being subjected to onerous pleading requirements.” Id. at 511. The Government’s allegations satisfy these standards. With respect to the reckless origination scheme, the Government specifically alleges the practices by which Wells Fargo sought to increase its loan originations without regard to whether the practices or the loans themselves complied with HUD regulations (Am. Compl. ¶¶ 44-49, 85-86); the resulting increase in loans that evidenced material violations of these regulations (id. ¶¶ 50, 52-54, 84, 87-89); Wells Fargo’s decision to continue its loan origination practices, despite knowledge of these violations (id. ¶¶ 44-47, 51, 84-89); and its motive for doing so (id. ¶¶3, 5, 45, 82, 117). Additionally, the Government provides ten examples of insurance claims, identified by FHA case number, paid by HUD on loans the Government alleges Wells Fargo falsely certified as eligible for FHA insurance as a result of this scheme. (Am. Compl. ¶¶ 57-81, 91-115). These examples, drawn from throughout the time period the Government alleges the reckless origination scheme occurred, appear sufficient “in all material respects, including general time frame, substantive content, and relation to the allegedly fraudulent scheme, ... such that a materially similar set of claims could have been produced with a reasonable probability by a random draw from the total pool of all claims.” Bledsoe, 501 F.3d at 511. Combined with the allegations setting forth in detail the reckless origination scheme, they are, therefore, sufficient to satisfy Rule 9(b). See, e.g., State Farm, 589 F.Supp.2d at 237-38 (holding that a complaint that described in detail the fraudulent scheme alleged and provided examples of “many specific claims that plaintiff allege[d] were fraudulent” satisfied rule 9(b)); Carey v. Berisford Metals Corp., 90 Civ. 1045(JMC), 1991 WL 44843, at *5 (S.D.N.Y. Mar. 28, 1991) (holding that where a fraudulent scheme is pleaded with sufficient particularity to “give [the defendant] fair notice of the claim asserted,” the pleading of “a few examples” of the allegedly false or fraudulent claims submitted as a result of that scheme is sufficient); see also Harrison v. Westinghouse Savannah River Co., 176 F.3d 776, 784 (4th Cir.1999) (“A court should hesitate to dismiss a complaint under Rule 9(b) if the court is satisfied (1) that the defendant has been made aware of the particular circumstances for which [it] will have to prepare a defense at trial, and (2) that plaintiff has substantial prediscovery evidence of those facts.”). The allegations regarding the second scheme — the Bank’s alleged failure between 2002 and 2010 to report loans •with material underwriting violations to HUD — even more clearly satisfy Rule 9(b). The Government has pleaded with particularity HUD’s quality control and self-reporting requirements (Am. Compl. ¶¶ 24-30); Wells Fargo’s process for reviewing loans {id. ¶¶ 31-36); and its deliberate failure to report those loans that evidenced a material violation of HUD regulations {id. ¶¶ 51, 55, 84, 122-130, 132). In addition, the Government has provided not merely a representative sample, but rather a list of all false claims, identified by loan number, alleged to have been submitted as a result of this scheme. {Id. Exs. B, C). These allegations plainly satisfy Rule 9(b). See, e.g., Allstate Ins. Co. v. Lyons, 843 F.Supp.2d 358, 372-73 (E.D.N.Y.2012) (holding that where plaintiff “explain[ed] in detail the contours of the fraudulent scheme it allege[d]” and provided “a series of charts that include each of the charges submitted by the defendants that it believe[d] were fraudulent,” plaintiffs complaint satisfied Rule 9(b)); Beth Israel Medical Center v. Smith, 576 F.Supp. 1061, 1070 (S.D.N.Y.1983) (holding that a complaint “specifying] the nature and operation of’ an allegedly fraudulent scheme and the “exact dates and amounts of many of the alleged payments” satisfied Rule 9(b)). Wells Fargo’s co