Identifying a Ponzi Scheme - The Nugget of Glass in a Bowl of Diamonds

If an economic sink hole brought on by creativefor. Take a look at the many hedge funds that are
financing and lax regulatory controls weren't enough,now defunct because they were not only suffering
there's nothing like straight forward criminal actions tohuge losses in the market, but their overhead never
really paralyze investors. As a fund manager of anchanged, and their only choice was to close up shop.
extremely transparent fund, there is nothing thatGetting back to sound economics is what you really
brings out more fury in me than a few bad applesshould be looking for in an investment fund instead of
scaring people to a point of not even wanting to putcorner, glass office.
their hand in the barrel. Sure Madoff is the posterIndependent Auditor: I can see the benefits of having
child, but there are a host of others that havean independent auditor, but it is another issue when
created schemes of the Ponzi sort that are equallythe auditor is possibly in the back pocket of the fund
as devastating to the people invested in them.being audited. In Stanford's case, the independent
Now Stanford Financial is being accused ofauditor was in Antigua, and though I am not well
misrepresenting the safety and security of their C.D.versed on the auditing sector, I have a sneaking
offering while also providing returns that the SEC issuspicion that Antigua is not a hot bed of precise
called in its filing "improbable if not impossible". Inauditing firms. I would argue that an independent
other words, they are saying it's fraud. In the midstauditor is a god idea in many cases, but who do you
of all this fraud, we are seeing fingers pointing theend up choosing for the independent auditor? There
blame at every government regulatory body possible;just seems to be a barrage of unethical behavior
we are hearing a battle cry for some sort ofeven from some of the largest firms. For instance,
protection through regulation. I do believe that thethe UBS case in which they have admitted to
creators of these fraudulent schemes should meetconspiring to defraud the Internal Revenue Service
the firing squad, but it's important to understand thatby helping investors hide money in Swiss banks. An
the people investing in these schemes really didn'tinstitution of this size must surely have had one of
understand the investments in the first place.the best independent auditors in the business. The
In Madoff's case, he was creating such a complexproblem is that you only get to audit what you have
illusion, that unless you were in the business youaccess to and can see. I am guessing nobody at UBS
wouldn't understand that it was all a lie. We arehanded the auditors a book and said, "Oh yes, this is
reading all kinds of accounts where Madoff'sthe Illegal Swiss Bank Account Ledger for US
investment strategy even had many fund managersCitizens."
in the industry baffled. Some of these managersExclusivity: I think this is the portion of the Madoff
were smart enough to know a black hole when theystory that creates an inordinate amount of head
saw it and walked away. Others either figuredshaking. Nothing like using an elementary school tactic
Madoff was a genius and you shouldn't ask to fixof telling people that you don't want to be their
something that you thought wasn't broken, or theyfriend which in turn makes them want your friendship
were so intimidated by him that they thought tooeven more. Take this into the adult world of
many questions would have either insulted him orinvesting and think about the psychological aspects of
made themselves look foolish.an investor going into an investment agreement with
There is nothing like admitting when you don't knowMadoff. The interviews of burned Madoff Investors
something and for example, I have a pretty goodtalk about how it took persuasion and references to
understanding of the stock market but not enoughget Madoff to consider taking new investors on. By
of an understanding to invest heavily in it, andthe time the investors were ready to invest, they
therefore I don't. I do have an understanding thatwere already feeling that they were lucky Madoff
commodities like precious metals and oil are limited, sowas even going to allow them to invest. This ends up
the natural economist in me understands the longcausing a lack of questions being asked in a "don't
term supply and demand story. Again, if I understandbite the hand that is going to make you huge
it I invest in it, and if I don't I won't. It may seem likereturns" kind of way. These investors had the
an elementary philosophy, but one that has madepsychological deck stacked against them from the
and saved investment dollars over the years.beginning, and then in a typical Ponzi type of way,
What is on everyone's mind right now is how youbrought more investors in under the same conditions.
can tell if something is a Ponzi scheme or just plainUnderstanding the Model: Western culture celebrates
fraudulent. There have been all kinds of opinions onand marvels at genius, and this type of mentality has
this and like most knee jerk reactions they are notreally helped professionals like doctors create their
very rational. I thought it would be helpful for all of usfamous "God complexes". However when it comes
to re-examine some fundamental considerationsto being sick, I am just fine with the God complex
when weighing an investment opportunity.since most of us understand money better than we
Track Record: A fund manager's track record, inunderstand medicine. Financial instruments no matter
most cases, gives a history of performance and thehow complex come down to one very basic premise.
appearance of being reliable. The question is whetherI invest money, and I am going to receive that
or not you can you identify if a fund or its managersmoney back with some sort of profit. This is not to
are on the up and up from their track record. Madoffsay that everything goes as planned, but every
had a pretty good track record and he used theinvestment should be able to be followed from
confidence built from that track record to deceivebeginning to end to see how that profit and original
people. I do agree that a track record is a valuableprincipal is going to be returned. If you don't
gauge when tempered with other qualifying factors,understand how the money is being made, then why
but it is not the end all be all of litmus tests for trust.are you comfortable investing your money? A lot of
Fund Structure: Everyone is up in arms becausepassive investors feel like investing with a money
Madoff wasn't a registered investment advisor. Youmanager should be a Wizard of Oz experience and
would have to have 1950's style innocence to believeyou should never look behind the curtain. Being a
the government would somehow have discovered hisfund manager myself I am completely passionate
deception all because he was registered in a bloatedabout asking questions and I not only pull questions
government database. Whether he was registered orout of interested investors in our fund, but I ask
not, he was still going to deceive people and he wasquestions for them. There needs to be an open
still going to get away with it for as long as he did.dialogue anytime someone is investing your money
Government registration of either advisors or fundsand you should feel comfortable contacting them at
doesn't mean anything. The government allows for aanytime to ask any questions. It's what the job
Regulation D filing that permits private investmententails and if anyone tells you different, start running.
funds not to be registered with the SEC. Before youBut even before this you need to understand how
go and start writing your congressman to ban allthey are actually generating the returns. During the
private funds, you might want to stop typing.summer of 2007, a childhood friend of mine kept
Gauging integrity based on whether a fund is privatetelling me about the Agapi Fund being run my Nick
or public is a pretty naïve view when youCosmos, and the tremendous returns he was
consider we have had Enron, Worldcom, Subprimereceiving through them. Since the Agapi Fund was
Mortgage Backed Securities (MBS) rated AAA, and asupposed to be acting as a bridge lender, which is the
whole host of other world class schemes that havesame model as my own Fund, I knew something
taken down not only their shareholders, but in thewas wrong because I truly understand how returns in
MBS case, it has now taken down the globalthis model are generated. Since the Agapi fund was
economy. Remember, these were all publically tradedpromoting returns five times higher than our own
and not private. In the Stanford scheme all of thefund, I kept telling my friend that these returns were
Stanford companies were either licensed ornot possible and he should ask for his investment
registered in the United States. So much for theback immediately since it sounded like an investment
government registration theory to gauge investmentscheme. Some time after that conversation, Nick
safety.Cosmos was indicted on running a Ponzi Sceme and
Appearances: The old saying goes, believe nothingmy dear friend is out $100,000. He didn't understand
that you hear and half of what you see. Justhow the returns were being generated and
because something looks or feels legitimate, doesn'ttherefore, he didn't understand how he was being
necessarily mean it is. Madoff had what appeared todeceived until it was too late. Transparency is
be a mini trading floor and this was probably createdsecurity.
to put any investor concerns to rest. Though if youIt's easy to see the moral of the story. There are no
speak to anyone in the business they will tell youquick answers in identifying a fraudulent investment
that most trading floors are about as big as a footballscheme and the typical answers are not always the
field and packed with frantic people. For my taste,right ones. The only thing that you can really rely on
the last thing I would like to see in any investmentis your own common sense, and hopefully the above
strategy is an excessive amount of overhead thatpoints help you organize that common sense in a
needs to be paid for by either investor returns orway that creates an early warning detection system.
higher risk strategies. The thought of a giant office inSaid another way, don't rely on your neighbor, friend,
a prestigious part of town, or a building with a logoor even investment advisor to use their common
on it makes me cringe when I think about the costs.sense for your best interests. It's like volunteering to
Again, as an investor you always need to considerlet yourself hang off the edge of the Grand Canyon
how all of these overhead costs are going to be paidwith someone else holding the rope.