{"id":34158,"date":"2020-10-31T15:07:31","date_gmt":"2020-10-31T19:07:31","guid":{"rendered":"http:\/\/stateofthenation.co\/?p=34158"},"modified":"2020-10-31T15:07:31","modified_gmt":"2020-10-31T19:07:31","slug":"now-we-hear-that-the-biden-crime-family-was-involved-with-a-fraudulent-hedge-fund","status":"publish","type":"post","link":"http:\/\/stateofthenation.co\/?p=34158","title":{"rendered":"Now we hear that the Biden Crime family was involved with a fraudulent hedge fund."},"content":{"rendered":"<h2>Paradigm Global, the Bidens and allegedly fraudulent hedge funds \u2013 a summary<\/h2>\n<div class=\"post-header\">\n<div class=\"post-header-line-1\">John Hempton<\/div>\n<\/div>\n<div id=\"post-body-4117517403107379076\" class=\"post-body entry-content\">\n<div><\/div>\n<div>This is a summary of the situation to put all the posts in one place. \u00a0You can read this as an alternative to the other posts \u2013 though I will leave the original posts up for posterity. \u00a0There are some versions on the web that are\u00a0<a href=\"http:\/\/libertymaven.com\/2009\/05\/02\/scandals-the-jane-harman-nancy-pelosi-aipac-alberto-gonzales-power-ranger-spy-plot-and-the-biden-boys\/5544\/\">wildly inaccurate<\/a>. \u00a0All I will assert is that the Biden&#8217;s firm has been shockingly sloppy about basic due diligence issues. \u00a0Unsurprisingly the inaccurate versions are coming from right-wing politics driven blogs (who like the idea that Biden&#8217;s family is in trouble) and who reinvent complex facts to fit their simple world view. \u00a0Some of the financial blogs have been\u00a0<a href=\"http:\/\/zerohedge.blogspot.com\/2009\/04\/is-joe-biden-associated-with-hedge-fund.html\">much better<\/a>.<\/div>\n<div><\/div>\n<div>The short version is that an allegedly fraudulent hedge fund (Ponta Negra) shared an office and a phone number and a common marketer (Jeff Schneider) with Paradigm Global a fund of hedge funds owned by the Vice President\u2019s family.<\/div>\n<div><\/div>\n<div>Paradigm Global have said that they were subtenants \u2013 and that they were introduced via their common marketer.<\/div>\n<div><\/div>\n<div>The story however is murkier than that simple explanation. \u00a0However it is consistent with repeated and extreme sloppiness by the Vice President&#8217;s family and the fund of hedge funds they control.<\/div>\n<div><\/div>\n<div>First we run through the players in this drama.<\/div>\n<div><\/div>\n<div><span class=\"Apple-style-span\">1. \u00a0The small alleged fraudulent hedge fund: Ponta Negra\u00a0<\/span><\/div>\n<div><\/div>\n<div>Ponta Negra is a hedge fund run out of a\u00a0<a href=\"http:\/\/www.whitepages.com\/search\/FindPerson?extra_listing=mixed&amp;form_mode=opt_b&amp;post_back=1&amp;firstname_begins_with=1&amp;firstname=krancesco&amp;name=rusciano&amp;street=&amp;city_zip=&amp;state_id=CT&amp;localtime=survey\">unit<\/a>\u00a0in Connecticut that just had its assets frozen by a Federal Judge and had the SEC accuse it of fraud. \u00a0The Justice Department has yet to file criminal charges and unless criminal charges are filed you would have to wonder what the point of the current crackdown is.<\/div>\n<div><\/div>\n<div>The alleged fraud is brazenly simple. \u00a0The company simply produced fake return numbers and doctored accounts from their counterparty brokers to over-represent funds under management. The last set of published return numbers I have access to is here.<\/div>\n<div><\/div>\n<div><a href=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1qSUd7ajI\/AAAAAAAAAP4\/BbwAXLzYBUI\/s1600-h\/Pomta+Negra+Returns.jpg\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331534396840962610\" src=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1qSUd7ajI\/AAAAAAAAAP4\/BbwAXLzYBUI\/s400\/Pomta+Negra+Returns.jpg\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div>(click for detail and you can find the original\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14713748\/PontaNegraFeb09\">here<\/a>)<\/div>\n<div><\/div>\n<div>Ponta Negra was run by Francesco Rusciano \u2013 who is also alleged to have faked trading data whilst working for UBS. \u00a0Francesco Rusciano sometimes goes as Krancesco.<\/div>\n<div><\/div>\n<div>Ponta Negra was marketed by Jeff Schneider and Jared Toren. \u00a0More on those individuals later.<\/div>\n<div><\/div>\n<div><\/div>\n<div><span class=\"Apple-style-span\">2. \u00a0The fund of funds owned by Joe Biden\u2019s family: Paradigm Global\u00a0<\/span><\/div>\n<div><\/div>\n<div>Paradigm Global is a fund of hedge funds headquartered on the 17th Floor of 650 Fifth Avenue. It was founded by Dr James Park who for a while had a reputation as a guru on hedge funds. Paradigm in marketing documents claim particular expertise in \u201cdue diligence\u201d allowing them to source the best hedge fund managers.<\/div>\n<div><\/div>\n<div>Paradigm claimed as recently as 2006 in marketing documents that it had over $1.5 billion under management and 28 full time staff as well as offices in New York, Monte Carlo and Tokyo. Now (according to its IARD filing) it has about 300 million in 210 discretionary accounts and 6-10 employees. \u00a0There are no offshore offices.<\/div>\n<div><\/div>\n<div>As recently as a few days ago their website claimed that they had never had a down year and that their volatility had decreased over time. \u00a0This is not impossible \u2013 but if it is true that last year was a year of decreased volatility then the performance is truly remarkable. \u00a0Consistently positive returns with low volatility make an 80% reduction in funds under management somewhat difficult to explain.<\/div>\n<div><\/div>\n<div>Paradigm was purchased by Hunter Biden and James Biden who are the Vice President\u2019s son and brother respectively. \u00a0Hunter Biden was CEO was for a brief time at the end of 2006 and in early 2007. \u00a0The original press reports implied that was a permanent position but it was later described as an interim position. \u00a0The leadership of the firm since then has been moveable.<\/div>\n<div><\/div>\n<div>In the latest\u00a0<a href=\"http:\/\/www.finra.org\/Investors\/ToolsCalculators\/BrokerCheck\/index.htm\">IARD filings<\/a>\u00a0Hunter and James Biden are listed as owners. \u00a0Markus Karr is listed as the chief investment officer and CEO. \u00a0 Dr Park is listed as an investment consultant.<\/div>\n<div><\/div>\n<div>Hunter and James Biden purchased Paradigm when they wanted to get out of the lobbying business. \u00a0Having your son as a highly paid registered lobbyist was incompatible with Joe\u2019s (Vice) Presidential ambitions. \u00a0The purchase was problematic and litigated. \u00a0During the litigation James Biden signed an amazing affidavit which you can find\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14758437\/James-Biden-sworn-statement\">here<\/a>.<\/div>\n<div><\/div>\n<div>In it he alleged a few things including that:<\/div>\n<div><\/div>\n<div>\n<ul>\n<li>The Paradigm Hedge Funds had only between two and three hundred million dollars under management, which were leveraged to over five hundred million, not the more than $1.5 billion under management represented to us by Lotito and Fasciana.<\/li>\n<\/ul>\n<\/div>\n<div>\n<ul>\n<li>The returns on the Paradigm Hedge Funds were not as represented to us by Lotito and Fasciana; and<\/li>\n<\/ul>\n<\/div>\n<div>\n<ul>\n<li>The primary manager of the funds, Dr. James Park, had an apparent substance abuse problem and had been an absentee manager for several years&#8230;<\/li>\n<\/ul>\n<\/div>\n<div><\/div>\n<div>These are things which is would make continued ownership of the business untenable. \u00a0If James Biden is alleging that the returns have been misrepresented to clients and potential clients then he is alleging a crime. \u00a0It\u2019s a crime not fundamentally different the crime which Ponta Negra is alleged to have committed. \u00a0The only responsible course of action for the Bidens would be \u2013 after being made aware of the problem \u2013 call the regulatory authorities, sack the offending staff and write a letter to clients indicating that they can have what is left of their money. \u00a0Even a small misstatement of returns to prospective clients constitutes a crime.<\/div>\n<div><\/div>\n<div>If the Bidens were to continue to own the management company \u2013 and to take the benefit of that ownership \u2013 without taking these steps then the Bidens are accessories after the fact to that crime.<\/div>\n<div><\/div>\n<div>The alternative hypothesis (clearly possible) is that the returns were misrepresented to the Bidens but were not misrepresented to clients. \u00a0Then no crime has been committed on clients and it is possible to keep running the fund.<\/div>\n<div><\/div>\n<div>Anyway given one possible misrepresentation I figured I would go looking for other misrepresentations.<\/div>\n<div><\/div>\n<div>If the number and depth of the staffing was misrepresented when potential customers did due diligence that would also constitute fraud. \u00a0Certainly there is a reasonable possibility of that. \u00a0For instance this due diligence document asserts 28 full time staff \u2013 and names them. \u00a0Here is an organisational chart:<\/div>\n<div><\/div>\n<div><a href=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2PBjl-M8I\/AAAAAAAAAQI\/_qM1sFuD_ao\/s1600-h\/Paradigm+org+chart.jpg\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331574790773683138\" src=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2PBjl-M8I\/AAAAAAAAAQI\/_qM1sFuD_ao\/s400\/Paradigm+org+chart.jpg\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div><\/div>\n<div>(click for detail &#8211; you can find the original in\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14758478\/PGA-Presentation\">this document<\/a>)<\/div>\n<div><\/div>\n<div>This organisational chart differs dramatically from the current structure as described in IARD filings (6-10 employees). \u00a0It is unclear when the employee numbers were scaled back so dramatically. \u00a0Moreover it is very difficult to trace many of these employees in FINRA\u2019s database which means if the people exist they are no longer licensed within the industry. \u00a0Again it is possible that the firm used to have 28 staff and now has 6-10. \u00a0Indeed the rapid decline in staff numbers might be the reason that there was space to sublet to Ponta Negra.<\/div>\n<div><\/div>\n<div>Another inconsistency worries me. \u00a0As at August 2005 Paradigm warranted that all custody of client asset assets \u2013 including subscription and redemption funds and the computation of net assets is done by reputable third party custodians. \u00a0This is an important element of due diligence for prospective investors. \u00a0See this extract\u2026<\/div>\n<div><\/div>\n<div><a href=\"http:\/\/1.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2Q3B9xmoI\/AAAAAAAAAQQ\/lMyw6QulADg\/s1600-h\/Paradigm+stated+custody.JPG\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331576808971278978\" src=\"http:\/\/1.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2Q3B9xmoI\/AAAAAAAAAQQ\/lMyw6QulADg\/s400\/Paradigm+stated+custody.JPG\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div><\/div>\n<div>(click for detail &#8211; the original can be found\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14758658\/Due-Diligence-SV-Onshore-0809051\">here<\/a>)<\/div>\n<div><\/div>\n<div><\/div>\n<div>This looks kosher and highly comforting except that I can\u2019t find out much information about Global Fund Services. \u00a0[I looked in the obvious places like the White Pages.] \u00a0Folio Administrators however does have a presence and I have written to them to confirm their role. \u00a0I will report any reply&#8230; \u00a0<span class=\"Apple-style-span\">Reply reported below&#8230; see postscrips. \u00a0Folio has confirmed the relationship which is highly comforting&#8230;<\/span><\/div>\n<div><\/div>\n<div>My main concern though is that these custody details differ dramatically from the (much later) IARD filing. \u00a0Here is the extract from the IARD filing:<\/div>\n<div><\/div>\n<div><a href=\"http:\/\/3.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1yOsLdtMI\/AAAAAAAAAQA\/-wQh0WsraE4\/s1600-h\/IARD+filing+-+Paradigm+Global+custody1.JPG\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331543130579514562\" src=\"http:\/\/3.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1yOsLdtMI\/AAAAAAAAAQA\/-wQh0WsraE4\/s400\/IARD+filing+-+Paradigm+Global+custody1.JPG\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div><\/div>\n<div>(Click for detail and you can find the original\u00a0<a href=\"http:\/\/www.adviserinfo.sec.gov\/\">here<\/a>\u00a0by following obvious prompts.)<\/div>\n<div><\/div>\n<div>In the IARD filing they handle client cash and a related person handles client securities. \u00a0Moreover that related person is not a broker dealer subject to SIPC protection.<\/div>\n<div><\/div>\n<div>Whilst holding client assets in house is not a certain indicator of fraud it is a huge red flag. \u00a0The lesson of Madoff (or Stanford for that matter) was that a fund that actually controls custody of client assets is dangerous \u2013 whereas a fund which has custody at a reputable independent custodian or prime broker is unlikely to outright steal your money (though they sure can lose it). \u00a0The really big frauds have been funds with inadequate external controls over custody. \u00a0Bayou for example was another hedge fund with controlled its own custodian.<\/div>\n<div><\/div>\n<div>There are legitimate reasons why a financial institution might use in-house custody. \u00a0A bank for instance really does take custody of your cash. \u00a0However I can\u2019t see any good reason for bringing custody in-house as your staff numbers shrank by two thirds and your business model remains unchanged. \u00a0However telling people you have third party custody when they do due diligence but not having it is fraud. \u00a0I presume no fraud and that they must have bought the custody in house possibly to save money.<\/div>\n<div><\/div>\n<div>However I am still worried about custody. \u00a0<a href=\"http:\/\/www.sec.gov\/Archives\/edgar\/data\/1338646\/000100472608000237\/audit.txt\">This audit report<\/a>\u00a0lodged with the SEC specifically mentions material weakness with respect to safeguarding of securities. \u00a0Having material weakness in custody arrangements allows theft. \u00a0That makes it a very bad audit report.<\/div>\n<div><\/div>\n<div>All of these red flags \u2013 the decline in staff numbers (28 to 6-10), the decline in funds under management (over $1.5 billion to 200-300 million), the returns that James Biden alleged were misrepresented and the unusual change in customer asset custody probably happened before the Bidens had purchased the management company. \u00a0They must have all happened despite the fund making positive returns better than indices and with reduced volatility (as claimed on the website).<\/div>\n<div><\/div>\n<div>There is one more red flag \u2013 again pre-Biden ownership \u2013 which I have not previously discussed on this blog. \u00a0That is the Canadian fund called Paradigm Global. \u00a0Canadian Paradigm Global was associated with James Park\u2019s Paradigm Global and often claimed that James Park (then the hedge fund guru) had a consulting relationship with them. \u00a0That relationship ended and the Canadian Paradigm changed its name to Portus Alternative Asset Management. \u00a0Portus was later discovered to be a ponzi which \u2013 in typical ponzi fashion \u2013 paid its distributors well over the odd to distribute its toxic product. \u00a0James Park was clearly involved in this fund in its beginning and lent his reputation to it \u2013 but he was safely (and probably reasonably) distant by the denouement. \u00a0You can find press reports\u00a0<a href=\"http:\/\/www.investmentnews.com\/article\/20050228\/SUB\/502280714\">here<\/a>,\u00a0<a href=\"http:\/\/analystsexposed.blogspot.com\/2007\/11\/portus-alternative-asset.html\">here<\/a>\u00a0and\u00a0<a href=\"http:\/\/caymannetnews.com\/2005\/10\/940\/foreign.shtml\">here<\/a>.<\/div>\n<div><\/div>\n<div><span class=\"Apple-style-span\">Player 3 \u2013 the distributor of dodgy hedge funds: Onxy Capital and Jeff Schneider<\/span><\/div>\n<div><\/div>\n<div>Onyx Capital was how I found this mess. \u00a0Onyx \u2013 was a firm based in Austin Texas but also subleasing space from Paradigm. \u00a0Onyx was a marketer of hedge funds to relatively unsophisticated clients. \u00a0I say \u201cwas\u201d because Onyx appears to be running dead \u2013 and its\u00a0<a href=\"http:\/\/www.onyx-cap.com\/\">website<\/a>\u00a0died a few days before Ponta Negra was closed by SEC action.<\/div>\n<div><\/div>\n<div>The typical sort of client was someone who had sold a medium sized business for a lot of money (a few million) and was looking for investment advice including what the smart money (that with a New York address presumably) was doing. \u00a0Sharing a New York address with a firm owned by the Bidens probably helped.<\/div>\n<div><\/div>\n<div>The principal of Onyx was Jeff Schneider. \u00a0To complicate research he spells his name multiple ways. \u00a0Onyx \u2013 being a seller of hedge funds and financial advisor \u2013 was almost certainly required to be licensed but never was.<\/div>\n<div><\/div>\n<div>Jeff Schneider has a past which would raise eyebrows in most people doing a due diligence. \u00a0He was \u201callowed to resign\u201d from Merrill Lynch after allegedly being party to fraud by foreigners. \u00a0In that case he denies guilt. \u00a0He was sacked from CIBC, fined and given a 90 day industry suspension for allegedly defrauding CIBC\u2019s bonus system. \u00a0In that case he neither accepted nor denied guilt but accepted the fines. \u00a0You can find the details in his\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14781691\/FINRA-Check-on-Jeff-Schneider2\">FINRA broker registration statement<\/a>.<\/div>\n<div><\/div>\n<div>Anyway Jeff Schneider was a full time employee of Paradigm Global from 2004 to 2007 or 2008 (his FINRA regulatory records say Feb 2008 but\u00a0<a href=\"http:\/\/blogs.reuters.com\/felix-salmon\/2009\/04\/30\/when-bloggers-uncover-ponzis\/\">Felix Salmon gives a different date<\/a>). \u00a0After that he worked for other firms, notably\u00a0<a href=\"http:\/\/www.puritansecurities.com\/\">Puritan Securities<\/a>. \u00a0He also set up Onyx \u2013 but his FINRA record states that was working at Onyx only from March 2009 though other records suggest he established Onyx much earlier. \u00a0I have an email from Ponta Negra dated June 2008 giving Schneider an email at Onyx. \u00a0The FINRA CV (compiled by Schneider) is thus false.<\/div>\n<div><\/div>\n<div>The decision to allow Schneider to cease being a full time employee but to maintain an office within Paradigm Global\u2019s office and to continue to state in some marketing documents that he is an employee was made when the Bidens controlled Paradigm.<\/div>\n<div><\/div>\n<div>Felix Salmon is characteristically blunt about Onyx and Schneider. \u00a0He describes it as the hedge fund equivalent of a chop shop.<\/div>\n<div><\/div>\n<div>That said \u2013 it was probably Onyx that turned Ponta Negra into investigators. \u00a0Because Onyx is largely based in Austin Texas the Texas division of the SEC is taking the Ponta Negra case.<\/div>\n<div><\/div>\n<div>Onyx distributed other dodgy product \u2013 most notably the head of investor relations at Onyx (Justin Hare) was also a full time sales employee of Stanford. \u00a0Justin Hare\u2019s myspace page (which has since been made private) is the source of the photos of the glamourous life of a Stanford salesman that I posted\u00a0<a href=\"http:\/\/brontecapital.blogspot.com\/2009\/05\/what-was-it-like-to-be-stanford.html\">here<\/a>.<\/div>\n<div><\/div>\n<div>Anyway Onxy and Jeff Schneider introduced Paradigm to Alan Stanford\u2019s organisation. \u00a0Paradigm obviously thought fairly highly of Stanford and vice versa because they launched a cobranded product \u2013 the Paradigm Stanford Core Alternatives Fund.<\/div>\n<div><\/div>\n<div>According to the\u00a0<a href=\"http:\/\/online.wsj.com\/article\/SB123543815326954907.html\">Wall Street Journal<\/a>\u00a0no Paradigm money got sent to Stanford though some Stanford moneys were sent to Paradigm and I gather have since been returned.<\/div>\n<div><\/div>\n<div>This suggests carelessness on the part of Paradigm. \u00a0Financial institutions are fundamentally based on trust. \u00a0If people do not trust you then you do not have a business. \u00a0The Stanford relationship was the second time that Paradigm had lent its name to a large-scale ponzi (the first being Portus). \u00a0Remember that Paradigm \u2013 being a fund of funds \u2013 is meant to be an expert in due diligence. \u00a0And they failed. \u00a0Badly.<\/div>\n<div><\/div>\n<div>There was one other ex Paradigm employee who later worked at Onxy \u2013 that is Alla Babikova. \u00a0If you go back and look at the org chart above she essentially runs the sales function. \u00a0She was Schneider\u2019s boss in those days. \u00a0At Onyx Schneider it seems became her boss. \u00a0I have saved Alla Babikova\u2019s FINRA record\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14874583\/Alla-Babikova-Finra-Check\">here<\/a>. \u00a0Unlike Schneider\u2019s it is clean.<\/div>\n<div><\/div>\n<div>Jared Toren was also an employee of Onyx \u2013 though I gather he might have left Onyx to market for Ponta Negra. \u00a0He also has a clean\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14874662\/FINRA-Ch-Jared-Toren\">FINRA record<\/a>\u00a0but one that does not mention for instance that he once shilled for Onyx. \u00a0I have emails from him in that function. \u00a0The record is \u2013 at best \u2013 incomplete. \u00a0At a minimum Jared has made minor false representations to regulators.<\/div>\n<div><\/div>\n<div>Paradigm in the pre-Biden days also used to employ John Page. \u00a0He had the same rank as Jeff Schneider in the above org chart. \u00a0His 30 page long FINRA record (which you can find\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14874705\/Finra-John-l-Page\">here<\/a>) is full of customer complaints settled for six figure sums. \u00a0His regulatory problems existed both before and after his employment by Paradigm. \u00a0John Page was eventually forced to bankruptcy by UBS who sued him for repayment of bonuses and commissions that they had previously paid him and I think for moneys that they had paid out to clients as a result of his infractions. \u00a0As noted above \u2013 Paradigm appears to be careless about who it employs and associates with.<\/div>\n<div><\/div>\n<div><span class=\"Apple-style-span\">The Ponta Negra\/Paradigm\/Schneider connection<\/span><\/div>\n<div><\/div>\n<div><a href=\"http:\/\/brontecapital.blogspot.com\/2009\/04\/fraudulent-hedge-fund-associated-with.html\">This blog observed for the first time<\/a>\u00a0that Ponta Negra was (a) housed within the offices of Paradigm Global, (b) had a phone number that was the Paradigm Global switch and (c) used the same marketing agent as Paradigm \u2013 a marketing agent who is often listed as a full time employee of Paradigm. \u00a0That marketing agent was Onxy\/Jeff Schneider.<\/div>\n<div><\/div>\n<div>This was news because the\u00a0<a href=\"http:\/\/www.sec.gov\/news\/press\/2009\/2009-90.htm\">SEC says that Ponta Negra was run from a unit in Stamford Connecticut<\/a>. \u00a0(The address is on an early marketing email I have and also linked above.)<\/div>\n<div><\/div>\n<div>Moreover this is the third time that it has been publicly confirmed that Paradigm has associated itself with an alleged fraud. \u00a0The prior two were Portus and Stanford.<\/div>\n<div><\/div>\n<div>This suggests a degree of clumsiness \u2013 and it is a real problem for funds of funds. \u00a0Funds of funds have \u2013 as their single most important skill \u2013 the ability to do due diligence.<\/div>\n<div><\/div>\n<div>And the due diligence on Ponta Negra was really easy. \u00a0My original post on Ponta Negra is repeated at the end of this post. \u00a0Pretty well everyone with any real expertise I showed this to came to the same conclusion as me. \u00a0It was highly suspect. \u00a0The marketing literature failed basic requirements \u2013 not mentioning consistent custodians or auditors and having returns inconsistent with the strategy.<\/div>\n<div><\/div>\n<div>The Paradigm\/Onyx\/Ponta Negra\/Biden story has hit the main stream press (at least if you consider FT Alphaville and Felix Salmon at Reuters to be mainstream press).<\/div>\n<div><\/div>\n<div>I see little to object to in any of their stories (FT\u00a0<a href=\"http:\/\/ftalphaville.ft.com\/blog\/2009\/04\/30\/55358\/untangling-floor-17-650-5th-avenue\/\">here<\/a>\u00a0and\u00a0<a href=\"http:\/\/ftalphaville.ft.com\/blog\/2009\/04\/30\/55288\/the-politics-of-paradigm\/\">here<\/a>\u00a0and\u00a0<a href=\"http:\/\/ftalphaville.ft.com\/blog\/2009\/04\/30\/55253\/of-hedge-funds-and-asbestos\/\">here<\/a>, Felix\u00a0<a href=\"http:\/\/blogs.reuters.com\/felix-salmon\/2009\/04\/30\/when-bloggers-uncover-ponzis\/\">here<\/a>).<\/div>\n<div><\/div>\n<div>The line they take is essentially that Paradigm Global \u2013 owned and controlled by the Vice President\u2019s family \u2013 is less than careful about who it associates with and who it lends its name to.<\/div>\n<div>However they accept that Paradigm Global itself did not know that Ponta Negra was a fraud marketed out of their offices. \u00a0They accept the \u201cwe were dumb\u201d view of how Paradigm got caught up with Ponta Negra (and also with Stanford before them).<\/div>\n<div><\/div>\n<div>I have no evidence that Paradigm Global knew anything was wrong with Ponta Negra anyway. But plenty of evidence that they were sloppy.<\/div>\n<div><\/div>\n<div>That in itself is a problem. \u00a0Paradigm pitches itself as a highly sophisticated fund of hedge funds with superb due diligence processes. \u00a0That they did not suspect that Ponta Negra was a fraud almost immediately suggests that their marketing spiel (excellence in due diligence) is only marketing spiel.<\/div>\n<div><\/div>\n<div>When I wrote my original post on Ponta Negra (preserved below for posterity) it was blindingly obvious (to me at least) that Ponta Negra made no sense whatsoever.<\/div>\n<div><\/div>\n<div>It should have been blindingly obvious to Paradigm too \u2013 but it wasn\u2019t. \u00a0About half the readers thought it was a scam \u2013 and the\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14713883\/Ponta-Negra-First-Lawyers-Threat\">lawyers for Ponta Negra<\/a>\u00a0were sure I was implying it was a scam. \u00a0Even the most cursory check on Ponta Negra would have identified it as suspect. \u00a0Moreover in its literature Paradigm claims to have a database of just about every hedge fund and special skills at identifying scams. \u00a0They were \u2013 it seems \u2013 just too gullible and they failed at their core function.<\/div>\n<div><\/div>\n<div>I guess their advertising material \u2013 detailing extensive expertise at detecting scams- is just plain crap. \u00a0Like their $1.5 billion under management and their custody arrangements and even (as alleged by James Biden) their stated returns.<\/div>\n<div><span class=\"Apple-style-span\">\u00a0<\/span><\/div>\n<div><span class=\"Apple-style-span\">The Paradigm defence<\/span><\/div>\n<div><\/div>\n<div>Paradigm rejects that the notion that they actively participated in the alleged Ponta Negra scam. \u00a0That is an accusation I do not make. \u00a0I only make the suggestion that \u2013 through clumsiness and the failure to perform even the simplest due diligence that they lend their name to alleged scammers. \u00a0I also note that James Biden himself has sworn that Paradigm misrepresent their own return and makes allegations consistent with them misrepresenting themselves in marketing material.<\/div>\n<div><\/div>\n<div>Paradigm\u2019s only statement to date is simply to observe that Ponta Negra was a subtenant introduced to them by their common marketer.<\/div>\n<div><\/div>\n<div>That defence would be entirely plausible to even the accusation of clumsiness except that Paradigm Global has a history of lending its name or reputation to (alleged) scam hedge funds. \u00a0By far the most important was Portus Alternative Asset Management \u2013 an association that pre-dates any Biden involvement in Ponta Negra. \u00a0But to pick Stanford and Ponta Negra suggests above average carelessness.<\/div>\n<div><\/div>\n<div>And employing chop-shop operators like Schneider \u2013 who operates from an unlicensed investment advisory firm (Onyx) is also in great contrast to the due diligence that they claim they undertake when they invest their own money.<\/div>\n<div><\/div>\n<div>This place is littered with red flags. \u00a0There are more \u2013 but I think this should be enough to get the mainstream media and the SEC involved.<\/div>\n<div><\/div>\n<div>Oh, and if I were Rusciano from Ponta Negra I would be busy finding a lawyer with experience plea bargaining. \u00a0This story has a long way to run.<\/div>\n<div><\/div>\n<div>I for one though will be signing off. \u00a0I have real stocks to look at. \u00a0The whole point of being a digger \u2013 and I am a digger \u2013 is to make money from that which other people have not worked out. \u00a0And unfortunately I see no way to make money here.<\/div>\n<div><\/div>\n<div><\/div>\n<div>John<\/div>\n<div><\/div>\n<div><\/div>\n<div>My original note on Ponta Negra \u2013 which was posted under the title \u201cHedge Fund Marketing Material\u201d<\/div>\n<div><\/div>\n<div>I regularly read the letters from fund managers more successful than me. \u00a0I like to know what they are doing.<\/div>\n<div><\/div>\n<div>Sometimes I cannot work it out at all. \u00a0Maybe that is because I am stupid &#8211; or maybe that is just because they are making it up. \u00a0I have identified a couple of frauds that way&#8230;<\/div>\n<div><\/div>\n<div>Here is the letter from a fund (name withheld for now) which I do not understand. \u00a0Can anyone explain this strategy to me?<\/div>\n<div><\/div>\n<div><\/div>\n<blockquote>\n<div>Dear Fellow Investors:<\/div>\n<div><\/div>\n<div>The global economic stress as measured by FX short term volatility, sovereign and corporate CDS spreads and VIXX indices persisted in the month of February, as the barrage of negative economic indicators remained unabated.<\/div>\n<div><\/div>\n<div>Continued stress on the financial sector that peaked with the record quarterly loss of AIG and the collapse of Citigroup equity valuations has left policy makers and market participants perplexed as to how the current turmoil will be resolved.<\/div>\n<div><\/div>\n<div>The month of February marked one of the most complex environments in foreign exchange that we have experienced since the inception of the Fund, as the ambiguity in governmental commentary on interest rate decisions and the measures being considered to aid the distressed economic climate caused abnormal gyrations in the G10 arena.<\/div>\n<div><\/div>\n<div>We remain committed to our long DXY bias but as was mentioned in last month\u2019s commentary, we have preferred to express this through a short EUR\/USD bias and selectively partially imperfectly hedge it with a lower weighted long GBP\/USD trade.<\/div>\n<div><\/div>\n<div>We believe that the euro zone will continue to be weighed down by the massive 1.3 tn. EUR of outstanding debt of Eastern Europe that will be a challenge to refinance at reasonable yields in the current climate.<\/div>\n<div><\/div>\n<div>The reversal of our short USD\/JPY hedge was well-timed, as the announcement of the reissuance of U.S. Treasury samurai bonds to the Japanese marketplace has accelerated the upside momentum in USD\/JPY. We have decreased the size of our short EM bias as commodity prices appear to have temporarily stabilized and we prefer to selectively express views through cross regional plays such as short EMEA\/LatAm with underweights in HUF, PLN and overweights in CLP, BRL.<\/div>\n<div><\/div>\n<div>We will continue to utilize low quantities of leverage and fewer numbers of intraday positions, as we anticipate the persistence of a high volatility marketplace into the end of Q1 2009.<\/div>\n<div><\/div>\n<\/blockquote>\n<div><\/div>\n<div>Now of course it would be nice to understand how these guys do it &#8211; because they are good. \u00a0Very good. \u00a0Here are there monthly performance numbers.<\/div>\n<div><\/div>\n<div>\u00a0<a href=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1qSUd7ajI\/AAAAAAAAAP4\/BbwAXLzYBUI\/s1600-h\/Pomta+Negra+Returns.jpg\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331534396840962610\" src=\"http:\/\/4.bp.blogspot.com\/_AL2FXcy6tvw\/Sf1qSUd7ajI\/AAAAAAAAAP4\/BbwAXLzYBUI\/s400\/Pomta+Negra+Returns.jpg\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div><\/div>\n<div>Of course &#8211; as I do not understand the letter I can&#8217;t vouch in any way for the validity of these results. \u00a0So I am not publishing their name on this blog. \u00a0But if anyone can explain this to me I would be very grateful&#8230;<\/div>\n<div><\/div>\n<div><\/div>\n<div><\/div>\n<div>POSTSCRIPTS:<\/div>\n<div><\/div>\n<div>1. \u00a0The FBI has arrested Rusciano &#8211; see\u00a0<a href=\"http:\/\/www.connpost.com\/ci_12276125\">this article<\/a>.<\/div>\n<div><\/div>\n<div>2. \u00a0Folio Administrators has confirmed the relationship with Paradigm&#8217;s international funds. \u00a0Here is the email:<\/div>\n<div><\/div>\n<div>\n<div><\/div>\n<blockquote>\n<div>Dear Mr. Hempton,<\/div>\n<div><\/div>\n<div>I can confirm that Folio Administrators Limited are the appointed\u00a0fund administrator for Paradigm Global Fund.\u00a0 Folio has been providing fund administration services to Paradigm&#8217;s offshore funds since July 2004.<\/div>\n<div><\/div>\n<div>Please let me know if you require any further information.<\/div>\n<div><\/div>\n<div>Kind regards<\/div>\n<div><\/div>\n<div>William Harris<\/div>\n<div>Director<\/div>\n<div><\/div>\n<div>Folio Administrators Limited<\/div>\n<div>Folio House<\/div>\n<div>James Walter Francis Drive<\/div>\n<div>Road Town, Tortola<\/div>\n<div>British Virgin Islands, VG1110<\/div>\n<div><\/div>\n<div>Tel: (284) 494-****<\/div>\n<div>Fax: (284) 494-****<\/div>\n<div><span lang=\"EN-GB\"><a href=\"http:\/\/www.folioadmin.com\/\" target=\"_blank\" rel=\"noopener noreferrer\"><span lang=\"EN-US\">www.folioadmin.com<\/span><\/a><\/span><\/div>\n<p>&nbsp;<\/p><\/blockquote>\n<p>&nbsp;<\/p>\n<\/div>\n<div>I have some concerns though and have further followed up. \u00a0In an Auguest 2005 document linked\u00a0<a href=\"http:\/\/www.scribd.com\/doc\/14758658\/Due-Diligence-SV-Onshore-0809051\">here<\/a>\u00a0they clearly say that Folio has been an administrator of their offshore fund for THREE YEARS. \u00a0That would bring the date to 2002 &#8211; whereas Folio Administrators confirm the date since 2004 only. \u00a0 Here is the extract:<\/div>\n<div><\/div>\n<div><a href=\"http:\/\/1.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2Q3B9xmoI\/AAAAAAAAAQQ\/lMyw6QulADg\/s1600-h\/Paradigm+stated+custody.JPG\"><img decoding=\"async\" id=\"BLOGGER_PHOTO_ID_5331576808971278978\" src=\"http:\/\/1.bp.blogspot.com\/_AL2FXcy6tvw\/Sf2Q3B9xmoI\/AAAAAAAAAQQ\/lMyw6QulADg\/s400\/Paradigm+stated+custody.JPG\" alt=\"\" border=\"0\" \/><\/a><\/div>\n<div><\/div>\n<div>Again I will follow up.<\/div>\n<\/div>\n<p>___<br \/>\n<a href=\"http:\/\/brontecapital.blogspot.com\/2009\/05\/paradigm-global-bidens-and-allegedly.html\">http:\/\/brontecapital.blogspot.com\/2009\/05\/paradigm-global-bidens-and-allegedly.html<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Paradigm Global, the Bidens and allegedly fraudulent hedge funds \u2013 a summary John Hempton This is a summary of the situation to put all the posts in one place. \u00a0You can read this as an alternative to the other posts &hellip; <a href=\"http:\/\/stateofthenation.co\/?p=34158\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-34158","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"http:\/\/stateofthenation.co\/index.php?rest_route=\/wp\/v2\/posts\/34158","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/stateofthenation.co\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/stateofthenation.co\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/stateofthenation.co\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/stateofthenation.co\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=34158"}],"version-history":[{"count":0,"href":"http:\/\/stateofthenation.co\/index.php?rest_route=\/wp\/v2\/posts\/34158\/revisions"}],"wp:attachment":[{"href":"http:\/\/stateofthenation.co\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=34158"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/stateofthenation.co\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=34158"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/stateofthenation.co\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=34158"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}