After an exhaustive and costly investigation of nearly two years, and without admitting or denying the findings detailed in the SEC’s order, we agreed to settle with the SEC and pay a $225,000 penalty which will go directly to our investors.

We’re glad to put this matter behind us. We used Fireblocks, a non-qualified custodian, as a best-in-class solution to secure our crypto assets.

Although Fireblocks was not a qualified custodian, we believed they were the best solution for our needs and, in our opinion, the safest way to secure crypto for our investors at the time. We disclosed our use of Fireblocks in our Form ADV filing with the SEC.

We also had a redemption policy for our investors that required at least five business days' notice before month end for redemption.

However, we thought it would be a nice thing to do to allow investors out of the fund earlier if they didn’t want to be there without having to wait the full five business days. As a result, no good deed goes unpunished. What more is there to say…