139 Weeks of Radical Transparency: The Antithesis of a Ponzi Scheme

For 139 consecutive weeks — from the fund's inception through the CFTC's emergency asset freeze — I sent every Rose City Fund investor a weekly update called "Five Bullet Friday." Every single issue included the fund's Ethereum wallet address so investors could verify the fund's holdings independently, in real time, on the public blockchain.

This is the antithesis of a Ponzi scheme.

What Ponzi Schemes Actually Look Like

Bernie Madoff sent investors fabricated account statements. He never disclosed actual trading activity. He discouraged questions about his strategy. He operated in secrecy for decades.

Rose City Fund operated in the opposite way:

• Weekly investor updates for 139 consecutive weeks
• Public blockchain wallet address included in every update
• Transparent DeFi strategy — OHM, KLIMA, and other protocols
• Open redemptions — investors could exit at any time

The Five Bullet Friday Record

Issue #139 — the final update before the CFTC's emergency freeze — is included in the Legal Documents section of this site. It demonstrates the consistent, professional, transparent communication that characterized the fund's operations throughout its existence.

What the CFTC Ignored

CFTC investigator Heather Dasso admitted under oath that she never reviewed the blockchain records. She never reviewed the Five Bullet Friday newsletters. She never spoke to a single investor who complained about not receiving their promised payments.

She built a case for fraud without reviewing the most fundamental evidence of whether fraud occurred.

The Broader Lesson

Transparency is not a defense strategy — it is the foundation of trust between a fund manager and their investors. The 139 weeks of Five Bullet Friday updates represent a commitment to that trust that no Ponzi scheme operator has ever made.

The CFTC's failure to acknowledge this record is not an oversight. It is a choice — and it is a choice that the GAO, DOJ, and 7th Circuit are now being asked to scrutinize.