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The Fraud of the Century:The Case of Bernard MadoffThe fraud perpetrated by Bernard Madoff which was discovered in December, 2008 is based upon a Ponzi scheme. Madoff took money from new investors to pay earnings for existing customers. The greater the payout to retiring and withdrawing customer, the more revenue or clients he would need to start and “investment relationship” with Madoff. The Ponzi scheme was named after Charles Ponzi who in the early 20th Century, saw a way to profit from international reply coupons. International reply coupons were a guarantee of return postage in response to an international letter. Charles Ponzi determined that he could make money, legally, by swapping out these coupons for more expensive postage stamps in countries where the stamps were of higher value. While making a significant profit with this system, Ponzi got the idea of enticing investors to provide him more capital to trade coupons for higher priced postage stamps. His promise to investors was a 50% profit in a few days. Touted as a financial wizard and the ‘Warren Buffet’ of his day, Ponzi lived outside Boston, he had a fairly opulent life bringing in as much as $250,000/day. Part of Ponzi’s success came from is personal charisma and ability to con even savvy investors. The promised payout was supported by the new investors anxious to take advantage of these robust returns because he appeared to create an image of power, trust, and responsibility. In July of 1920, the Boston Post ran an article exposing the scheme and soon after, regulators raided his offices and charging him with mail fraud knowing that his fabricated investment reports were mailed to his clients. The foundational operating principle of a Ponzi scheme is that you must constantly attract new investors to pay the old investors the ‘gains’ they were promised. Most Ponzi schemes self-destruct fairly quickly as the ability to keep attracting new investors dwindles. In the case of Bernard Madoff, he may have perpetuated the fraud for many years.Bernard L. Madoff Investment Securities LLC: ‘All in the Family’Bernie Madoff started in the investment business by legally buying and selling stocks not listed on the New York Stock Exchange (NYSE). Started in 1960 as a sole proprietorship, he served as a ‘wholesaler’ between institutional investors. In the early days, working with investment firms such as A.G. Edwards, Charles Schwab and others he made his money based on the variance between the offer price and sales price of stocks. In the 1990s, Madoff Securities was trading up to 10% of the NASDAQ shares on certain days. Early success and competitive advantage came from Bernie working with his brother, Peter (the first of several family members to join his firm) who after graduating from law school joined Madoff’s company and developed superior technology for trading buying and selling at the best prices. Madoff did not operate a hedge fund, which charges a fee for services and holds the money at a custodial bank. Madoff controlled the funds in house and made his money, in this division, from commissions on sales and profits and as far as has been revealed, the profits were not based on fraud.As Madoff became more successful, he moved the company’s headquarters from Wall Street to Third Avenue to the red granite “Lipstick Building” built by famed architect Philip Johnson. Not unlike Ken Lay and his lobbying efforts to deregulate the energy and gas industry, Bernie became more involved in lobbying for regulatory changes which would make it easier to trade electronically. Peter took on more oversight of the firm’s securities business. Bernie served as Chairman of the NASDAQ in 1990, 1991, and 1993. Through his successful networking, visibility at the NASDAQ, and promise of consistent returns (10-12%) Bernie was drawing billions of dollars from hundreds of investors. In addition, he held a seat on the government advisory board on stock market regulation, served on charitable boards and started his own foundation added to his credibility. He developed respectability and trust as a highly knowledgeable investment specialist. His inaccessibility and ‘invitation only’ approach to new investors created an air of exclusivity and desire to be involved. It could be equated to the most exclusive of country clubs-the greatest enjoyment is the status of membership. Ruth Madoff, Bernie’s wife, also worked at the firm for a time indicating a family network of relationships in the firm.Peter’s niece, Shana Madoff, was a rules and compliance officer at Madoff’s firm and worked under her father who was head of compliance in the market making arm (not the firm’s money management business). Shana, although not charged with any crimes, is married to Eric Swanson, a former SEC compliance lawyer. Shana Madoff has a respected career and was honored by the Girl Scouts of America as a “woman of distinction.”Although under investigation, neither of Madoff’s sons, Mark and Andrew have been charged with any wrong doing and were responsible for turning their father in when he confessed the fraudulent nature of his investment firm. Andrew did have money invested in his father’s firm where as Mark took his money out of the firm eight years earlier. The two deny any knowledge of the fraud. The family emphasizes the separation of the stock trading business (run on the 19th floor) and the investment management business (run on the 17th floor) by Bernie Madoff. In March, 2009 when Bernard Madoff stated his guilt, he never indicated the involvement of any other company employees or family members. He stated in the Allocution that “I want to emphasize today that while my investment advisory business—the vehicle of my wrongdoing—was part of Bernard L. Madoff Securities, the other businesses that my firm engaged in, proprietary trading and market making, were legitimate, profitable and successful in all respects. Those businesses were managed by my brother and two sons.” (Madoff Plea Allocution, p. 2) Further investigation will determine the extent and level of external support which Madoff had in defrauding thousands. His hiring philosophy for the investment business was to hire inexperienced individuals with no backgrounds in finance. They may have been unknowing participants.Explaining the Growth NumbersMadoff claimed he could consistently generate 10-12% returns for investors. Many of his clients were already wealthy and just looking for a stable and constant rate of return. His stated investment strategy was to buy stocks while also trading options on those stocks as a way to limit the potential losses on those stocks. His market timing strategy was called the “split strike-conversion.” With the large financial portfolio Madoff managed, many indicate at least one ‘red flag’ would have been the fact that he would have overtaken the market had he traded the options in the volumes necessary to meet his financial goals. In his “Plea Allocution” statement in March of 2009, he indicated that he never invested any of his client’s funds. Madoff simply moved money between Chase Manhattan Bank in New York and Madoff Securities International Ltd., a United Kingdom Corporation. Madoff stated that his fraud began in the early 1990s.Madoff had relationships with intermediaries also known as ‘feeders’ to his investment fund. These ‘feeders’ trusted Madoff and at this point do not appear to be integrally involved in the fraud. One such middleman, Rene-Thierry Magon de la Villehuchet committed suicide on December 23 after losing his life savings to Madoff. The middlemen profited by receiving fees and Madoff had a stream of money flowing into his operation. Robert Jaffe operated as a middleman for Madoff starting in 1989 when he became the manager of Boston based Cohmad Securities, a firm co-owned by Madoff to attract investors. Jaffe was the son-in-law of one of Madoff’s earliest investors and was a member of the Palm Beach Country Club, where he solicited new investors. He earned a small profit when Madoff took on an investor Jaffe introduced to him. Stanley Chais was a private investor from Beverly Hills who consistently brought in returns of 10-15%. Chais was funneling all his clients’ money to Madoff. Investors with Chais claim they thought he was personally managing their money and were not aware of the Madoff connection. In June, Chais sent a letter to clients informing them that he was moving to Jerusalem for six months for medical reasons and his son would take over in his absence. Chais’s fortune is claimed to be devastated as is that of his clients. In addition, Chais lost significant money in his own charitable fund.Jeffrey Tucker was an attorney for eight years at the SEC. Tucker also facilitated the meeting between Fairfield Greenwich Group and Madoff resulting in the loss of $7.3 billion (the biggest known single loss). Andres Piedrahita wed one of the daughters of Fairfield Greenwich’s co-founder Walter Noel. Piedrahita joined Greenwich and attracted significant revenue from Europe’s wealthiest families, operating out of a London office. Wealthy Spanish clients invested just under $50 million with the Group and Madoff.Robert Schulman operated Tremont Group Holdings after gaining experience working with Smith Barney and Shearson Lehman Brothers. Investors with Tremont, who ended up with Madoff, lost an estimated $3.3 billion. Tremont is part of Massachusetts Life Insurance Company that oversees billions of dollars in Oppenheimer Funds mutual fund assets. Tremont helped Mass Mutual enter the hedge fund business. Schulman, at the age of 62, retired from Tremont in the summer of 2008 (nearly 6 months before Madoff’s fraud was exposed). Schulman claims to have lost money in the Madoff funds and now operates a charity helping women and children who are poor or abused. None of his charities funds were invested with Madoff at the time the scandal broke. Swiss Bank Union Bancaire Privee (UBP) placed $700 million of wealthy client’s money in Madoff’s Ponzi scheme. Top management received warnings from the bank’s research department that Madoff’s fund should be eliminated from a list of approved funds. The bank’s senior executives were aware of the concerns and continued to leave hundreds of millions of investor funds with Madoff. UBP told its clients it was the victim of “massive fraud” and that it had conducted due diligence in managing client funds.Financial Support Near the End and the ArrestThe week and a half before Madoff admitted to his sons that he was operating a Ponzi scheme, 95 year old Palm Beach philanthroper and entrepreneur, Carl Shapiro gave Madoff $250 million. Shapiro lost the $250 million that he provided to Madoff as well as the loss of $100 million in a charitable organization he had invested with the firm. Madoff had made requests of many others for funds to save his business and Martin Rosenman provided $10 million. Rosenman is the President of a fuel company in New York. Rosenman is suing Madoff for the money alleging that Madoff proposed the solicitation was for a new fund and was sent a 19 page promotional piece in advance of the investment. Madoff was arrested on December 11, accused of operating a $50 billion Ponzi scheme after confessing his failure to his sons Andrew and Mark, who worked with their father in the firm. The official charge is criminal securities fraud. Madoff declared to his sons that he had roughly $200-300 million left in the business and that he wanted to provide the money to employees before turning himself over to authorities. The sons thought the investment arm of the business held between $8 billion and $15 billion in assets. SEC records showed that the firm had $17 billion in assets at the beginning of 2008. The Investigation and ChargesInvestigators in this case include the Securities and Exchange Commission (SEC), FBI, federal prosecutors from the U.S. attorney’s office for the Southern District of New York, and the Financial Industry Regulatory Authority. Forensic accountants will try to pull together the trail of investments and spending to determine where the money went. There is a belief that multiple offshore funds have been created by Madoff to shelter assets prior to the collapse of the firm. Madoff’s business was not registered with the SEC until 2006 after a SEC investigation. Bernard Madoff is charged with fraud. Investigators are evaluating documents dating back to January 1, 2000. The charges were not new when exposed to the SEC. Beginning in 1992 federal regulators investigated allegations of wrongdoing by Madoff. Following is a summary table of the nature of these investigations.Table 2Government & Regulatory Investigations of Bernard MadoffYearNature of the Investigation1992SEC-Madoff’s name came up in Florida accounting investigation.1999SEC-reviews Madoff’s trading practices2001SEC-Harry Markpolos, securities industry executive, raises question regarding Madoff’s returns2004SEC-Review into allegations of improper trading practices2005SEC-interviews Madoff and family finding no improper trading activities2005Industry-based regulatory group finds no improper trading activities2005SEC -meets with Harry Markopolos who claims Madoff operates world’s largest Ponzi scheme2006SEC –enforcement investigation finds misleading behavior & Madoff registers as an investment advisor2007-Financial Industry Regulatory Authority investigates and no regulatory action was takenSource: Associated Press (2009) “The Many Fruitless Probes into Bernie Madoff,” APNewswire, January 5, http://news.moneycentral.msn.com/provider/providerarticle.aspx?feed=AP&date=20090105&id=9486677, accessed January 5, 2009.Investors ImpactedThe list of Madoff clients is a who’s who of organizations, non-profits, successful entrepreneurs and businesspeople as well as entertainers. The Fairfield Greenwich Group had around $7.5 billion or more than half of its assets invested in the firm. Tremont Group Holdings, owned by Oppenheimer had $3.3 billion invested. Ezra Merkin, head of GMAC operated a hedge fund which lost $1.8 billion to Madoff. For a list of selected victims of the fraud see Table 1. Several victims have shared their ‘stories’ and relationship with Bernie Madoff. Richard Sonking met with Madoff in the mid ‘90s after his father, who had an account with Madoff, recommended the investment for the steady 8-14% returns. Sonking pulled together the minimum $100,000 required for investment at that time and was reminded how selective Madoff was in developing relationships. After selling his business, importing porcelain collectibles from France, he placed additional funds in Madoff’s hands. He was pleased with the returns and pleased with the monthly, detailed seven to eight page statements provided (including detail on equity trades). Upon retiring in 2005, Sonking requested quarterly distributions from his account and the amount could be increased with a faxed request. Until the news stories in December, 2008 there was no warning of any fraudulent activities.Loretta Weinberg, a New Jersey state senator, and conservative investor embraced her late husband’s philosophy that you live on half of what you make and save the rest. She was invested with Stanley Chais, a Los Angeles money manager who provided quarterly investment reports and a 10-14% annual return. Until the Madoff scandal hit the press, Weinberg had not heard of Madoff. As a 73 year old state senator making $49,000/year she will have to cope with the loss of her $1.3 million in life savings. In addition, she is concerned for her family who were all invested with Chais and, unknowingly, Madoff. Joseph Gurwin is 88 years old and lives in Palm Beach. He came to know Madoff and become his friend through the Palm Beach social and philanthropic community. Gurwin noted Madoff’s reputation for secure and conservative financial management. Gurwin’s Foundation (The J. Gurwin Foundation, Inc.) operating with around $28 million in assets donated $1.2 million in one year. The Foundation was invested heavily with Madoff. He indicated no warning signs and when he requested withdrawals, the money came quickly. Gurwin’s Foundation supports health care, as well as services and programs for frail, elderly or disabled younger adults. Law firms in Florida are representing clients who believed they were investing with Westport National Bank (a regulated banking institution in Connecticut) not Madoff investments. On December 12 the investors received a letter from Westport National indicating that they had a custodial agreement with Westport, giving full discretionary authority to Bernard L. Madoff Investment Securities. Restitution for InvestorsSome investors are suing the SEC for negligence in its regulatory responsibility and not being able to identify the fraud. Such attempts represent first time investors have sought restitution from a regulatory agency. Christopher Cox, SEC Chairman at the start of the fraud investigation indicated that the SEC examiner has missed ‘red flags’ in reviewing the Madoff firm. Allegations of wrongdoing started nearly 10 years ago and Madoff confirms fraud dating back to the early 1990s. Repeated investigations and examinations by the SEC showed no investment fraud. Because many SEC employees end up working in the investment business on Wall Street, there was speculation that an overall lack of objectivity clouded these investigations.Most investors are looking for minor compensation from the Securities Investor Protection Group (SIPC) which is a security-industry group started by Congress to provide up to $500,000 per customer for theft in a relationship between a broker and direct investor. The trustee has mailed claim forms to more than 8,000 Madoff customers. Many experts believe that third party investors (those who invested indirectly in the Madoff accounts) will not be eligible for SIPC funds.Some investors are engaging in “clawback suits.” This litigation would attempt to secure funds from ‘investors’ who had been able to successfully withdraw funds and reallocate that money among the defrauded clients. To protect their assets, many who have received payout funds from Madoff are transferring the money to irrevocable trusts, homes, annuities, or life insurance policies to protect them from seizure (Kim, 2009). A search of Madoff’s office by Federal prosecutors and investigators found about 100 signed checks for nearly $173 million. The court appointed trustee has obtained $29 million in assets and identified another $830 million in liquid assets which could be recovered and returned to investors. Perhaps the greatest restitution for some investors came as Bernard Madoff was handcuffed on March 12 and taken to prison after his 12 minute confession of guilt in a Lower Manhattan court house. Some victims asked the judge for a trial to uncover more about this extensive fraud and to determine why the governments ‘regulatory system failed to many investors. Judge Chin indicated there would be no trial as there was a plea of guilt and ongoing investigation at hand (Lucchetti, 2009).The Future of Charitable GivingDue to the widespread impact of the Madoff-related losses upon charities, non-profits, and educational institutions, donor skepticism and withdrawl are not unexpected consequences. As mentioned earlier, some of the organizations affected include the Elie Wiesel Foundation for Humanity, Yeshiva University, and Wunderkinder Foundation (Steven Spielberg’s Fund). This wariness comes at a time when the global recession has resulted in losses of around 30% for many foundation endowments. The vast majority of non-profits indicate that the economy was having a negative/very negative impact on fund raising, before the Madoff scandal was exposed. There is an increased care and sensitivity that will accompany charitable giving and shape the questions and stipulations placed upon donations. Some guidelines provided for evaluating responsible charities include the following: 1.) see what materials are readily available to potential investors/donors from the organization (annual reports, audited financial statements, payroll, and overhead), 2.) Who is the charity invested with and how much of their funds are invested, 3.) Who is managing the fund/charity and is there an independent investment committee (who’s on this committee), 4.) is the investment portfolio appropriately diversified, 5.) Who is auditing the fund/charity, and 6.) is there objectivity among board members through written ‘conflict of interest’ statements that prevent direct business dealings while serving on the board. ConclusionsBernard Madoff is accused of creating Ponzi scheme that destroyed $65 billion in investments. Many people are trying to understand how so many experienced investors, including banks, insurance companies, and nonprofit foundations lost billions of dollars to an individual who was able to deceive them as well as regulators. Investigators are trying to determine who helped Madoff carry off what some say could be a 30 year scheme that caused the$65 billion in losses and may have impacted over 4,800 people. Accountants, auditors and regulators are supposed to be gatekeepers that protect the public interest. Investigators believe that Madoff had a trading strategy that failed, then after a while, he made few trades for many years and his operation consisted of taking money from new clients and paying it out to existing clients, a classic Ponzi scheme.From an ethical perspective, this would be an example of white collar crime. White collar crime creates victims by establishing trust and respectability. As in this case, victims of white collar crime are trusting clients who believed there were many checks and balances that certified the Madoff investment operation as legitimate. Madoff appears to be the classic white collar criminal. He was an educated and experienced individual in a position of power, trust, respectability and responsibility and abused his trust for personal gains. From the inception of his investment business, he knew that he was operating a Ponzi scheme and defrauding his clients. In the end, he said he “knew this day would come.”An important question is how one individual could deceive so many people that certified his operation as legitimate. Madoff’s accountants, family and other employees will have to answer to authorities about their knowledge of the operations. For example, investigators have issued a subpoena for David Friehling who is a New York accountant who audited Madoff’s financial statements. Frank DiPascili, who dealt with client accountants and worked at Madoff’s firm for 22 years “responded evasively” and many of his answers to investigators were “incomprehensible”. While only Madoff has been charged with misconduct at this time, if there were other participants, they will face responsibility for their actions.White collar crime is unique in that it is often done knowingly by a rouge individual to steal, cheat or manipulate in order to damage others. Often, the only way to prevent white collar crime is to have internal controls and compliance standards that detect misconduct. Perhaps the most difficult white collar crime and fraud to expose is that perpetrated by the top executive. We count on leadership within an organization to create, manage and motivate and ethical organizational culture with all the checks and balances in place. In the Madoff case there was the opportunity to deceive others without effective audits or transparency and an understanding of the true nature of his operations. As a result of this case, individual investors, institutions, and hopefully regulators will exert more diligence in demanding transparency and honesty from those that manage investments. Copyright Linda Ferrell, 2009. The case is designed exclusively for classroom discussion rather than to illustrate effective or ineffective handling of an administrative ethical or legal decision of management. All sources were obtained through publically available sources.Sources:(2009) “Madoff’s Victims,” Wall Street Journal, http://s.wsj.net/public/resources/documents/st_madoff_victims_20081215.html, accessed January 9, 2009. (2009) “Plea Allocution of Bernard L. Madoff,” http://online.wsj.com/public/resources/documents/20090315madoffall.pdf, March 12, 2009, accessed March 12, 2009.(2008) “Victims of Scandal Reflect on Shocking Turnabout,” Wall Street Journal, online.wsj.com/article/SB122972955226822819.html, accessed December 23, 2008.Bernstein, Elizabeth (2008) “After Madoff, Donors Grow Way of Giving,” Wall Street Journal, online.wsj.com/article/SB122999068109728409.html, accessed December 23, 2008.Law, Cassel Bryan (2009) “Inside a Swiss Bank, Madoff Warnings,” Wall Street Journal, January 14, p. 1A.Catan , Thomas, Christopher Bjork and Jose De Cordoba (2009) “Giant Bank Probe Over Ties to Madoff,” Wall Street Journal, online.wsj.com/article/SB123179728255974859.html, accessed January 13, 2009.Efrati, Emir (2009) “Q&A on the Madoff Case,” Wall Street Journal, online.wsj.com/articles/SB123005811322430633.html, accessed January 9, 2009. Efrati, Amir (2008) “Scope of Alleged Fraud is Still Being Assessed,” Wall Street Journal, online.wsj.com/article/SB122953110854314501.html, accessed December 23, 2008.Efrati, Amir and Chad Bray (2009) “U.S.: Madoff Had $173 Million in Checks,” Wall Street Journal, online.wsj.com/article/SB123143634250464871.html, accessed January 9, 2009.Efrati, Amir, Aaron Luccchetti and Tom Lauricella (2008) “Probe Eyes Audit Files, Role of Aide to Madoff,” Wall Street Journal, online.wsj.com/article/SB122999256957528605.html, accessed December 23, 2008.Frank, Robert and Amir Efrati (2009) “Madoff Tried to Stave Off Firm’s Crash Before Arrest,” Wall Street Journal, online.wsj.com/article/SB123129835145559987.html, accessed January 7, 2009.Frank, Robert and Tom Lauricella (2008) “Madoff Created Air of Mystery,” Wall Street Journal, online.wsj.com/article/SB122973208705022949.html, accessed December 23, 2008.Scannell, Kara (2008) “Investor Who Lost Money in Alleged Scheme Seeks Relief from SEC, “ Wall Street Journal, online.wsj.com/article/SB122999646876429063.htmlKim, Jane J. (2009) “As ‘Clawback’ Suits Loom, Some Investors Seek Cover,” Wall Street Journal, March 12, p. C3.Lucchetti, Aaron (2009) “Victims Welcome Madoff Imprisonment,” Wall Street Journal, March 12, http://online.wsj.com/article/SB123687992688609801.html, accessed March 12, 2009.Strasburg, Jenny (2008) “Madoff ‘Feeders’ Under Focus,” Wall Street Journal, December 27-28, pp A1, A8.Strasburg, Jenny (2008) “Mass Mutual Burned by Madoff,” Wall Street Journal, December 22, p. C1. Trex, Ethan (2008) “Who Was Ponzi—What the Heck Was His Scheme?” cnn.com, http://www.cnn.com/2008/LIVING/wayoflife/12/23/mf.ponzi.scheme/index.html, accessed December 23, 2008. Elizabeth Williamson (2008) “Shana Madoff’s Ties to Uncle Probed,” Wall Street Journal, onine.wsj.com/article/SB122991035662025577.html, accessed December 23, 2008.AppendixFairfield Greenwich AdvisorsAn investment management firm$7,500,000,000Tremont Group HoldingsAsset management firm$3,300,000,000Banco SantanderSpanish bank$2,870,000,000Bank MediciAustrian bank$2,100,000,000Ascot PartnersA hedge fund founded by billionaire investor, philanthropist and GMAC chief J. Ezra Merkin$1,800,000,000FortisDutch bank$1,350,000,000HSBCBritish bank$1,000,000,000Carl ShapiroThe founder and former chairman of apparel company Kay Windsor Inc., and his wife$500,000,000Fairfield, Conn.town pension fund$42,000,000Jewish Community Foundation of Los AngelesThe largest manager of charitable gift assets for Los Angeles Jewish philanthropists$18,000,000Korea Teachers PensionA 10 trillion won Korean pension fund$9,100,000Fred Wilponowner of New York MetsN/ASteven SpielbergThe Spielberg charity -- the Wunderkinder FoundationN/AChais Family FoundationA charity that gave to Jewish causesN/AAllianz Global InvestorsThe asset management unit of German insurer Allianz SEN/AUBS AGSwiss bankN/AYeshiva UniversityA New York-based private university$14,500,000The Elie Wiesel Foundation for HumanityThe charitable foundation of Nobel laureate$15,200,000Leonard FeinsteinThe co-founder of retailer Bed Bath & BeyondN/ASen. Frank LautenbergThe charitable foundation of the New Jersey Senator's familyN/ANorman Bramanformer owner of Philadelphia EaglesN/AJeffrey KatzenbergThe chief executive of DreamWorks Animation SKG Inc.N/AGerald BreslauerThe Hollywood financial advisor to Steven Spielberg and Jeffrey KatzenbergN/ARoyal Dutch Shell pension fundGlobal energy and petrochemical companyN/ANew York Law Schoollaw school in New York City$300,000J. Gurwin FoundationCharityN/AFire and Police Pension Association of ColoradoPension fundN/AInternational Olympic CommitteeOlympic organizer$4,800,000Kevin Bacon and wife Kyra SedgwickHollywood actorsN/AEric RothHollywood screenwriterN/AHenry KaufmanIndividual investor, former Salomon Brothers chief economistN/ANew York UniversityUniversity $24,000,000Burt Rossformer mayor of a town in New Jersey$5,000,000Gabriel Partners Money-management firm run by GMAC Chairman Ezra Merkin.N/AThe Diocese of St. Thomas Catholic church in the U.S. Virgin Islands$2,000,000Members of the Hillcrest Golf Club of St. Paul, Minn. and Oak Ridge Country Club in Hopkins, Minn.country clubsN/ABard CollegeUniversity in New York$3,000,000Martin RosenmanNew York City-based heating oil distributor$10,000,000Source: WSJ reporting; Associated Press; the companies and charities.wsj.net/public/resources/documents/st_madoff_victims_20081215.html, accessed January 9, 2009.
Solution: Bernard Madoff Case Study Answers (100% Original Work APA Format With References)