Subject: File No. 3-14863
From: Karen Roberts

February 17, 2017

To whom it may concern:

I had to comment on your accountability here, or lack thereof.

It's been 4 years since this fund was set up. How is it that with an independent consultant, a tax administrator and a fund administrator, it took 4 years before the SEC could issue a plan of distribution?

What kind of notice, I wonder, was sent out to the claimants and/or potential claimants in the interim? Did you provide annual updates? Or, a better question, is, during these four years in which 3 independent firms were selected to act as administrators (hello? Fiduciary duty anyone?), did anyone actually to identify the claimants? And, if so, by what process was this achieved? More importantly, when was it achieved?

The notice issued in January 2017 states "The Plan establishes a process in which both data provided by Respondent and by claimants, through a claims process, will be used to identify potential claimants and to determine whether a potential claimant is eligible to receive a distribution payment."

So the fund is now a plan, wow That's some transformation When did this change occur? I assume the 'plan,' being a plan and not a fund, has a different set of fiduciaries? Guess the plan fiduciaries must of dropped the ball on notice, too, eh? So the fund, which took the time to change itself into a plan, what? Got distracted? Lost it's way? Where were the three consultants to guide them?

And what does it look like now, as a plan? Would we even be able to recognize it? How did it transform from a fund set up in an interest bearing treasury account to a plan? Did it just one day wake up and say "That's it I am tired of waiting on these Puerto Ricans I wanna see some action"

And no one complained this whole time? What about the 3 independent consultants? Where do I sign up to get paid on those gigs? Were they paid monthly? What does that invoice look like I wonder? And, who gets the interest? 10% earns $2,600,000. Seriously though?

I digress. I was going to comment on the fact that your statement applies the future tense, as in "will be used." This is the claims process itself, that has yet to be established. Ha As if Who in the hell is even going to have the documentation anymore? The transactions date back to 2008 and 2009 I know I keep 10 year old trade orders lying around...

Of course, this all assumes this whole thing is legitimate. NOT just a sham in the first place. If the intent in imposing these fines was genuine, and the SEC really did intend on repaying those 'harmed investors', then how is it no one has lifted a finger to even so much as identify who these people (if they are people, oh excuse me 'harmed investors') are in 4 years?

Please do keep us all updated on how things proceed. Feel free to provide a public or a private response to my commentary. I look forward to hearing the progress you have made in 2021.