Accusations of fraud make sense if you believe CRGP was a sophisticated dividend scheme from its inception. Otherwise, the fraud portion falls about when you consider the logistics of what knowledge was necessary to invent the notes, execute the dividend strategy, coordinate share issuance and buyers during the little known and understood DTCC clearance process with regards to a special dividend, and finally hope DTCC and FINRA both approve a highly unorthodox dividend.

Maybe that all happened. We may never know.