Several filers reported suspected Ponzi schemes where subjects gathered client funds for investment in commercial real estate or real estate securities without actually purchasing the underlying assets. A hedge fund claimed to invest millions in CMBS and credit derivatives, but the filer found no evidence of CMBS ownership. The hedge fund primarily bought long-term certificates of deposit earning minimal interest, which were inconsistent with the fund’s investment strategy. In addition, the filer noted many small client deposits, consistent with a Ponzi scheme. Filers submitted six SARs totaling $15 million on another suspected Ponzi scheme that purported to involve.