For 10 years, tens of millions of buys, you did not lose a penny on any of the buys.

How many times did that happen?

But is this a Barclays document?

You actually stopped them from making purchases every day.

Is it not true that they had discretionary--"they" being RenTec--has total discretion, full discretion and authority without obtaining your prior approval to manage the investment in the trading of the accounts?

It is also something they are representing to the SEC that they do not control it.

Now, when Renaissance sends a marketable order using your software system to the stock market, 30 million--or, I guess--yes, 30 million a year between the two banks.

Senator Johnson, whenever you are ready, let me know. I would be happy to yield to you...

Is this a serious representation when you tell the SEC that you do not control Palomino?

More significantly, Renaissance is signing a deal with itself, and the company is such a shell that you, as an executive officer of RenTec, sign all of the papers.

COLT provides an after-tax benefit to these investors through the conversion of their return from the fund from short-term capital gains (taxed at 39.6%) to long-term capital gains (taxed at 20%).

Is there any practical way in which 30 million trades a year could be 30 million recommendations?

Was that statement true?

This gives rise to significant short-term capital gains for the investors regardless of whether or not they are invested in the fund for the shorter or longer term.

Did the banks, either of your banks, from these tens of millions of trades that were executed every year in your accounts for the option basket and from the billions of dollars of profits earned in those accounts, did your banks receive…

This algorithm was not just making changes by itself. It took human beings to make changes.

Don't you think that you have a responsibility to determine whether or not you are aiding and abetting a fiction?

The banks and Renaissance claim that Renaissance is independent from the fund when it is acting as investment advisor to the banks.

Year after year after year, that is what they say to the SEC.

Did you tell him that one of the concerns was whether or not there would be a tax benefit under the old structure?

To my knowledge, no. However, I am aware that my control functions were in regular conversations with all of the external regulatory constituencies on an ongoing basis.

I would say yes, although there is the word 'either' here, and I do not quite understand this formulation.

The reality is that tax reform is moving slowly and the inversions are moving very rapidly, and, as I indicated before, I think that is a prescription for real chaos.

The IRS has recently experienced budget reductions that do constrain the resources that are potentially available for large partnership audits.

Was there a question in these conversations with your tax people, that there was a concern that the old MAPS, the old approach, might not be respected as a derivative or it might not be respected as an option for tax purposes?