New York, Manhattan.
On the first Monday in July, a heat wave evaporated from the Hudson River, turning the entire city into a sweltering steamer.
The air conditioner of Era Vanguard New York Office is turned on at full speed, and the screens of Bloomberg Terminal are lined up on the conference table to form a cold-colored light wall.
When Lin Shicheng opened the door and came in, he was holding a Kraft Paper Envelope in his hand, with a blue badge of United States Securities and Exchange Commission printed on the corner of the envelope.
His tie was tied meticulously and his shirt cuffs were neatly buttoned.
But Zhao Chen noticed that when he came in, he didn't put Briefcase on the cabinet at the door first as usual--
He put the envelope directly on the coffee table.
"Zhao Zong, SEC's second inquiry letter."
Lin Shicheng's voice is not high-pitched, but every word carries a kind of prudence unique to lawyers when touching on core risks.
"They only added one question this time - asking Era Vanguard to further explain the source of the initial funds."
Zhao Chen leaned on the back of the sofa and stopped with his fingers on the edge of the tea cup.
Nearly two months have passed since the last submission of Schedule 13D Amendment Filing.
The SEC's first inquiry letter was sent in late May, and Era Vanguard issued a complete response in early June.
He thought the matter had come to an end, but apparently the SEC reviewers didn't intend to let them go just like that.
"Initial capital."
Zhao Chen repeated these two words, his tone was calm, and no emotion could be heard.
"They want to know where the money came from when Era Vanguard was founded."
"Yes."
Lin Shicheng took the inquiry letter out of the envelope and turned to the second page.
"The SEC's wording is very direct --
'Please explain the specific source of the initial funds for Times Pioneer Capital,
Including but not limited to the original lender of the funds, cross-border transfer path, and relevant tax compliance certificates.
If the initial funds came from cryptocurrency or other digital asset transactions, please provide complete transaction records and bank statements.'"
He placed the inquiry letter on the coffee table and tapped his finger lightly on the last sentence.
"Crypto Asset. They named him directly."
Zhao Chen picked up the tea cup and took a sip. The richness of Pu'er melted on the tip of the tongue.
He wasn't surprised.
In the inquiry letter at the end of May, the SEC requested to explain the source of Henglong stock pledge financing.
Era Vanguard mentioned "the actual controller's overseas investment income" in his reply.
These words are a huge question mark in the eyes of SEC examiners--
A 25-year-old China person, without any external fundraising record,
Where does the "overseas investment income" come from that is enough to support US Stocks positions of more than 20 billion US Dollar?
"What they want is my complete Capital Chain from First Pot of Gold to now."
Zhao Chen Put down the teacup,
"From 500 million Hong Kong Dollar to 8 billion US Dollar, every step must be well documented."
Lin Shicheng nodded and opened the Black Notebook he carried with him. There was a thick stack of paginated labels inside.
"Zhao Zong, I told you before, the SEC will ask this step sooner or later.
So when their first inquiry letter was sent out, I had already started preparing this batch of materials."
He took out a dark gray file box from Briefcase. There was a label on the spine of the box.
There are a few lines written on it in black marker--
"Era Vanguard Fund Traceability, 2016.11-2017.12".
He placed the file box on the coffee table and opened the lid.
There are at least two hundred pages of documents neatly packed in the file box--
Bank statements, exchange transaction records, cross-border transfer certificates, Offshore SPV's registration documents, and the complete transaction log left behind by Bitcoin when it cleared its position.
Each document is arranged in chronological order, and each page is marked with sticky notes to indicate the corresponding stage and purpose.
Zhao Chen turned a few pages, and the paper made a slight rustling sound in the quiet room.
"Bitcoin's transaction records, from the first purchase to the final liquidation, each transaction is accompanied by an exchange statement and bank statement."
Lin Shicheng pulled out a document paginated with color labels and spread it on the coffee table.
"This is the original statement from Coinbase and Bitfinex, spanning from the end of 2016 to the end of 2017.
This is the bank voucher for cross-border transfer - Offshore Account from Hong Kong HSBC to Cayman Islands, and then transferred from Offshore Account to the exchange.
This is the fund withdrawal record during liquidation."
Zhao Chen flipped through the documents in the file box from beginning to end, looking at each one carefully.
From the 500 million Hong Kong Dollar raised by pledging Henglong Holdings shares, 355,000 Bitcoin were bought at an average price of about 855 US Dollar.
In the middle of the process, Swing Trading held more than 500,000 coins, and then the liquidation process occurred on the day Bitcoin exceeded 17,000 US Dollar.
The net profit after liquidation was 7.94 billion US Dollar, all of which was deposited into Offshore Account of Cayman Islands.
"These materials can withstand anyone's verification."
Lin Shicheng closed the file box and leaned back on the sofa.
"From the transaction hash on Blockchain to the bank's transaction-by-transaction flow, every record can be mutually verified.
If anyone is willing to take the time to review all the large on-chain transfers near several key price points in Bitcoin's history,
They will find that the timing of our opening and closing positions exactly matches the pending order price."
Zhao Chen In front of him are more than two hundred pages of documents - more than two hundred pages of paper, recording the craziest and loneliest period after his rebirth.
In those few months, he barely slept a full night's sleep. He sat in front of the computer every night and stared at the market price of Bitcoin.
Use the memory brought by rebirth to repeatedly calibrate the time points of each purchase and sale.
No one knew what he was doing. Su Wantang thought he was working overtime to look at the project, and Chen Xi thought he was studying the trend of US Stocks.
Only he knows that he is using Previous Life's knowledge to bet on a position that others would not even dare to think about.
"Submit it."
Zhao Chen closed the file box, her voice was not loud, but every word fell steadily.
"If they want the source of funds, give them all the transaction records of Bitcoin.
From the first purchase to the last liquidation, each transaction is accompanied by the exchange statement and bank statement.
Let them see for themselves where Era Vanguard's money comes from."
Lin Shicheng unscrewed the Fountain Pen cap and quickly wrote a few lines on the notebook.
"In addition,"
Zhao Chen added,
"There can't be any gray area in this deal.
Tax, money laundering regulations, cross-border funds transfer compliance--
For every hidden danger that may be picked out by the SEC, check it out yourself first, don't wait for them to ask."
"In terms of taxation, we have dealt with it according to the capital gains tax withholding rules of United States during the liquidation.
Cayman Islands's Offshore Account strictly complies with the intermediate holding structure.
We have also confirmed compliance with the law firms Hong Kong and New York in advance regarding the cross-border fund transfer path.
In terms of money laundering regulations--Bitcoin's transaction records are all kept from the hash on the chain to the KYC of the exchange.
Every source of funds can be traced back to the original bank transfer.
In other words, we have blocked all possible areas of criticism in advance."
Lin Shicheng capped the pen, turned the notebook forward a few pages, found the revised version of the text that had been drafted, and pushed it in front of Zhao Chen.
"I added a legal opinion at the end of the inquiry reply letter--
All sources of funds of Era Vanguard can be traced back to the overseas investment income of its actual controller Mr. Zhao Chen's personal legal income.
There is no illegal fund-raising, money laundering or illegal cross-border transfer of funds.
All transaction records have been attached for review by the SEC."
Zhao Chen nodded after reading the legal opinion.
"After submission, your entire wealth path will be completely public."
Lin Shicheng put away Fountain Pen and stared at Zhao Chen solemnly,
"This is not speculation circulated privately by Wall Street, nor is it a rough estimate from Bloomberg's anonymous source--
It is an original record in black and white with bank seal and exchange watermark.
Everyone will see that you started buying Bitcoin for eight hundred US Dollar and sold it only after getting seventeen thousand US Dollar.
From 500 million Hong Kong Dollar to nearly 8 billion US Dollar, how every penny was earned and how every tax was paid are all spread out under the sun."
Zhao Chen picked up the already cold Pu'er and drank it in one gulp. The bottom of the cup fell next to the file box, making a crisp squeak.
"Then spread it out in the sun."