Lin Shicheng slept on the sofa in the office for less than three hours.
Manhattan The morning light filtered in through the gaps in the blinds, casting slender golden stripes on the conference table.
When he woke up, the folder with more than two hundred pages was still pressed against the side of his face, and the corner of the sticky note left a shallow mark on his cheek.
It was already past five in the morning when I finished sorting out the last attachment last night.
He sent a message to Zhao Chen that "all credentials are closed-loop verifiable".
Then he leaned back in the chair and closed his eyes for a while, and fell asleep directly.
The coffee machine in the office made a low roar.
He rubbed his temples and flipped through the folder from beginning to end.
Henglong Holdings pledge file of Phase One--
The bank transfer voucher, Board of Directors resolution, and Offshore SPV registration certificate are each stamped with the original seal.
Phase Two's Bitcoin position record – institutional account statements of Coinbase and Bitfinex,
Each transaction is accompanied by a timestamp and transaction hash, which can be verified directly on Blockchain.
Phase Three's clearance summary--Bitcoin's complete position change table from eight hundred US Dollar to seventeen thousand US Dollar,
The net profit is 7.94 billion US Dollar. The final figure after deducting various expenses is accurate to two decimal places.
In the fourth stage, Fund Flow--Cayman Islands Offshore Account is transferred to the bank certificate of United States brokerage account,
Each transaction can correspond one-to-one with the subsequent position opening timeline of Tesla and Nvidia.
He put on his glasses, picked up a red pen, and began to do the final cross-reference page by page.
This is a habit he has developed after working as a lawyer for twenty years -
Before submitting any document to the regulatory agency, personally check the core numbers from beginning to end.
From the pledge financing amount of Henglong on the first page to the current cash balance of Era Vanguard on the last page,
Each number has a small tick next to it with a red pen.
More than four hundred ticks, not a single one missed.
At ten o'clock in the morning, he printed out the final version of the reply letter.
More than two hundred pages, bound in four files, with "Times Pioneer Capital--" printed on the cover of each file.
SEC Inquiry Response Attachment", with the file number and content summary marked below.
The text of the reply letter is only three short pages, and the wording is so concise that it is almost cold--
"According to the requirements of the SEC's second inquiry letter, Times Pioneer Capital now submits the following attachments to explain the complete chain of initial funding sources."
What follows is a brief overview of the four stages and their corresponding dossier numbers.
The last page of the text is a legal opinion signed by Lin Shicheng, the wording is also crisp and clear:
"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.
All transaction records have been attached for review and there are no misrepresentations or misleading omissions.
If you have any questions, please contact the legal representative of the Fund Lin Shicheng."
He read the last paragraph of the legal opinion again.
Although this passage is only four short lines,
But every sentence has been carefully considered by him and his team for several hours -
Especially the sentence "there are no false statements or misleading omissions",
It is within the strict liability legal framework that Era Vanguard must ensure that every number in every attachment can withstand line-by-line scrutiny by the SEC.
Lin Shicheng's fingers typed the SEC's EDGAR System website address on the keyboard.
He has been using this system for twenty years, and he knows which button to click at each step with his eyes closed--
Log in, select application type, upload attachments, fill in summary, preview and submit.
But before clicking the last confirmation button, his finger paused on the mouse for two seconds.
Once these two hundred pages of documents are uploaded, they will become permanent public records.
Anyone can download the full version at EDGAR System--
Bloomberg reporters, Reuters analysts, Muddy Waters investigators, and anyone in the world who is interested in Era Vanguard.
It will peel off the complete wealth path of an offshore fund,
It went all the way to the early morning when the Shan City boy pledged his family business equity to buy the first batch of Bitcoin.
He clicked OK.
EDGAR System A green prompt popped up - "Your declaration has been submitted successfully."
Lin Shicheng downloaded the confirmation receipt and forwarded it to Zhao Chen, Chen Xi and Zhang Qingxue. The body of the email only contained one sentence:
"Submitted, four files, more than 200 pages, all documents are closed."
After sending the email, he leaned back in his chair, took off his glasses and rubbed the bridge of his nose.
From taking over the legal work of Era Vanguard last November to now,
He has experienced the controversy over the wording of the 13D declaration, the channel design of the Apple liquidation, the life-or-death round of pledge replenishment in May, and the repeated back-and-forth between the two SEC inquiry letters.
Every matter is a challenge he has never encountered in his twenty-year legal career, and at this moment,
The last important document was finally confirmed and submitted from my keyboard.
Next is waiting.
Wait for EDGAR System to complete file processing, and wait for analysts Bloomberg and Reuters to download these public documents from EDGAR.
Waiting for the reporters sitting in front of the trading terminal to flip through more than two hundred pages of transaction records page by page,
Waiting for them to spell out the most authentic background of Era Vanguard from the complete chain from Henglong pledge to Bitcoin clearance,
Waiting for Wall Street to use a magnifying glass to examine every number, every transfer, and every time node they spread out.
This process took less than three hours.
Just after two o'clock in the afternoon Eastern Time, an alert popped up on Bloomberg Terminal, with a concise and deadly title--
"Era Vanguard submitted SEC Response Letter, disclosed Bitcoin's complete transaction records, and net profit was 7.94 billion US Dollar".
The text of the news only has a few lines:
"Times Pioneer Capital fully disclosed its initial source of funds for the first time in the attachment to the response letter just submitted to the SEC.
The attachment shows that Era Vanguard obtained a net profit of approximately 7.94 billion US Dollar through Bitcoin transactions from the end of 2016 to the end of 2017.
The funds were subsequently used to build large-scale positions on US Stocks Tesla, Nvidia and SpaceX.
All transaction records are accompanied by exchange statements and bank statements."
Lin Shicheng stared at the news on Bloomberg Terminal. The coffee cup in his hand was hanging in the air, but it was not brought to his mouth for a long time.
He knew that this reply letter would be made public, but he did not expect that Bloomberg would respond so quickly--
It takes less than two hours from the time EDGAR System is available for download to the time the alert is sent.
This means that Bloomberg's analyst downloaded the attachment at the first opportunity and has completed preliminary digital verification.
Immediately afterwards, Reuters's follow-up report also popped up, with more direct wording than Bloomberg--
"Era Vanguard's operation time span on Bitcoin exceeds one year,
The average buying price was 855 US Dollar, the average selling price was over 17,000 US Dollar, and the peak position reached approximately 600,000 pieces.
This is one of the largest single Bitcoin transactions documented."
The two analysts in the office raised their heads and looked at Lin Shicheng at the same time.
The data stream on Bloomberg Terminal is still being refreshed, and several follow-up reports are popping up intensively.
Lin Shicheng leaned back in his chair and exhaled a long breath,
For more than two hours, he had been imagining how the outside world would interpret this reply letter - and now the answer came.
In the evening, another update popped up on Bloomberg Terminal--
Analysts at Reuters compared the Bitcoin position opening timeline disclosed in the reply letter step by step with the historical price chart from the end of 2016 to the end of 2017.
The conclusion is. "All disclosed average transaction prices are highly consistent with the historical price range of Bitcoin during the same period, and there are no traces of subsequent adjustments."
Analysts at Reuters also noticed a detail:
Era Vanguard cleared the position after Bitcoin exceeded seventeen thousand US Dollar,
The periodic big top of Bitcoin happened to appear on this day.
Lin Shicheng started sorting out the Nvidia Schedule 13D Amendment Filing materials that need to be submitted tomorrow,
The confirmation receipt page for EDGAR System is still open in the lower right corner of the computer screen.
The green line "Submission Successful" glowed slightly in the dark.