Is it possible for a group like this with a relationship with a certain mutual fund to say, "can we park our shares in your mutual fund spread across all your customers names for a set period of time and we will guarantee profit for you if you give it back to us when we say". This wouldn't effect ownership documents. A person can put in a large wierd random purchase amount and a buyer with the exact amount = transaction done. If done at the last minute and the company is dead. What paperwork would there be to fill out?
A second point to this is, maybe we should ask the examiner to review all transactions for a certain time just prior to settlement for this type of criminal or at least barely legal activity. Especially important if insiders do it.