200% is very possible without buying every fraud stock out there. I exceeded 200% in 1999 and 2000. In 2003 it was +327%. I don't think that any of the winners were fraud stocks, but a lot of them are way below where I sold them. (Example CMGI sold at $89 is now around $1.60) One thing that I have noticed is that the larger your account gets the harder it is to have those kind of returns. Last year was only 105% and because of a large cash position, I may have a hard time even getting that much this year even with VPHM up 520%.
PS: Never used margin to get these returns either.