The Non-Financial Ledger: What the Numbers Don’t Capture

Two people are identified in this complaint as Fund Participant 1 and Fund Participant 2. Their names are redacted from the public record. Their decisions, however, are documented in granular detail, because those decisions are the proof of harm. They are not cautionary tales about greed. They are accounts of people doing exactly what financial advisors tell you to do: demand documentation, review performance history, ask for audited statements, and only invest after receiving them.

Fund Participant 1 did all of this. In May 2020, they received an April 2020 Performance Sheet and a Q1 2020 Investor Presentation. They reviewed those materials. They saw a fund with years of documented positive returns, an auditor listed by name, a multi-member advisory board with photographs and biographical writeups, and AUM figures that implied dozens of other sophisticated investors had already done their own due diligence and found the fund credible. Fund Participant 1 wired $1,000,000 on or about May 29, 2020. The CFTC’s complaint states that they did so “in part, based on the false performance returns stated in these documents.”

Fund Participant 2 received a January 2021 Performance Sheet in February 2021. They took time to consider. They contacted Defendants in early April 2021 to confirm participation. They wired $1,600,000 on or around May 6, 2021. The complaint confirms that at least one fund participant specifically asked whether the fund was audited and requested audited financial statements before committing. The fund produced those statements. They were allegedly fabricated.

“They did everything right. They asked for the audit. They got the audit. The audit was a lie assembled from someone else’s templates.”

The damage here is not just financial, though the financial damage is severe. Trust in documentation, trust in the structure of investment oversight, trust in the idea that asking the right questions will protect you: all of that was weaponized. The fund’s entire infrastructure of credibility was built as a tool of extraction. The professional-looking investor portal. The quarterly presentations with formal titles like “Investor Presentation Q1 2020.” The LinkedIn profile. The monthly account statements showing ever-increasing balances. Every piece of it existed to make people feel safe. None of it was real.

The complaint does not tell us whether these investors needed the money. It does not tell us whether the $1 million or the $1.6 million represented savings, inheritance, retirement assets, or capital raised from family. It does not need to. The structure of the fraud tells us everything about how it was designed: it was designed for people who had enough money to wire seven figures and enough sense to demand documentation first. It was designed to pass scrutiny. The most careful investors were the most useful targets, because their due diligence created the appearance of legitimacy.

Based on the complaint’s timeline, monthly false statements were delivered to participants throughout the multi-year relevant period from mid-2017 through at least April 2022. Each statement showed account balances growing. Each statement reinforced the decision to stay. Each statement was, according to the CFTC, false.

“The monthly statements kept arriving. The numbers kept going up. The actual account was collapsing the entire time.”

Legal Receipts: Direct From the Federal Complaint

The following passages are reproduced verbatim from the CFTC’s complaint filed August 19, 2022, in the Eastern District of Michigan. Paragraph numbers are included so you can locate each passage in the source document attached below.

“Neither EIA nor the Fund has ever been a client of Audit Firm 1 or 2.” — CFTC Complaint, Para. 57

The Gap Between the Claims and Reality

The chart below maps what EIA told investors in the December 2021 Performance Sheet against the CFTC’s allegation that the fund had negative returns in every one of those years. The claimed figures come directly from Paragraph 29 of the federal complaint.

Societal Impact Mapping

Environmental Degradation

This particular fraud does not carry a direct environmental dimension based on the source material. The fund traded commodity interests including futures contracts and options on futures contracts tied to financial instruments. No environmental permits, natural resource extraction, or ecological harm are described in the CFTC complaint. What is documented is the routine financial harm that compounds: when personal wealth is stripped through fraud, affected households have less capacity to weather economic shocks, take on debt, and lose the financial cushion that separates a bad year from a life-altering one.

Public Health

Financial fraud of this kind produces documented public health consequences. Research consistently links major personal financial loss to elevated rates of depression, anxiety, sleep disorders, and stress-related physical illness. For investors who concentrated significant capital in this fund, the loss of six or seven figures represents the loss of retirement security, healthcare funding, housing stability, or the ability to provide for dependents. The complaint documents that investors were actively deceived into increasing their contributions while the fund deteriorated. This means the harm was not a single event but a sustained, multi-year process of mounting exposure to a fraud that participants had no honest information to evaluate.

Financial loss at this scale does not stay in the bank account. It follows people home. It changes how they sleep. It changes what medical care they can access and what plans they can make for their families.

Economic Inequality

The structure of this fraud is a precise instrument of upward wealth transfer. Investor capital, pooled from dozens of participants, flowed into trading accounts where it was lost. Meanwhile, the complaint seeks disgorgement of “salaries, commissions, loans, fees, revenues, and trading profits derived, directly or indirectly” from the scheme. Someone received fees and salary during this period. The investors did not. The fund operator lived in Detroit, then relocated to Dallas, while running a fund described as having $130 million in AUM as recently as March 2022. That AUM figure was, according to the CFTC, false. But the operational costs of maintaining that fiction, including the investor portal, the quarterly presentations, the LinkedIn presence, and the attempted audit engagement, were real. Those costs were paid from investor funds.

The scheme also illustrates a specific dynamic in unregistered commodity pools: access to complex financial instruments is sold as a privilege. Minimum investments in the range documented here ($1 million, $1.6 million) filter out most working-class investors and attract those with substantial assets. The framing of exclusivity, the advisory board, the professional documentation, the language of sophisticated institutional-style management, all served to make wealthier targets feel that their due diligence had worked, when in fact it was being used against them.

The “Cost of a Life” Metric

What Now: Who to Watch and What to Do

Named Defendants

The CFTC’s complaint names Andrew M. Middlebrooks, identified as the sole owner, member-manager, CEO, and Chief Investment Officer of EIA All Weather Alpha Fund I Partners, LLC (a Delaware LLC, principal place of business in Novi, Michigan). As of the complaint filing, Middlebrooks resided in Dallas, Texas. Neither Middlebrooks nor EIA has ever been registered with the CFTC in any capacity.

What the Complaint Demands

The CFTC requests the court issue permanent injunctions barring Middlebrooks and EIA from trading on registered exchanges, entering commodity interest transactions, soliciting funds from investors, applying for CFTC registration, and acting in any officer or employee capacity at any CFTC-registered entity. It also demands full restitution to every person who sustained losses, disgorgement of all benefits received including salaries and fees, and civil monetary penalties for each individual violation.

What You Can Do

If you or someone you know sent money to EIA All Weather Alpha Fund, contact the CFTC directly at 1-866-366-2382 or through cftc.gov/ConsumerProtection. Victims of commodity fraud may be eligible for restitution through court orders.

Before placing any money with an unregistered investment pool: demand proof of CFTC registration, verify the registration independently at cftc.gov, demand independently verifiable audited financial statements from a named firm you can call directly, and confirm that any named advisory board members actually agreed to serve. Call the named auditor yourself. If you cannot verify a registration in five minutes, the investment is not worth the risk.

For mutual aid and grassroots resistance: local investor protection organizations, legal aid societies, and state securities regulators offer free consultations for fraud victims. In Michigan, contact the Michigan Department of Insurance and Financial Services at michigan.gov/difs. In Texas, where Middlebrooks resided at time of filing, the Texas State Securities Board at ssb.texas.gov handles investor complaints.

Share the CFTC complaint link with your networks. Fraud schemes like this survive on the assumption that victims will not talk to one another. When investors compare notes, patterns emerge. Patterns become evidence.