I agree a bear market could expose them. We don't exactly know how they are doing the accounting (Dollars or BTC) but it took the 2008 subprime financial crisis to expose the Bernie Madoff investment scam. Expectation that there is a greater chance of it failing in a bear BTC market is well reasoned (note: a scam might still be able to survive BTC bear market.)(if they are smart, and indications are they are, they have likely thought of this.)