Bogdan Drăgoi chairman of SIF Banat Crişana self-denouncing on market manipulation

Shocking! The chairman of SIF Banat Crişana (SIF 1) Bogdan Drăgoi self-denounces in the Communique sent to the Bucharest Stock Exchange on July 30, 2020: "Prior to April 2019, the differences in value between the two evaluation methods have not been significant enough to substantially distort the value of the shares of SIF Imobiliare." (For context, see EDITOR'S NOTE).

EDITOR'S NOTE

Bogdan Drăgoi is referring to two stock evaluation methods he had detailed before:

"[...] the evaluation of the shares of SIFI for the calculation of the NAV is being conducted through different methods, depending on whether or not the market has seen any trades in the last 30 days, as follows:

- If trades have occurred in the last 30 days of trading, the shares of SIFI are valued according to the provisions of art. 113 letter (a) item 2 of ASF Regulation no. 9/2014 at the reference price for the day when the calculation is being performed, in the case of shares traded via trading systems others than the regulated market, including via other alternative trading systems, provided by the operator of the respective trading system, for each of the segments of the system in question. The price used as reference price is being calculated based on the trading activity of the day which the calculation is made for, used as benchmark in the opening of the next day's trading session";

- If no trades are recorded for more than 30 days, the evaluation of the shares of SIFI is made according to the provisions of art. 115 paragraph (2) and paragraph (1) letter a), item (1) of ASF Regulation no. 9/2014, at "the book value per share, as established based on the latest approved annual financial statement of the entity in question".

(See the entire Communique here)

Denying that the differences in the amounts obtained via the two evaluation methods would have been significant, Bogdan Drăgoi explicitly admits that he tolerated a distortion of the value of the shares of SIF Imobiliare, but denies that it would have been "substantial", as if there were some legal limits on the distortion. that the law allows.

No, there aren't.

The tolerance to distortion expressed by Bogdan Drăgoi is legally unacceptable, and officially announcing it represents a self-denunciation broadcast through the BSE.

But that is not all...

SIF1 chairman Bogdan Drăgoi is not shy about providing false information to the BSE, because the differences in the amounts derived from the two evaluation methods, prior to April 2019, amount to tens of millions of Euros.

For instance, the difference that Bogdan Drăgoi is speaking about was, on September 28, 2018, of 248.5 million lei (about 50 million Euros), as it follows from its own documents submitted to the BSE and which are public. (See the NOTE below)

• Note to the status of the reporting to the BSE of the assets and liabilities of SIF Banat Crişana on September 28, 2018:

"We inform investors that the value of the NAV of SIF Banat Crişana on September 28, 2018 posted an increase of 214,470,703 lei representing 8.7%, compared to the value of 31.08.2018. This increase is owed to the significant increase of the block of shares held in SIF Imobiliare PLC, which on September 28, 2018 is valued at 405 million lei, compared to 156.5 million lei on August 31, 2018. We make the mention that SIF Imobiliare PLC is an issuer listed on the BSE on the AeRO market (traded under the symbol SIFI), but with a low liquidity and with sporadic trading.

The significant variation of the value of the interest in SIF Imobiliare PLC is due to the evaluation methodology".

This jump of 248.5 million lei in the so-called "market value" of SIF Imobiliare is generated by the trade (that solitary trade!) with ...two (2!) shares in SIFI, at the price of 90 lei/share, of September 20, 2018.

The trade inflated SIFI by 248.5 million lei, and SIFI inflated the NAV of SIF Banat Crişana by the same amount.

But perhaps without that bump, the NAV of SIF Banat Crişana would have suffered a decrease of 34 million lei, so that, instead of the result rising by the same amount as that of SIFI, it settled for an increase of just 214.5 million lei.

• Inference:

- September 20 comes before April 2019;

- the difference between 404 million lei and 156.5 million lei is 248 million lei, which could not be considered negligible for any of the SIFs;

- therefore, SIF1 chairman Bogdan Drăgoi is not shy about providing false information to the BSE, stating that "Prior to April 2019, the differences in value between the two evaluation methods have been insignificant".

The manipulation of the NAV at SIF Banat Crişana didn't begin srecently, it did not begin on April 25th, when Bogdan Drăgoi was officially saying that he started asking the ASF to stop its distortion, instead, it has been going on for years.

The manipulation has been going on for seven years.

The manipulation began with the creation and listing of SIF Imobiliare.

The situation strongly suggests that SIF Imobiliare was created and listed with the goal of manipulating the NAV of SIF Banat Crişana (other ancillary purposes may exist).

BURSA makes available to its readers the complete history of the transactions with the shares of SIF Imobiliare, from the date the company was listed on the AeRO market and until the present day.

From what we've noticed, SIFI trades have occurred at times which were handy for inflating the NAV of SIF Banat Crişana; there times of stagnation, when the NAV of SIF Banat Crişana seems to be calculated correctly, which alternate with periods where the pace of the trades with one share of SIFI consistently and constantly distort it, from one month to the next.

According to our beliefs, the Total Assets, the Net Assets and the NAVPS for SIF 1, reported monthly via Appendix 16, have been overvalued (calculated based on the market price of SIFI) in the following periods:

December 2013, the whole year of 2014, January-March 2015, July 2015, December 2017, March-April 2018, September-October 2018, April-May 2019, May-June 2020.

Based on the book value (I think that these are correct values that reflect the fair and real value of the patrimony viewed through the prism of the SIFI evaluation), they were calculated in the following periods: April-May-June 2015; August-December 2015, the entire year of 2016, January-November 2017, January-February 2018; May-August 2018; November-December 2018; January-March 2019; June 2019-April 2020.

None of the BURSA journalists have experience as investment fund managers and, therefore, I would not bet my life on the accuracy of these calculations, but they cannot be entirely wrong and I publish them because they are illustrative when it comes to the practices of the manager of SIF Banat Crişana.

It should be mentioned that Bogdan Drăgoi received the ASF approval for the position of chairman of SIF Banat Crişana on August 19, 2015 and, therefore, he bears no responsibility for what his predecessors did.

But for the manipulation up until today, he is responsible, as he is for the falsification of the information submitted to the BSE one week ago.

On August 19, 2020, just two weeks from now, Bogdan Drăgoi should celebrate five year at the helm of SIF Banat Crişana, but he is at the center of a market manipulation that rivals that of Rompetrol and FNI.