by John Darer CLU ChFC MSSC CeFT RSP CLTC
Anyone familiar with our blogs, the settlement planning industry, suitability standards, and the judicial role in approving minors’ settlements will understand that an investment boasting a tempting 99.05% annualized rate of return over 13 years, coupled with an extraordinary 149.87% standard deviation during the same period*, is highly unlikely to be a suitable choice for substantial allocation for injury victims who cannot tolerate such risk. (*Backtest by Curvo.eu, for standard deviaton in USD) In statistics, the standard deviation is a measure that is used to quantify the amount of variation of a set of data values and used above as a measure of volatility.
Recent Bitcoin Headlines
Bitcoin drops below $86,000 ahead of BoJ hike December 15, 2025
Bitcoin’s 2025 price predictions fall short of reality
“Analysts see more than a 90% chance the Bank of Japan will raise rates to about 0.75% during its December 18–19 meeting, marking a significant shift from decades of ultra-loose policy. Previous BoJ rate increases in March, July 2024, and January 2025 coincided with Bitcoin drops ranging from roughly 23% to 31%”.
Bitcoin briefly erases 2025 gains as crypto bleeds over weekend Cointelegraph.com November 16, 2025. Down 25% since reaching its all time high in October 2025.
Bitcoin Miners Are Pivoting to Powering AI Instead October 27, 2025
Bitfarms Dumps Bitcoin To Go All-In on AI as Crypto Mining Profitability Drops November 14, 2025
‘The Worst Outcome’—Bitcoin Suddenly Drops Under $100,000 Price As Stark Fed Warning Fuels Crash Fears November 15, 2025
According to Ray Dalio of the hedge fund Bridgewater Associates, it is generally not deemed suitable for significant allocation by either everyday or prominent investors. However, in 2025, Dalio revised his position, increasing it beyond the 2% allocation level he held in 2022, alongside gold. (see Ray Dalio Says 15% In Bitcoin Or Gold May Be Essential As Fiat Currencies Face Devaluation Risks July 28, 2025
Structured Settlements as a “Bridge to Crypto” a New Frontier in the Factoring Company Sales Pitch?
Says Anthony Cioppa, who runs America Annuity Funding LLC, a Boca Raton Florida factoring company “For years, we’ve helped people access their structured settlement payments early, so they could invest in real estate, launch a business, or take control of their finances. But today’s wealth-building playbook is being rewritten. With Bitcoin now embraced by institutions like BlackRock and the U.S. financial system adapting to crypto, we’ve entered a new era. Cioppa said in a press release,”Our Structured Strategy helps people reallocate capital from a slow-moving annuity into the best-performing asset class of the past decade.”
Cioppa continues “The process, which is fully compliant with all state-level Structured Settlement Protection Acts, begins with a lump-sum offer from Structured Strategy for the client’s future payments. Once the buyout is court-approved, the client receives their funds and Structured Strategy helps them navigate the process to acquire Bitcoin through an exchange or platform of their choice while the client maintains full control and ownership of their assets”.
Cioppa is a hard working guy who is very active on social media. You can see Cioppa promoting a sell structured settlements to crypto strategy on Instagram, YouTube and through press releases placed on various well known platforms..Cioppa does not appear to registered through FINRA or IAPD portals.
VASP Search Tool: Discover and Validate Crypto Providers
Increased Awareness of Legal, Structured Settlement, Settlement Planning and Judicial Communities is Sensible
I encourage each and every member of the structured settlement and settlement planning community and every trial lawyer in America to go to school on what Cioppa is promoting and decide for themselves whether such a strategy is appropriate for their particular clients’ or ward’s circumstances. Given that there are already laws on the books.
State laws already restrict investments for minors and incompetents at the time of settlement
It is unlikely that judges would approve the allocation of a minor’s or incompetent person’s settlement funds into cryptocurrency investments.
My message was made clear in prior posts. The volatility of Bitcoin and other crypto are generally not suitable for injury victims and probably would not be approved for injury victims where court approval of settlement is required.
For example, consider the New York law where New York CPLR § 1206. Disposition of proceeds of claim of infant, judicially declared incompetent or conservatee, states:
(c) the court may order that money constituting any part of the
property be deposited in one or more specified insured banks or trust
companies or savings banks or insured state or federal credit unions or
be invested in one or more specified accounts in insured savings and
loan associations, or it may order that a structured settlement
agreement be executed, which shall include any settlement whose terms
contain provisions for the payment of funds on an installment basis,
provided that with respect to future installment payments, the court may
order that each party liable for such payments shall fund such payments,
in an amount necessary to assure the future payments, in the form of an
annuity contract executed by a qualified insurer and approved by the
superintendent of financial services pursuant to articles fifty-A and
fifty-B of this chapter. The court may elect that the money be deposited
in a high interest yield account such as an insured "savings
certificate" or an insured "money market" account. The court may further
elect to invest the money in one or more insured or guaranteed United
States treasury or municipal bills, notes or bonds. This money is
subject to withdrawal only upon order of the court, except that no court
order shall be required to pay over to the infant who has attained the
age of eighteen years all moneys so held unless the depository is in
receipt of an order from a court of competent jurisdiction directing it
to withhold such payment beyond the infant's eighteenth birthday.
Notwithstanding the preceding sentence, the ability of an infant who has
attained the age of eighteen years to accelerate the receipt of future
installment payments pursuant to a structured settlement agreement shall
be governed by the terms of such agreement. The reference to the age of
twenty-one years in any order made pursuant to this subdivision or its
predecessor, prior to September first, nineteen hundred seventy-four,
directing payment to the infant without further court order when he
reaches the age of twenty-one years, shall be deemed to designate the
age of eighteen years; or
(d) the court may order that the property be held for the use and
benefit of such infant, incompetent or conservatee as provided by
subdivision (d) of section 1210.
A regulatory gap exists
Structured settlement annuitants lack protections when solicited into structure settlements to cryptocurrency exchanges by unlicensed salespeople.
- Consider that the annuity industry officially has secured uniformity in sales regulations across all 50 states.
- The annuity sales regulation is modeled after an update from the National Association of Insurance Commissioners (NAIC).
- The NAIC’s model aligns with the Securities and Exchange Commission’s Regulation Best Interest (Reg BI) requirements.
- New York remains the lone outlier, but maintains a stricter annuity sales rules rooted in a fiduciary standard of care. States acted swiftly in updating their regulations to avoid federal oversight of fixed annuities by the SEC.
When it comes to structured settlements for crypto exchanges, it seems sensible that state regulators study transactions that have already occurred
- How was the sale of structured settlement payment rights presented to the judge?
- What was on the sellers declaration as the reason for selling? Was crypto on the declaration, so the judge could properly evaluate, as the Structured Settlement Protection Acts (in effect in all 50 states and DC) intend?
- Did the seller received Independent Professional Advice? Remember the majority of states DO NOT require Independent Professional Advice.
It seems sensible that compliance departments at securities firms and financial advisory firms become aware of these types of transactions as they monitor the activities of representatives of their firms with respect to alternative assets and overall suitability requirements,
“Bits and Bobs”
1. Cryptocurrency Crash Deepens: $1.3 Billion Wiped Out In 24 Hours November 4, 2025
2. A Closer Look at Bitcoin’s Volatility by Zack Wainwright Fidelity Digital Asset May 1, 2024
3. In a 2022 episode of the We Study Billionaires podcast, billionaire hedge fund manager Ray Dalio was asked by co-host William Green whether allocating 1% to 2% of one’s portfolio to bitcoin was reasonable. “I think that’s right,” Dalio replied. Dalio has served as co-chief investment officer of the world’s largest hedge fund, Bridgewater Associates, since 1985. Dalio is regarded as one of the greatest innovators in the finance world, having popularized many commonly used practices, such as risk parity, currency overlay, portable alpha and inflation indexed bond management.
4. Five Ways Fraudsters May Lure Victims Into Scams Involving Crypto Asset Securities – Investor Alert | Investor.gov Investor Bulletin Securities and Exchange Commisions (SEC) May 29, 2024
5. Crypto Freefall Gives Retirement Plans New Reason to Avoid Risk [Bloomberg May 17, 2022]
“Upheaval in the cryptocurrency market puts teeth in a US Labor Department push to discourage retirement plans from adding digital assets to their 401(k) plan lineups. Crypto markets lost more than $270 billion just weeks after the department’s Employee Benefits Security Administration issued strongly worded guidance (CAR No. 2022-01) all but banning retirement plans from offering crypto assets.
6. On June 29, 2022 an article by Alex Hern and Dan Milmo appeared in The Guardian with the headline “Crypto crisis: how digital currencies went from boom to collapse “Savers talk of devastating losses as assets such as bitcoin and ‘stablecoins’ like terra fell sharply”
7. On August 1, 2022 Nerd Wallet published an article “After a Fall, Crypto Winter Sets In“
9.. The Curious Case of QuadrigaCX – Energent Media June 23, 2025 “What was at one point the leading cryptocurrency exchange in Canada, QuadrigaCX has devolved into a tangled mess of lost user funds, creditor protection initiatives, and mystery surrounding the deceased founder and missing funds. Now, QuadrigaCX is officially transitioning into bankruptcy following a ruling by the Nova Scotia Supreme Court that transfers the exchange out of the Companies’ Creditors Arrangement Act (CCAA), which it has been operating under since late January 2025″
10. If that’s not enough, on April 26, 2022, the New Jersey law firm of Console & Associates discusses data breaches related to crypto
“Over recent years, Bitcoin, Ethereum, Litecoin and other cryptocurrencies have surged in popularity and value as more and more people see the value that the asset class presents. However, hackers see the fact that everyday investors are now holding cryptocurrency as a major opportunity. In fact, over the past year, there have been several high-profile cryptocurrency hacks resulting in the loss of more than $14 billion dollars”.
11. Comedian Bill Murray loses $186,000 to hackers Bill Murray recently held an NFT auction in which most of the recouped funds were in the said wallet. The statement showed that the hacker drained 90% of the entire funds in the wallet, leaving just a little over $500 in the wake of the act. Cryptopolitan September 3, 2022
12. May 12, 2022 New York Post reports “Bitcoin’s plunge slashes the fortunes of major crypto billionaires”, the Winklevoss twins lost 40% of their respective fortunes, more than $2 Billion each at the time the story was poublished in the NY Post.. Sam Bankman-Fried, the founder and CEO of crypto exchange FTX, has lost roughly half of his on-paper fortune since March and is now worth about $11.3 billion”. Crypto billionaires losing fortunes as bitcoin tumbles (nypost.com)
13. “We’ve only scratched the surface of how bad the crypto crime wave has gotten June 13, 2022 LA Times by Matt Pearce
“These are tough days for cryptocurrency investors. Values are cratering. Prominent crypto firms are faltering. And it’s coming after a massive surge of criminal fraud that has been pummeling crypto users with unknown billions of dollars in losses with little relief in sight”
14. Bitcoin is down roughly 60% this year and some other tokens have lost even more. The ninth month of the year has historically been one of the worst for the largest cryptocurrency, falling every September since 2017. Bitcoin has averaged an 8.5% drop for the month over the past five years, according to Bespoke Investment Group”. August 31, 2022 Bloomberg
15. Says Fort Lauderdale’s and Owings Mills Maryland’s Richart Ruddie (also self-styled as “Richart Ruddie Annuity”), a bête noire of sorts in structured settlement circles due to his association withJRR Funding, AnnuitySold and related companies, which were banned from doing business in Maryland for 7 years from January 2018 for fraud: Frosh announces compensation in Structured Settlements lawsuit – The Southern Maryland Chronicle
“Losses of Bitcoin Value – As the shining light of the cryptocurrency industry, Bitcoin advanced in value to a high watermark of $69,000, but the erosion of that value has declined since November of 2021. The currency currently trades roughly around the $20,000 mark a high mark in 2018 that now feels like a low mark for the worlds most well known coin. That’s almost an 80% loss in just over 6 months”.- The Crypto Updates July 12, 2022
On a $1,000,000 investment that’s a $800,000 loss. Could you handle it emotionally? What if you were not physically able to work? What if that money represented compensation for the loss of your spouse, parent or child?
16. Bitcoin, Ethereum Nosedive: $445M Liquidated From Crypto Market (msn.com) September 19, 2022
17. Bitcoin Loses Steam Bitcoin is currently trading at $19,100, down 14% in the past week and down by around 4% over the past 24 hours. The world’s largest cryptocurrency is now down by a staggering 75% from its all-time high in November 2021 when its market capitalization was $1.27 trillion. It is now down to $366 billion.
18. Crypto: Treasury’s financial stability watchdog says fraud is rampant in digital currency markets (cnbc.com) December 16, 2022
How Good a Bull Rider Are You?
Those who hung on from 2022 until now, weathering the recent pullbacks, have likely come out ahead. But if you’re considering this strategy, you’d better respect the standard deviation. It’s like riding a bull at a rodeo—how long can you hang on to that bucking bronco before it throws you off?
I’m not sure we need to keep dragging this out. Is this the kind of rollercoaster ride we want to strap a vulnerable group of investors into?
The “Bitcoin-Shitcoin” Expression
Next time someone tries to “poo-poo” the renewable credentials of Bitcoin mining, remember AmityAge Mining Farm. Founded by Gabriel Kozak and Dušan Matuska, the Bitcoin mining facility uses human and animal waste to generate electricity for mining”. According to Matuska, using renewable energies such as biogas “shows that we can really accelerate the adoption of these renewables and make their return on investment higher in the end,” while it’s also a cheap energy source. An ecologically sound and low-cost way of generating electricity, biogas electricity plants convert waste into methane gas due to a fermentation process. The gas is then burned as fuel”. Read the full story here
In 2020, John McAfee opined that “Bitcoin is the true Shitcoin“. Oh dear!
Structured settlement annuitants receiving stable tax exempt income shouldn’t be groomed into selling structured settlement payment rights to pennies on the dollar merchants from South Florida or Maryland to put into volatile investments with a 150% standard deviation
Beware the “Muthaforkers” | Warning to 18-21 Year Olds With Structured Settlements February 22, 2018
Last updated December 15, 2025