Participants in the Madoff investment scandal the receiver assigned to Madoff's Ponzi scheme, extracted a settlement from Tremont worth over one billion dollars. A $1 billion class-action federal lawsuit was filed in Colorado against Fiserv, Inc. of Brookfield, Wisconsin whose subsidiaries were custodians for pension or IRA accounts and invested with Madoff. The complaint alleges Fiserv failed "to hold and safeguard assets entrusted to it" by about 800 Madoff customers who had been told to hire Fiserv to handle their accounts with him. Fiserv is accused of breach of fiduciary duty, fraud, negligence and aiding and abetting breach of fiduciary. Fiserv sold its investment account administration
Multi-level marketing have even gone so far as to say at best modern MLMs are nothing more than legalized pyramid schemes with one stating "Multi-level marketing companies have become an accepted and legally sanctioned form of pyramid scheme in the United States" while another states "Multi-Level Marketing, a form of Pyramid Scheme, is not necessarily fraudulent." In October 2010 it was reported that multilevel marketing companies were being investigated by a number of state attorneys general amid allegations that salespeople were primarily paid for recruiting and that more recent recruits cannot earn anything near what early entrants do. Industry critic Robert L.