Mr. Nickel,
The ASC does not investigate and charge an individual unless there is a reasonable certainty of obtaining a conviction. They obviously have reason to believe an infraction has occurred and are pursuing it accordingly. Your explanation of events is lame. Whatever the case, it will all come out in the wash.
This Specfund thing has been raised before as well without coherent explanation. I wonder if these two activities are linked in some way. After all there was a previous disclosure infraction with regard to said fund.
Cheers