On August 15th, the Second Circuit affirmed the dismissal of claims asserted by victims of Bernie Madoff's Ponzi scheme against their homeowner's insurance policy which included a "Fraud Safeguard" endorsement. The policy holders had invested over $4.3 million with Madoff and withdrew over $4.5 million. Their last statement showed a balance of over $8.5 million. Although the Court holds that the policy covered Ponzi scheme losses, it finds that the plaintiffs suffered no loss. Additionally, the policy specifically covers only direct losses and not losses associated with any potential opportunity costs. Horowitz v. AIG, Inc. (Summary Order).