On August 16th, the Second Circuit affirmed the method by which the Securities Investors Protection Act ("SIPA") trustee overseeing the liquidation of Bernard Madoff's broker-dealer calculated investors' net equity. The trustee properly used the "net investment method," which credited the amount of cash deposited by the investor less any amounts withdrawn. Although SIPA does not prescribe a single means to calculate net equity, the method selected in the instant case is more consistent with SIPA than any other method advocated. In re Bernard L. Madoff Investment Securities LLC.