Dean of Massachusetts School of Law Asks IRS: Why was Madoff Approved as Non-Bank IRA Custodian?

In an interesting letter to the IRS, Dean Lawrence Velvel of the Massachusetts School of Law asks why Bernie Madoff was approved as a non-bank custodian for IRAs. Dean Velvel summarizes the IRS rules for approval as a non-bank trustee as follows:
To carry out Congress’ intent, the IRS has regulations requiring that, to be an [...]