Can anyone chime in as to what the fiduciary responsibility is if you have a liability but no responsibility to pay it? If I promise to store $1 for every $1 taken but also don't agree to actually ever pay out, is it illegal to not actually store the $1, or is it just dishonest?
but now you have a (theoretical) liability of $1 as well, because you have an obligation to allow redemption.
Unless, of course, you assume no redemption, or you intend to not honor the redemption.