Here is one more criticism, that hasn't been pointed out; the wasting of time, if not money. You might eventually get out of the position without a loss or even with a small gain, but you have already spent 3 weeks trying to fight the trend with averaging down.
So that is 3 weeks wasted when you weren't making money. And as the way the market keeps going, it could be another 1-2 weeks before it finally turns down. Now if I understand the strategy well, if the NFV moves close to the real value, you would close out the position. Let's assume we actually have a huge downturn, but depending on the NFV, there is a chance you wouldn't ride it down into big profits, but close it out early in the move.
So in short, the strategy:
1. wastes time when huge 50+ moves are there to be taking advantage of,
2. and it doesn't necesserily stays in the position long enough for big profits once the market moves favorably....
Just a few thoughts for the weekend...