UNITED STATES OF AMERICA

before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 99763 / March 18, 2024

Admin. Proc. File No. 3-21211

In the Matter of 

RICHARD GREGORY TILFORD

ORDER DIRECTING STATUS REPORTS

On October 19, 2022, the Securities and Exchange Commission issued an order 

instituting administrative proceedings (“OIP”) against Richard Gregory Tilford pursuant to 

Section 15(b) of the Securities Exchange Act of 1934.1 On October 16, 2023, the Commission

ordered Tilford to show cause by November 30, 2023, why he should not be deemed to be in 

default and why this proceeding should not be determined against him due to his failure to file an 

answer and to otherwise defend this proceeding.2 The order further provided that, if Tilford 

responded to the order to show cause, the Division could file a reply within 28 days of its 

service.

3

 Otherwise, the order directed the Division to file a motion for entry of an order of 

default and the imposition of remedial sanctions by December 28, 2023.4

1 Richard Gregory Tilford, Exchange Act Release No. 96103, 2022 WL 13564463 (Oct. 

19, 2022). 

2 Richard Gregory Tilford, Exchange Act Release No. 98754, 2023 WL 6879089 (Oct. 16, 

2023).

3

Id. at *2.

4

Id.
2

On November 30, 2023, Tilford, through his attorney, filed a response to the 

Commission’s show-cause order.

5 Tilford stated that he is interested in settling this proceeding 

and requested an additional 30 days so that he could have an in-person meeting with his counsel. 

The Division did not reply to Tilford’s response or file a motion for entry of an order of default 

and the imposition of remedial sanctions.

The parties are reminded that any settlement discussions in which they might be engaged 

do not automatically toll deadlines in this proceeding.6 Instead, a party may request that the 

Commission extend or stay deadlines based on settlement discussions, which the parties have not 

done.7 Indeed, it is unclear whether the parties are even engaged in settlement discussions.

Accordingly, the Division and Tilford are ORDERED to file status reports concerning the 

status of this proceeding by April 15, 2024. The status reports should state whether settlement 

negotiations are ongoing and, if so, whether the parties request a stay of deadlines based on the 

settlement negotiations. If settlement negotiations are not ongoing, the status reports should

address what, if any, further action the Commission should direct in this proceeding. The parties 

may file the status reports jointly or individually.

5 This response is available at https://www.sec.gov/files/litigation/apdocuments/3-21211-

2023-11-30-response.pdf. Tilford’s attorney failed to include a certificate of service showing 

that this filing was served on the Division. Tilford and his attorney are again reminded that each 

filing made in this proceeding must be served on the Division and accompanied with a certificate 

of service. See Rule of Practice 150, 17 C.F.R. § 201.150 (generally requiring parties to serve 

each other with their filings); Rule of Practice 151(d), 17 C.F.R. § 201.151(d) (“Papers filed with 

the Commission . . . shall be accompanied by a certificate stating the name of the person or 

persons served, the date of service, the method of service, and the mailing address or email 

address to which service was made, if not made in person.”). E-filing a document with the 

Commission is insufficient to meet these requirements. In this proceeding, the Division of 

Enforcement is represented by Matthew Gulde, Fort Worth Regional Office, Securities and 

Exchange Commission, 801 Cherry Street, Suite 1900, Fort Worth, TX 76102, guldem@sec.gov.

6 Tilford, 2023 WL 6879089, at *1.

7 Cf. Water Now, Inc., Exchange Act Release No. 96648, 2023 WL 173351, at *1 (Jan. 12, 

2023) (granting extension of time based on Division’s representation that respondent had 

retained counsel and was now engaged in settlement discussions); Thomas Garnette Martin, Jr., 

Advisers Act Release No. 6375, 2023 WL 5203103, at *1 (Aug. 14, 2023) (granting “motion to 

stay proceedings pending Commission consideration of an offer of settlement,” applying 

standards similar to those found in Rule of Practice 161(c)(2), 17 C.F.R. § 201.161(c)(2)).
3

The parties’ attention is directed to the e-filing requirements in the Rules of Practice.8

For the Commission, by the Office of the General Counsel, pursuant to delegated 

authority.

Vanessa A. Countryman

Secretary

8

See Rules of Practice 151, 152(a), 17 C.F.R. §§ 201.151, .152(a) (providing procedure for 

filing papers with the Commission and mandating electronic filing in the form and manner 

posted on the Commission’s website); Instructions for Electronic Filing and Service of 

Documents in SEC Administrative Proceedings and Technical Specifications, 

https://www.sec.gov/efapdocs/instructions.pdf. Parties generally also must certify that they have 

redacted or omitted sensitive personal information from any filing. Rule of Practice 151(e), 

17 C.F.R. § 201.151(e).