UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of: 

Scott Becker, 

Respondent.

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CFTC Docket No. 22-14

ORDER INSTITUTING PROCEEDINGS PURSUANT TO 

SECTION 6(c) AND (d) OF THE COMMODITY EXCHANGE ACT, MAKING 

FINDINGS, AND IMPOSING REMEDIAL SANCTIONS

I. INTRODUCTION

The Commodity Futures Trading Commission (“Commission”) has reason to believe that 

from in or about March 2020 to at least the end of March 2021 (“Relevant Period”), Scott Becker

(“Becker” or “Respondent”) violated Section 6(c)(1) of the Commodity Exchange Act (“Act”), 

7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. §180.1(a)(1)–(3) (2021) of the 

Commission Regulations (“Regulations”) promulgated thereunder. Therefore, the Commission 

deems it appropriate and in the public interest that public administrative proceedings be, and 

hereby are, instituted to determine whether Respondent engaged in the violations set forth herein 

and to determine whether any order should be issued imposing remedial sanctions. 

In anticipation of the institution of an administrative proceeding, Respondent has 

submitted an Offer of Settlement (“Offer”), which the Commission has determined to accept. 

Becker admits the facts set forth below, acknowledges that his conduct violated the Act and 

Regulations, admits the Commission’s jurisdiction over him and the subject matter of these 

proceedings, consents to the entry of this Order Instituting Proceedings Pursuant to Section 6(c) 

and (d) of the Commodity Exchange Act, Making Findings, and Imposing Remedial Sanctions

(“Order”), and acknowledges service of this Order. 

II. FINDINGS

The Commission finds the following: 

A. SUMMARY

During the Relevant Period, while employed at an investment management firm

headquartered in New York (“Investment Manager 1”) that served as the investment manager of 
2 

private investment fund (“Investment Fund 1”), Becker and others at Investment Manager 1 

engaged in a fraudulent scheme whereby he intentionally and/or recklessly made false or 

misleading statements of material facts and/or omitted to state material facts necessary to make 

the statements made not untrue or misleading to Investment Fund 1’s swap counterparties in 

order to secure additional capacity for Investment Fund 1 to enlarge its swap trading positions; to 

obtain or maintain favorable margin rates; and, during the week of March 22, 2021, to attempt to 

satisfy margin calls. The false or misleading information Becker provided included information 

about the size, composition, and liquidity of positions in Investment Fund 1’s entire portfolio 

across financial institutions, as well as information provided in connection with attempts to 

satisfy Investment Fund 1’s margin calls. The false or misleading information provided by 

Becker concerned facts that were important for Investment Fund 1’s swap counterparties to 

know in making credit and risk management decisions about Investment Fund 1’s swap 

portfolios at those respective counterparties, including decisions regarding margin and position 

size. By virtue of this conduct, Becker violated Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and 

Regulation 180.1(a)(1)–(3), 17 C.F.R. § 180.1(a)(1)–(3) (2021). 

********** 

 In accepting the Offer, the Commission recognizes Becker’s entry into a formal 

cooperation agreement (“Cooperation Agreement”) with the Division of Enforcement 

(“Division”), which sets forth the terms of his agreement to cooperate with the Commission and 

the Division in connection with any investigation, litigation, or proceeding to which the 

Commission is a party relating to the subject matter of this Order and/or as described in the 

Cooperation Agreement (the “Proceedings”). 

B. RESPONDENT 

Scott Becker is an individual residing in Goshen, New York. During the Relevant 

Period, Becker was the Director of Risk Management of Investment Manager 1. Becker has 

never been registered with the Commission in any Capacity. 

C. FACTS 

1. Background

During the Relevant Period, Becker was the Director of Risk Management at Investment 

Manager 1, a limited partnership formed in Delaware pursuant to Delaware law and 

headquartered in New York that served as the investment manager of Investment Fund 1. 

Investment Fund 1 was a limited partnership formed in Delaware pursuant to Delaware law and 

headquartered in New York that was a private investment vehicle. Since around 2018, in his role 

at Investment Manager 1, Becker had responsibility for communicating with the credit teams and 

other representatives of financial institutions that were swap counterparties to Investment Fund 1 

(“Swap Counterparties”). 

During the Relevant Period, Investment Manager 1, as investment manager for 

Investment Fund 1, caused Investment Fund 1 to enter into numerous swap transactions with 
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various Swap Counterparties, including several Swap Counterparties provisionally 

registered with the Commission as swap dealers. Investment Fund 1 sought exposure to equities, 

among other ways, by entering into long total return swaps (“TRS”)1

 based on single name 

securities. In order to hedge the risk imposed by these long positions, Investment Fund 1 also 

entered into certain short TRS positions which were based on: (i) a custom index of more than 

nine component securities (“custom basket swaps”); or (ii) an exchange traded fund that 

provided exposure to an index of hundreds of component securities (“ETF swaps,” and together 

with the custom basket swaps, “broad-based security index TRS”).2 

Investment Fund 1’s swap transactions were generally subject to credit and risk 

limitations imposed by Investment Fund 1’s Swap Counterparties. For example, certain of 

Investment Fund 1’s Swap Counterparties permitted Investment Fund 1 to transact on a 

leveraged basis, provided it met certain margin requirements. In addition to margin 

requirements, certain of Investment Fund 1’s Swap Counterparties set other formal or informal 

credit and risk-related limitations on Investment Fund 1’s ability to transact swaps. Such 

limitations included setting a cap on the total notional value of Investment Fund 1’s portfolio 

with those respective Swap Counterparties; requiring that Investment Fund 1 maintain a certain 

ratio of long to short positions in its portfolio at that Swap Counterparty (which Investment Fund 

1 met on the short side primarily by maintaining short broad-based security index TRS 

positions); and/or requiring that Investment Fund 1 enter into highly liquid diversified swap 

positions. 

Starting around March 2020, Investment Fund 1 began to increase its exposure in certain 

long single name TRS positions, causing its highly leveraged portfolio at particular Swap 

Counterparties, as well as its overall portfolio across Swap Counterparties, to become more 

concentrated. Through the rest of 2020 and into 2021, Representatives of Investment Fund 1 

periodically communicated with representatives of its Swap Counterparties to provide 

information about Investment Fund 1 and to seek additional capacity to increase the size of its 

long single name TRS positions. Although Investment Fund 1’s portfolio became more 

concentrated in long single name TRS positions, its portfolio at its Swap Counterparties also 

included short broad-based security index TRS positions, which were needed to satisfy 

counterparty credit and risk management requirements. In several instances, in order to increase 

the size of its concentrated long single name TRS positions while obtaining or maintaining 

favorable margin rates, Investment Fund 1 also had to increase the size of its short broad-based 

security index TRS positions. 

 

1

 A total return swap is an agreement between two counterparties where one party, the seller of the credit risk, 

agrees to pay the other party the difference in value of a specified asset, index or derivative of an asset or an index, 

multiplied by an agreed-upon notional value should that value increase between specified periods of time. In 

exchange, the other party, the buyer of the credit risk, agrees to pay the difference in value of the specified asset 

multiplied by the notional value should that value decrease between the same specified periods of time. 

https://www.cftc.gov/MarketReports/SwapsReports/DataDictionary/index.htm. 

2

 The broad-based security index TRS had an index of more than nine or more component securities and did not 

meet any of the other criteria for a narrow-based security index set forth in Section 1a(35)(A) of the Act, 7 U.S.C. 

§ 1a(35)(A). 
4 

During the beginning of the week of March 22, 2021, certain of Investment Fund 1’s 

concentrated long single name TRS positions dropped in value dramatically. Thereafter, certain 

of Investment Fund 1’s Swap Counterparties issued substantial margin calls on its swap 

portfolio, and by March 25, 2021, Investment Fund 1 was unable to meet all of its margin calls 

due that day. 

2. Becker’s Participation in a Fraudulent Scheme 

During the Relevant Period, Becker, while acting in his role at Investment Manager 1, 

participated in a fraudulent scheme where he intentionally and/or recklessly provided false or 

misleading information and/or omitted to state material facts necessary to make that information 

not untrue or misleading. Among other things, Becker provided false or misleading information 

and/or omitted to state material facts about the size, composition, and liquidity of positions in 

Investment Fund 1’s entire portfolio across Swap Counterparties in order to secure additional 

capacity for Investment Fund 1 to enlarge its long single name TRS positions; to obtain or 

maintain favorable margin rates; and, during the week of March 22, 2021, to attempt to satisfy 

margin calls. The false or misleading information provided by Becker concerned facts or 

omitted facts that were important for Investment Fund 1’s Swap Counterparties to know in 

making credit and risk management decisions about Investment Fund 1’s swap portfolios at 

those respective Swap Counterparties. 

a. Becker’s False or Misleading Statements Concerning Investment Fund 

1’s Portfolio 

During the Relevant Period, Becker engaged in discussions with representatives of 

Investment Fund 1’s Swap Counterparties who were gathering information about Investment 

Fund 1 in order to make credit and risk management decisions about its portfolio at their 

respective institutions, which included both long single name TRS positions and short broadbased security index TRS positions. During these discussions, Becker was typically asked 

questions about Investment Fund 1’s largest positions, gross exposure, unencumbered cash, and 

liquidity, among other things. In several instances, Becker intentionally and/or recklessly 

provided answers that were false or misleading. 

For example, when asked about Investment Fund 1’s largest positions across its entire 

portfolio (including at other Swap Counterparties), Becker intentionally misrepresented to its 

Swap Counterparties that Investment Fund 1’s largest position was approximately 35% of its net 

asset value (“NAV”), despite knowing that this 35% figure was not true. For example, in late 

2020 or early 2021, Becker had a telephone call with a representative of Swap Counterparty 1 

and despite knowing Investment Fund 1’s largest long single name TRS position had grown to 

significantly larger than 35% of Investment Fund 1’s NAV, he falsely represented that it was 

only 35% of Investment Fund 1’s NAV. Becker intentionally made similar misrepresentations 

about the size of Investment Fund 1’s largest long TRS single name position to representatives of 

Swap Counterparty 2 on a recorded telephone call on March 8, 2021 and to representatives of 

other Swap Counterparties in late 2020 or early 2021. 

As another example, Becker also intentionally made misrepresentations concerning the 

composition of Investment Fund 1’s portfolio across its Swap Counterparties. For example, on 
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March 8, 2021, in a recorded telephone call with representatives of Swap Counterparty 2, Becker 

intentionally falsely represented that Investment Fund 1’s top ten largest positions at Swap 

Counterparty 2 were materially different than the top ten positions in Investment Fund 1’s 

overall portfolio in order to conceal the true size of its largest long TRS single name positions.3 

Also, during the March 8, telephone call, Becker falsely represented that Investment Fund 1’s 

position in a particular equity, Company 1, was “much larger” at Swap Counterparty 2 than it 

was at any other Swap Counterparty. 

Becker also intentionally and/or recklessly misrepresented to Swap Counterparties that 

Investment Fund 1’s portfolio across its swap counterparties was more liquid than it was. For 

example, on March 8, 2021, on a recorded telephone call with Swap Counterparty 2, Becker 

intentionally or recklessly represented that Investment Fund 1 could liquidate almost its entire 

portfolio in about two weeks without significantly impacting the market price of the securities in 

the portfolio. After Swap Counterparty 2 asked for additional information on Investment Fund 

1’s liquidity, in a recorded telephone call on March 10, 2021, Becker represented that Investment 

Fund 1 could liquidate: (i) about half of its total portfolio in ten days; (ii) seventy-five per cent 

of its total portfolio within twenty days; and (iii) its entire portfolio in about a month. Becker 

further stated that this was based on liquidation at a rate of 10-15% of average daily trading 

volume, which was meant to convey liquidation at a rate that would not significantly impact the 

market price of the securities in the portfolio, which included, in large part, the long single name 

TRS positions, that were to be sold. At the time Becker made these representations to Swap 

Counterparty 2, Becker knew or was reckless in not knowing, based on the size and composition 

of Investment Fund 1’s portfolio compared to relevant average daily trading volumes, that his 

statement that the entire portfolio could be liquidated in the stated time-frame was false or 

misleading. Becker knew or was reckless in not knowing that Investment Fund 1’s portfolio 

could not be unwound at the stated rate and in the stated time period without significantly 

impacting the market price, based on market conditions and the positions to be liquidated. 

Becker intentionally and/or recklessly made similar misrepresentations about the liquidity of 

Investment Fund 1’s portfolio to representatives of other Swap Counterparties in late 2020 or 

early 2021. 

Becker intentionally and/or recklessly made false statements about Investment Fund 1 in 

an effort to maintain and/or purchase additional long single name TRS positions and to obtain or 

maintain favorable margin rates. Becker understood that if he had told the truth about 

Investment Fund 1’s portfolio, its Swap Counterparties might take measures such as increasing 

Investment Fund 1’s margin requirements or limiting, restricting, or reducing Investment Fund 

1’s trade capacity. By Becker making false statements to Investment Fund 1’s Swap 

Counterparties, Investment Fund 1 was able to maintain and/or enlarge its long single name TRS 

positions, maintain existing trade capacity, secure additional capacity to enlarge its TRS 

positions, and obtain or maintain favorable margin rates. Becker also understood that Investment 

Fund 1 needed to maintain and/or increase its short exposure in order to maintain favorable 

margin rates and/or enlarge its long single name TRS positions. As a practical matter, 

Investment Fund 1 typically increased its short exposure through broad-based security index 

 

3

 In a March 24, 2021 recorded telephone call with representatives of Swap Counterparty 2, Becker again falsely 

indicated that Investment Fund 1’s largest positions at Swap Counterparty 2 were different than its positions at other 

financial institutions. 
6 

TRS positions, as those positions had been approved and encouraged by several Swap 

Counterparties as a risk-reducing measure. 

b. Becker’s False or Misleading Statements in Connection with Attempting 

to Meet Margin Calls During the week of March 22, 2021. 

During the week beginning March 22, 2021, Becker intentionally and/or recklessly 

continued to make false or misleading statements to representatives of Investment Fund 1’s 

Swap Counterparties in connection with attempts to meet Investment Fund 1’s margin calls. 

For example, on March 24, 2021, Investment Fund 1 faced substantial margin calls due 

by the close of business that day, and Investment Fund 1 needed to request the return of excess 

capital in its accounts at certain Swap Counterparties in order to meet margin calls from other 

Swap Counterparties. After representatives of Investment Manager 1 requested that Swap 

Counterparty 6 return excess margin to Investment Fund 1, Becker intentionally falsely 

represented to Swap Counterparty 6 that Investment Fund 1’s cash position was $9 billion when, 

in fact, the true amount of available cash was significantly less in order to conceal from 

Counterparty 6 that Investment Fund 1 needed these excess funds to immediately meet its margin 

calls. Becker also intentionally provided false assurances that Investment Fund 1 was not in a 

distress situation. Becker made these false representations in order to avoid Swap Counterparty 

6 from withholding or delaying the release of its excess funds. After the call, Swap Counterparty 

6 returned about $250 million in excess margin to Investment Fund 1 that day. 

Becker intentionally provided this false or misleading information in order to secure the 

immediate release of Investment Fund 1’s excess margin. Becker understood that if he had told 

the truth, Investment Fund 1’s counterparties may have withheld or delayed the return of excess 

margin until the Swap Counterparties gained a better understanding of Investment Fund 1’s 

financial solvency and ability to meet upcoming margin calls. By Becker providing false 

information to Investment Fund 1’s counterparties, Investment Fund 1 was able to secure the 

release of its excess margin, to the detriment of those Swap Counterparties. 

III. LEGAL DISCUSSION 

A. Use of a Manipulative or Deceptive Device in Violation of Section 6(c)(1) of the Act 

and Regulation 180.1(a)(1)-(3) 

Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), makes it “unlawful for any person, directly or 

indirectly, to use or employ, or attempt to use or employ, in connection with any swap, . . . any 

manipulative or deceptive device or contrivance, in contravention of such rules and regulations 

as the Commission shall promulgate.” Regulation 180.1(a)(1)-(3), 17 C.F.R. § 180.1(a)(1)-(3) 

(2021), in turn, provides that “it shall be unlawful for any person, directly or indirectly, in 

connection with any swap, . . . to intentionally or recklessly: (1) Use or employ, or attempt to 

use or employ, any manipulative device, scheme, or artifice to defraud; (2) Make, or attempt to 

make, any untrue or misleading statement of a material fact or to omit to state a material fact 

necessary in order to make the statements made not untrue or misleading; or (3) Engage, or 

attempt to engage, in any act, practice, or course of business, which operates or would operate as 

a fraud or deceit upon any person.” 
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As described above Becker, among other things, intentionally or recklessly, directly and 

indirectly, in connection with swaps: (a) used or employed, or attempted to use or employ, 

manipulative devices, schemes, and artifices to defraud; (b) made, or attempted to make, untrue 

or misleading statements of material facts; (c) omitted to state material facts necessary in order to 

make statements made not untrue or misleading; and (d) engaged, or attempted to engage, in 

acts, practices, and courses of business, which operated or would operate as a fraud or deceit 

upon any person, in violation of Section 6(c)(1) of the Act, and Regulation 180.1(a)(1)-(3).4

IV. FINDINGS OF VIOLATION 

Based on the foregoing, the Commission finds that, during the Relevant Period, Becker

violated Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. 

§ 180.1(a)(1)–(3) (2021). 

V. OFFER OF SETTLEMENT 

Becker has submitted the Offer in which he: 

A. Acknowledges service of this Order; 

B. Admits the jurisdiction of the Commission with respect to all matters set forth in this 

Order and for any action or proceeding brought or authorized by the Commission based 

on violation of or enforcement of this Order; 

C. Admits to all of the findings made in this Order; 

D. Waives: 

1. The filing and service of a complaint and notice of hearing; 

2. A hearing; 

3. All post-hearing procedures; 

4. Judicial review by any court; 

5. Any defense based on the statute of limitations applicable to any charges brought 

in connection with this Order; 

6. Any and all objections to the participation by any member of the Commission’s 

staff in the Commission’s consideration of the Offer; 

 

4

 Because certain swaps in connection with the fraud perpetrated by Becker are based on a broad-based securities 

index, this matter falls within the Commission’s jurisdiction. See Section 1a(47)(A) and (B) of the Act, 7 U.S.C. 

§ 1a(47)(A), (B); see also Further Definition of “Swap,” “Security-Based Swap,” and “Security-Based Swap 

Agreement”; Mixed Swaps; Security-Based Swap Agreement Recordkeeping, 77 Fed. Reg. 48,208, 48,271 (Aug. 

13, 2012) (“[A] Title VII instrument in which the underlying reference of the instrument is a security index that is 

not a narrow-based security index (i.e., the index is broad-based) is a swap subject to regulation by the CFTC”). 
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7. Any and all claims that he may possess under the Equal Access to Justice Act, 

5 U.S.C. § 504, and 28 U.S.C. § 2412, and/or the rules promulgated by the 

Commission in conformity therewith, Part 148 of the Regulations, 17 C.F.R. 

pt. 148 (2021), relating to, or arising from, this proceeding; 

8. Any and all claims that he may possess under the Small Business Regulatory 

Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, §§ 201–253, 

110 Stat. 847, 857–74 (codified as amended at 28 U.S.C. § 2412 and in scattered 

sections of 5 U.S.C. and 15 U.S.C.), relating to, or arising from, this proceeding; 

and 

9. Any claims of Double Jeopardy based on the institution of this proceeding or the 

entry in this proceeding of any order imposing a civil monetary penalty or any 

other relief, including this Order; 

E. Stipulates that the record basis on which this Order is entered shall consist solely of the 

findings contained in this Order to which Becker has consented in the Offer; and 

F. Consents to additional proceedings to determine what, if any, other sanctions may be 

assessed against him. In connection with such additional proceedings, he further 

consents that: (a) the findings of fact in Section II of this Order shall be accepted as and 

deemed true by the Commission or Presiding Officer; (b) Becker will be precluded from 

arguing that he did not violate the federal laws as described in Sections III and IV of this 

Order; and (c) he may not challenge the validity of his consents and agreements in the 

Offer or this Order; and 

G. Consents, solely on the basis of the Offer, to the Commission’s entry of this Order that: 

1. Makes findings by the Commission that Becker violated Section 6(c)(1) of the Act, 

7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. §180.1(a)(1)–(3) 

(2021); 

2. Orders Becker to cease and desist from violating Section 6(c)(1) of the Act and 

Regulation 180.1(a)(1)–(3); and 

3. Orders Becker to comply with the conditions and undertakings consented to in the 

Offer and as set forth in Part VI of this Order. 

Upon consideration, the Commission has determined to accept the Offer. 

VI. ORDER 

Accordingly, IT IS HEREBY ORDERED THAT: 

A. Becker shall cease and desist from violating Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), 

and Regulation 180.1(a)(1)–(3), 17 C.F.R. §180.1(a)(1)–(3) (2021). 
9 

B. The Commission reserves its determination as to other sanctions against Becker at this 

time based upon his cooperation in a Commission investigation and related proceedings, 

pursuant to the terms of the Cooperation Agreement, and his undertaking to continue to 

cooperate, as set forth in this Order in Section VI.C.2 below. The determination of what, 

if any, other sanctions may be assessed against him will be made at a public hearing for 

the purpose of taking evidence and hearing arguments on the issue in accordance with the 

Commission’s Rules of Practice, 17 C.F.R. pt. 10 (2021), at a time and place to be fixed 

as provided in Regulation 10.61, 17 C.F.R. § 10.61 (2021), except that in the additional 

proceedings: (a) the findings of fact in Section II of this Order shall be accepted as and 

deemed true by the Presiding Officer; (b) Becker will be precluded from arguing that he 

did not violate the federal laws as described in Sections III and IV of this Order; and (c) 

Becker may not challenge the validity of his consents and agreements in the Offer or this 

Order. All post-hearing procedures shall be conducted pursuant to Regulations 10.81-

10.107, 17 C.F.R. §§ 10.81-10.107 (2021). 

C. Becker shall comply with the following conditions and undertakings set forth in the 

Offer: 

1. Public Statements: Becker agrees that neither he nor any agents or employees 

under his authority or control shall take any action or make any public statement 

denying, directly or indirectly, any findings or conclusions in this Order or 

creating, or tending to create, the impression that this Order is without a factual 

basis; provided, however, that nothing in this provision shall affect Becker’s: (i) 

testimonial obligations; or (ii) right to take legal positions in other proceedings to 

which the Commission is not a party. Becker shall comply with this agreement, 

and shall undertake all steps necessary to ensure that all of his agents and/or 

employees under his authority or control understand and comply with this 

agreement. 

2. Cooperation with the Commission: Becker shall cooperate fully and truthfully 

with the Commission, including the Division, in any Proceedings. As part of such 

cooperation, Becker agrees to: 

a. preserve and produce to the Commission in a responsive and prompt 

manner, as requested by Division staff, all relevant non-privileged 

documents, information, and other materials wherever located, in the 

appropriate possession, custody, or control of Becker; 

b. utilize his knowledge and skill to explain transactions, interpret 

information and terminology, or identify new and productive lines of 

inquiry; 

c. prepare and appear for interviews and testimony at such times and places 

as requested by Division staff; 

d. respond completely and truthfully to all inquiries and interviews, when 

requested to do so by Division staff; 
e. identify and authenticate relevant documents and other evidentiary 

materials, execute affidavits and/or declarations, and testify completely 

and truthfully at depositions, trial, and other judicial proceedings, when 

requested to do so by Division staff; 

f. enter into tolling agreements, when requested to do so by Division staff, 

during the period of cooperation; 

g. waive any defense based on the statute of limitations applicable to any 

charges brought in connection with any Proceedings; 

h. consent to procedural matters, when requested to do so by Division staff, 

in connection with the Proceedings; 

1. accept service by mail, electronic mail, or facsimile transmission of 

notices or subpoenas for documents and/or testimony; 

J. appoint his attorney as agent to receive service of such notices and 

subpoenas; 

k. waive the territorial limits on service contained in Rule 45 of the Federal 

Rules of Civil Procedure and any applicable local rules in connection with 

requests or subpoenas of Division staff; and 

1. serve by hand delivery or by next-day mail all written notices and 

correspondence required by or related to the Cooperation Agreement to 

the Director of the Division of Enforcement, Commodity Futures Trading 

Commission, 1155 21st Street, NW, Three Lafayette Centre, Washington, 

DC 20581, unless otherwise directed in writing by Division staff. 

3. Change of Address/Phone: Until such time as Becker satisfies in full his 

obligations as set forth in the Cooperation Agreement and this Order, Becker shall 

provide written notice to the Commission by certified mail of any change to his 

telephone number and mailing address within ten calendar days of the change. 

The provisions of this Order shall be effective as of this date. 

By the Commission. 

Christopher J. Kirkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: April 27, 2022 

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