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COMPLAINT

Thomas L. Simek (DC Bar #57268)

Anthony C. Biagioli (MO Bar # 72434)

Attorneys for Plaintiff 

COMMODITY FUTURES TRADING COMMISSION 

2600 Grand Boulevard, Suite 210 

Kansas City, MO 64108 

Telephone: (816) 960-7700 

tsimek@cftc.gov 

abiagioli@cftc.gov 

UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

 PHOENIX DIVISION

Commodity Futures Trading 

Commission, 

Plaintiff, 

v. 

Purvesh Mankad; CTAX Partners, LLC; 

and CTAX Series, LLC, 

Defendants. 

Civil Action No. 

COMPLAINT FOR INJUNCTIVE RELIEF 

CIVIL MONETARY PENALTIES, 

RESTITUTION, DISGORGEMENT, 

AND OTHER EQUITABLE RELIEF 

 Plaintiff Commodity Futures Trading Commission (“CFTC” or “Commission”), 

by and through its attorneys, alleges as follows: 

I. SUMMARY 

1. From at least July 25, 2014 through at least March 22, 2019 (“Relevant 

Period”), Purvesh Mankad (“Mankad”) and two entities Mankad controlled—CTAX 

Partners, LLC (“CTAX Partners”) and CTAX Series, LLC (“CTAX Series,” and together 

with CTAX Partners, “CTAX,” and together with CTAX Partners and Mankad, 

“Defendants”)—directly and/or through others, fraudulently solicited funds for, 

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COMPLAINT

misappropriated money from, and/or concealed near-total trading losses in the affiliated, 

Mankad-controlled CTAX Series 1, LLC commodity pool (“CTAX Pool”). 

2. Defendants, directly and/or through officers, agents, or employees, solicited 

members of the public (“pool participants”) to contribute funds to the CTAX Pool. 

Ultimately, 16 of the CTAX Pool’s 17 pool participants were investment advisory clients 

of Paul Ohanian (“Ohanian”), an SEC-registered investment advisor and a CFTCregistered associated person of CTAX Partners, and Ohanian’s investment advisory firm 

Scottsdale Wealth Planning, Inc. (“Scottsdale Wealth”).

1

 Defendants drafted and 

provided to prospective pool participants a detailed Private Placement Memorandum (the 

“CTAX Memorandum”) which made extensive, detailed representations regarding who 

would trade pool funds, Mankad’s fiduciary responsibilities, how fees would be 

calculated and paid, and the frequency of account statements, among other things. 

3. In the CTAX Memorandum, Mankad and CTAX Series fraudulently stated 

that only commodity trading advisors (“CTAs”) would trade funds in the CTAX Pool, 

creating the impression that pool participants would be entrusting their funds to 

experienced, successful traders. This was false. In fact, Mankad—who was not a CTA 

and admitted to the CFTC’s Division of Enforcement (“Division”) in sworn investigative 

testimony to having limited and unsuccessful prior experience trading the specific kinds 

of commodity futures and options traded in the CTAX Pool—began trading in CTAX 

 1 On October 8, 2021, the CFTC issued a settlement order making findings of fact 

and violations of law concerning Ohanian’s and Scottsdale Wealth’s role in the events 

described in this Complaint. In re Paul C. Ohanian and Scottsdale Wealth Planning, 

Inc., CFTC No. 22-02 (Oct. 8, 2021).

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COMPLAINT

Pool accounts in 2015, engaged in approximately 23% of the trading in the CTAX Pool 

in 2016, 46% in 2017, 65% by June 2018, and 100% of the trading in the CTAX Pool by 

August 2018. Mankad traded recklessly—a fact about which Ohanian repeatedly 

complained. From July through December 2018, due to Mankad’s unauthorized reckless 

trading, the CTAX Pool lost approximately 89% of its value. During that period, to

conceal those losses, Mankad and CTAX Series delayed and then simply stopped sending 

monthly account statements (which the CTAX Memorandum had falsely stated would be 

sent monthly), while a panicked Mankad scrambled, unsuccessfully, to recoup his losses

through continued trading. Mankad admitted to the Division in sworn investigative 

testimony that he delayed sending account statements in part due to embarrassment at the 

losses he caused and to hide the losses from pool participants while he tried to earn the 

money back. As a result of this conduct, the majority of pool participants submitted 

requests to redeem their interests in the CTAX Pool in late December 2018, but by that 

time, their contributions had evaporated to pennies on the dollar. 

4. In addition, despite explicitly stating in the CTAX Memorandum that 

Mankad and CTAX Series had a fiduciary duty to manage the CTAX Pool with good 

faith and integrity, CTAX Partners, at Mankad’s direction, misappropriated pool funds by 

secretly extracting unauthorized, excessively disproportionate brokerage commissions 

from at least one CTAX Pool sub-account that Mankad traded as compared to subaccounts traded by CTAs. The variance was so excessive that CTAX’s third-party 

compliance advisor (“Advisor 1”) warned Mankad that the commission structure was 

highly problematic and that, if the National Futures Association (“NFA”) discovered it, 

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COMPLAINT

the NFA may allege rules violations. Mankad ignored the advice and continued 

extracting the excessive commissions.

5. In 2019, the NFA conducted an audit of CTAX. In connection with that 

audit, Mankad and CTAX Series (through Mankad) falsified and submitted to the NFA 

several emails to make it appear that a pool participant received account statements 

earlier than he did and that another received account statements at all. In his sworn 

testimony to the Division, Mankad admitted he did so to mislead the NFA into believing 

pool participants timely received account statements.

6. As a result of Defendants’ unlawful conduct, at least 14 of the original 17 

pool participants lost at least approximately $1,969,072.29—over 93% of their 

contributions.2

7. By virtue of this conduct and the conduct further described herein, 

Defendants—either directly, as controlling persons, or as principals liable for their 

agents’ misconduct—have engaged, are engaging, or are about to engage in acts and 

practices in violation of Sections 4b(a)(1)(A) and (C), 4o(1)(A)-(B), and/or 9(a)(4) of the 

Commodity Exchange Act (the “Act”), 7 U.S.C. §§ 6b(a)(1)(A), (C), 6o(1)(A)-(B), 

13(a)(4) (2018).

8. Unless restrained and enjoined by this Court, Defendants will likely 

continue to engage in acts and practices alleged in this Complaint and similar acts and 

practices, as described below.

 2 The remaining three pool participants had earlier redeemed their interests. 

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COMPLAINT

9. Accordingly, the Commission brings this action pursuant to Section 6c of 

the Act, 7 U.S.C. § 13a-1 (2018), to enjoin Defendants’ unlawful acts and practices, to 

compel their compliance with the Act and the Regulations promulgated thereunder, and 

to enjoin them from engaging in any commodity-related activity. In addition, the 

Commission seeks civil monetary penalties and remedial ancillary relief, including, but 

not limited to, trading and registration bans, restitution, disgorgement from Defendants, 

rescission, pre- and post-judgment interest, and such other and further relief as the Court 

may deem necessary and appropriate.

II. JURISDICTION AND VENUE

10. The Court has jurisdiction of this action pursuant to 28 U.S.C. § 1331 

(2018) (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (2018) (providing 

that district courts have original jurisdiction over civil actions commenced by the United 

States or by any agency expressly authorized to sue by Act of Congress). In addition, 

Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a) (2018), authorizes the Commission to seek 

injunctive and other relief against any person whenever it shall appear to the Commission 

that such person has engaged, is engaging, or is about to engage in any act or practice 

constituting a violation of any provision of the Act, or any rule, regulation, or order 

thereunder. 

11. Venue lies properly in this Court pursuant to 7 U.S.C. § 13a-1(e) because 

Defendants transacted business in this District and certain transactions, acts, practices, 

and courses of business in violation of the Act occurred, are occurring, or are about to 

occur in this District, among other places. 

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COMPLAINT

III. THE PARTIES 

A. Plaintiff 

12. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency charged by Congress with the administration and enforcement 

of the Act and the Regulations promulgated thereunder. The CFTC maintains its 

principal office at Three Lafayette Centre, 1155 21st Street NW, Washington, D.C. 

20581.

B. Defendants

13. Defendant Purvesh Mankad, a California resident, was the principal, 

control person, and CFTC-registered associated person (“AP”) of CTAX Partners and 

CTAX Series.

14. Defendant CTAX Series, LLC is a Delaware limited liability company 

(“LLC”) based in California and a CFTC-registered commodity pool operator (“CPO”). 

CTAX Series operated the CTAX Pool and claimed to be exempt from certain regulatory 

obligations pursuant to Regulation 4.7, 17 C.F.R. § 4.7 (2020).

15. Defendant CTAX Partners, LLC is a Delaware LLC based in California 

and a CFTC-registered introducing broker (“IB”). Mankad formed CTAX Partners to, 

among other things, introduce prospective pool participants to CTAX Series and the 

CTAX Pool. 

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COMPLAINT

C. Related Individual and Entity

16. Paul Ohanian, an Arizona resident, owns and controls Scottsdale Wealth. 

Ohanian is an SEC-registered investment advisor. Ohanian was also a CFTC-registered 

AP of CTAX Partners from May 23, 2014 through July 3, 2019.

17. Scottsdale Wealth Planning, Inc. is an Arizona corporation located in 

Scottsdale, Arizona. It has never been registered with the Commission in any capacity.

IV. FACTS

A. Mankad Established CTAX and Partnered with Ohanian To Solicit Pool 

Participants for the CTAX Pool.

18. From approximately 2012 through 2014, Mankad established CTAX Series 

with the intent of operating multiple commodity pools and CTAX Partners to introduce 

customers to those pools.

19. During this period, Mankad marketed the CTAX Pool as an opportunity for 

pool participants to access the trading strategies of registered CTAs with a proven track 

record of performance.

20. Separately during this period, Mankad established Investor Services 

Exchange LLC (“Investor Services”) with the goal of assisting investment advisors in 

opening their own advisory firms.

21. In 2014, through Investor Services and CTAX, Mankad entered into two 

business ventures with Ohanian, an SEC-registered investment advisor with an 

established client base, and Ohanian’s advisory firm Scottsdale Wealth. First, Investor 

Services agreed to provide Scottsdale Wealth $30,000 in start-up capital and 

administrative services in exchange for 30% of Scottsdale Wealth’s management fees.

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COMPLAINT

22. Second, Ohanian agreed to register as an AP of CTAX Partners, the IB; to 

assist Mankad in selecting CTAs for the CTAX Pool; and to solicit the initial $2 million 

investment in the CTAX Pool from his clients. In exchange, CTAX would pay Ohanian

2 percent of the value of Ohanian clients’ holdings in the CTAX Pool, as well as 0.5

percent of CTAX Pool assets between $10 million and $50 million.

23. On approximately July 11, 2014, CTAX Series, by and through Mankad, 

finalized the CTAX Memorandum. Shortly thereafter, Defendants provided the CTAX 

Memorandum to prospective pool participants, both directly and through Ohanian. 

24. Between approximately July through October 2014, 17 pool participants 

signed the CTAX Memorandum and contributed funds to the CTAX Pool. Sixteen (16)

clients (at least 12 of whom reside in Arizona) of Ohanian and Scottsdale Wealth

contributed a total of approximately $2.15 million.3

 One other pool participant—a 

personal friend of Mankad’s—contributed $250,000. 

B. Mankad’s Unauthorized Trading and Concealment of Steep Trading Losses 

Eviscerated Pool Participants’ Contributions.

1. Mankad and CTAX Series Fraudulently Represented That Only CTAs 

Would Trade CTAX Pool Funds and Failed To Disclose Mankad’s 

Unauthorized Trading. 

25. “Commodity trading advisor” is defined in the Act as an individual or 

organization that, for compensation or profit, advises others, directly or indirectly, as to 

the value of or the advisability of trading futures contracts, options on futures, and certain 

other transactions. Such individuals or organizations must register with the Commission 

 3 Three of those pool participants (who contributed a total of $300,000) redeemed 

their contributions in 2015 and 2016.

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COMPLAINT

as CTAs or qualify for a registration exemption. Commission Regulations impose 

extensive requirements on certain CTAs designed to protect CTA customers, including 

detailed disclosure requirements. 

26. Mankad was not a CTA. In addition, Mankad had little experience trading 

futures and options relevant to the CTAX Pool. What little futures trading Mankad had 

done previously had been limited in scope and volume, was conducted for his personal 

accounts, and was unsuccessful. 

27. Mankad’s purported objective in soliciting prospective pool participants 

was to connect investment advisors and their clients who typically did not trade futures 

with CTAs who had significant experience and a track record of success. 

28. Consistent with this purported objective, the overall message the CTAX 

Memorandum communicated to pool participants was that CTAX Series, through 

Mankad, would select a talented, experienced team of CTAs to trade CTAX Pool funds to 

“achieve significant absolute investment returns over the short and long-term” by trading 

futures. 

29. Specifically, the CTAX Memorandum represented that only CTAs would 

trade CTAX Pool funds. For example, the CTAX Memorandum stated that the CTAX 

Pool was “a fund of commodity trading advisors (‘CTAs’) and, as such, will engage in a 

diversified investment strategy by investing in various managed accounts . . . guided by 

such CTAs.” Elsewhere, the CTAX Memorandum told pool participants that Mankad 

would “employ[] macro discretionary based allocations to CTAs” and that Mankad 

would employ complex strategies to enable “the dynamic allocation of capital to CTAs.” 

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COMPLAINT

The CTAX Memorandum made repeated references throughout that CTAX Pool funds 

would be traded by professionals who were experienced, sophisticated, and talented 

enough to achieve the significant returns referenced in the CTAX Memorandum. For 

example, the CTAX Memorandum represented that only a “select group of investment 

managers” would engage in such trading. Nowhere did the CTAX Memorandum state 

that any non-CTA—much less Mankad himself, who was an inexperienced and 

unsuccessful futures trader—would trade pool funds. The CTAX Memorandum also 

stated that Mankad was accountable to pool participants as a “fiduciary” and was 

required to exercise “the utmost good faith” in all activities relating to the CTAX Pool. 

Taken together, based on these representations, no reasonable pool participant would 

have expected Mankad himself to trade any—much less all—CTAX Pool funds.

30. Despite these representations, beginning in 2015, Mankad began trading a 

portion of CTAX Pool funds, and thereafter extensively—and eventually exclusively—

traded CTAX Pool funds. For example, Mankad traded funds totaling approximately 

23% of the entire CTAX Pool in 2016, 46% in 2017, 65% by June 2018, and 100% of the 

CTAX Pool by August 2018. In connection with this unauthorized trading, Mankad 

traded futures in 10-year Treasury notes, silver, and mini silver, among other contracts.

31. Mankad and CTAX Series did not amend the CTAX Memorandum to 

authorize and disclose Mankad’s trading.

2. Mankad’s Unauthorized and Reckless Trading Eviscerated Pool 

Participants’ Contributions.

32. Ohanian repeatedly communicated to Mankad that Mankad was trading 

recklessly, had not sufficiently hedged his positions in the CTAX Pool, and was thus 

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COMPLAINT

needlessly exposing the CTAX Pool to a significant risk of loss. For example, on 

approximately August 11, 2015, Ohanian wrote an email to Mankad suggesting that 

Mankad consider selling out of certain positions, noting “Pigs get fat Hogs get 

slaughtered. My concern is always that we have too many positions for the size of the 

account.” 

33. On multiple occasions, Mankad ignored Ohanian’s advice and continued 

his previous trading strategy.

34. From July through December 2018, due to Mankad’s unauthorized and 

reckless trading, the CTAX Pool lost approximately 89% of its value. Approximately all 

such losses occurred in accounts traded by Mankad, who was the only person trading in

the CTAX Pool by August 2018.

3. Mankad and CTAX Series Concealed Mankad’s Steep Trading Losses 

from Pool Participants, Compounding and Cementing Those Losses.

35. The CTAX Memorandum represented that each pool participant would 

“receive[] a monthly . . . account statement” from Advisor 1.

36. Prior to July 2018, to comply with this requirement, Mankad provided 

relevant account information to Advisor 1 each month, who prepared account statements 

and sent them to pool participants—each time within approximately one month of the 

conclusion of the month the account statements summarized. For example, March 2018 

CTAX Pool account statements were provided to pool participants on May 1, 2018; and 

April 2018 account statements were provided on May 29, 2018.

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COMPLAINT

37. However, from July through December 2018—a period when Mankad’s 

trading was causing significant losses—Mankad intentionally withheld information that 

Advisor 1 needed to prepare and send pool participants monthly account statements.

38. In sworn investigative testimony before the Division, Mankad admitted that 

he withheld this information with the goal of delaying the provision of account 

statements to pool participants. Mankad admitted he did this to conceal losses from pool 

participants due to his embarrassment at the losses and desire to give himself time to 

make the money back.

39. Because Mankad intentionally withheld this information, pool participants 

did not receive July 2018 account statements until approximately September 28, 2018;

and did not receive August-December 2018 account statements until approximately 

February 25, 2019. These delays violated Defendants’ representation in the CTAX 

Memorandum that they would provide accurate monthly account statements.

40. As a result of these delays, pool participants were prevented from learning 

of the losses Mankad was causing, timely redeeming their interests in the CTAX Pool,

and avoiding further losses as the CTAX Pool’s value collapsed.

41. Ohanian learned the approximate extent of the CTAX Pool’s losses, at the 

latest, when delayed account statements were circulated to pool participants. By 

approximately December 31, 2018, 13 of the 14 pool participants (Ohanian’s clients) who 

had not earlier redeemed their interests in the CTAX Pool submitted requests to redeem 

their interests. The fourteenth (Mankad’s personal friend) did not redeem his interest and 

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COMPLAINT

lost his entire investment. In total, these pool participants lost at least approximately 

$1,969,072.29—over 93% of their contributions.

42. In contributing funds and maintaining those contributions, pool participants 

reasonably and actually relied on the misrepresentations and material omissions described 

herein. 

C. Mankad and CTAX Partners Misappropriated CTAX Pool Funds Through 

Extraction of Excessive Commissions, and Mankad and CTAX Series 

Misrepresented That Mankad Would Exercise Good Faith with Respect to the 

CTAX Pool and Failed to Disclose the Misappropriation.

43. The CTAX Memorandum expressly noted Mankad’s fiduciary duties 

toward the CTAX Pool, noting Mankad was “accountable to [pool participants] . . . as a 

fiduciary and consequently must exercise the utmost good faith and integrity in handling 

the [CTAX Pool’s] . . . affairs . . . .” These provisions were terms of the CTAX 

Memorandum agreed to by pool participants. 

44. Despite these duties, Mankad and CTAX Partners (through Mankad) 

extracted excessive, unjustified, and unlawful commissions from pool participants for 

trades that Mankad executed on behalf of the pool. Specifically, Mankad caused CTAX 

Series to pay CTAX Partners much higher commissions (for example, $50 round turn) for 

trades executed for the CTAX Pool in at least one account traded by Mankad, but much 

lower commissions (for example, $20 round turn) for trades by third-party CTAs. 

Although the CTAX Memorandum disclosed that pool participants would ultimately pay 

for brokerage commissions and other trading costs, it did not disclose either (1) that 

CTAX Partners would charge disproportionately higher commissions on the trades 

executed by Mankad or (2) that Mankad had the unilateral discretion to increase the 

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COMPLAINT

trading costs borne by pool participants by allocating more of the pool’s assets to the 

account he traded. By doing so, Mankad misled pool participants as to the true cost of 

their investment in the CTAX Pool. 

45. In addition, these commissions constituted misappropriation of CTAX Pool 

funds. The commissions CTAX Partners charged for at least one account traded by 

Mankad were inconsistent with the express representation in the CTAX Memorandum 

that Mankad was acting as a fiduciary and obligated to “exercise the utmost good faith 

and integrity in handling [the CTAX Pool’s] affairs.” There was no justification for the 

higher commission rate CTAX Partners charged pool participants for trades in the 

account traded by Mankad compared to those traded by third-party CTAs beyond 

Mankad’s desire to enrich himself at the expense of pool participants. These 

commissions were therefore not charged in good faith, let alone “the utmost good faith,” 

and were inconsistent with Mankad’s obligation to act as a fiduciary for pool participants. 

The commissions were thus inconsistent with the representations, and violated the terms 

agreed to by pool participants, in the CTAX Memorandum.

46. Advisor 1 recognized these issues and communicated them to Mankad, but 

Mankad ignored him. On approximately July 9, 2016, Advisor 1 discovered the disparity 

and asked Mankad, “why as the fiduciary to the pool is this account charged above 

industry normal commission rates? I don’t see this in the retail sector anymore and 

neither does NFA.” Advisor 1 communicated to Mankad that the NFA might discover 

the significant difference and might allege rules violations. 

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COMPLAINT

47. Mankad had no answer. In response to this email, Mankad did not adjust 

his commission structure; did not amend the CTAX Memorandum to caveat his fiduciary 

responsibilities or explicitly disclose the disparity; did not otherwise communicate to 

pool participants the disparity; and continued using CTAX Partners to misappropriate 

pool funds through extraction of excessive and unauthorized commissions.

48. Mankad and CTAX Partners charged the unlawful commissions described 

above within a business structure Mankad created to maximize the extraction of fees and 

commissions, and ultimately his personal profits, from pool participants. The following 

describes that business structure. That Mankad charged the above unlawful commissions 

within the below business structure further illustrates that Mankad did not act in good 

faith when charging the above unlawful commissions. Specifically, Mankad did not need 

to involve CTAX Partners at all in the CTAX Pool’s operations. Mankad created CTAX 

Partners as an introducing broker purportedly, in part, to facilitate the placement of orders 

and execution of trades by Mankad and the CTAs that traded pool funds with the futures 

commission merchants (“FCMs”) that held the CTAX Pool’s trading accounts. However, 

CTAX Partners was unnecessary in this respect. The “brokerage services” it claimed to 

provide were illusory because Mankad and the CTAs that traded pool funds had access to 

and traded their FCM accounts directly through electronic trading platforms provided

either by the FCM or third-party providers. Nor did CTAX Partners provide any 

necessary services in connection with soliciting participants for the CTAX Pool. Because 

Mankad controlled CTAX Series (the CPO), there was no need to insert the Mankadcontrolled CTAX Partners into the process of soliciting funds for the CTAX Pool. The

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commissions Mankad charged through CTAX Partners were in addition to the 

commissions that the CTAX Pool (and thus pool participants) were already paying to the 

FCM holding the CTAX Pool’s accounts as well as the management fees Mankad was 

already charging pool participants as the “Managing Member” of CTAX Series and the 

management fees charged by the various CTAs trading the CTAX Pool’s funds. The one 

thing CTAX Partners did enable Mankad to accomplish was to interpose an additional 

entity to charge pool participants commissions—which CTAX Partners (through

Mankad) did charge, in part in the form of the unlawful, excessive commissions in 

connection with at least one sub-account Mankad traded, as described above.

D. Mankad and CTAX Series Falsified Documents To Conceal Their Misconduct 

from the NFA.

49. In early 2019, the NFA audited CTAX Partners and CTAX Series. In 

connection with those audits, the NFA requested, and Defendants provided, various 

documents and information.

50. Specifically, on March 12, 2019, Mankad, acting on behalf of CTAX 

Series, provided the NFA with an email purportedly dated February 25, 2019 from 

Advisor 1 to a pool participant attaching a January 1, 2019 account statement. In fact, 

that email had been sent on March 12, 2019. Before providing the email to the NFA, 

Mankad changed the date from March 12, 2019, to February 25, 2019. Mankad and 

CTAX Series did so to mislead the NFA regarding the date the email was sent—

specifically, to make it appear that the pool participant received the account statement 

sooner than he did.

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51. On March 14, 2019, Mankad, on behalf of CTAX Series, forwarded to the 

NFA emails purporting to reflect the provision to a different pool participant—Mankad’s 

personal friend—the April 2018 CTAX account statement (purported email dated May 

29, 2018); the May 2018 CTAX account statement (purported email dated June 29, 

2018); the June 2018 CTAX account statement (purported email dated August 16, 2018); 

the July 2018 CTAX account statement (purported email dated September 28, 2018); and 

the August-December 2018 CTAX account statements (purported email dated February 

25, 2019). Mankad fabricated these emails. No such emails were ever sent. Mankad 

submitted these fabricated emails to the NFA to mislead the NFA into believing that the 

account statements had been provided to this pool participant.

52. In testimony before the Division, Mankad admitted to intentionally 

falsifying the emails described above to make it appear that a pool participant received 

account statements earlier than he did and that another pool participant received any 

account statements at all.

E. The NFA Found That Mankad and CTAX Series Violated NFA Rules in 

Connection with the Conduct Charged Herein.

53. On January 21, 2020, the NFA issued Decisions finding that Mankad and 

CTAX Series violated NFA Compliance Rules 2-2(f), 2-4, and, in the case of CTAX 

Series, 2-13 relating to their concealment of the CTAX Pool’s performance by delaying 

delivery of account statements to pool participants, as well as their false statements to the 

NFA.

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F. The CFTC Entered an Order Making Findings and Imposing Remedial 

Sanctions Against Ohanian and Scottsdale Wealth.

54. On October 8, 2021, the CFTC entered an Order Instituting Proceedings 

Pursuant to Section 6(c) and (d) of the Commodity Exchange Act, Making Findings, and 

Imposing Remedial Sanctions (“Ohanian Order”) against Ohanian and Scottsdale Wealth, 

who consented to the entry of the Ohanian Order. In re Paul C. Ohanian and Scottsdale 

Wealth Planning, Inc., CFTC No. 22-02 (Oct. 8, 2021). The Ohanian Order found that 

Ohanian and Scottsdale Wealth violated antifraud provisions of the Act by failing to 

disclose certain material facts, including (1) Ohanian’s relationship with and 

compensation from Mankad and certain entities Mankad owned; (2) Ohanian’s concerns 

regarding the fees associated with the CTAX Pool; (3) Ohanian’s concerns regarding 

Mankad’s change in trading strategy; and (4) details relating to the CTAX Pool’s neartotal loss in value beginning in July 2018. In addition, Ohanian and Scottsdale Wealth 

failed to register with the Commission as CTAs. The Ohanian Order requires Ohanian 

and Scottsdale Wealth to pay, jointly and severally, $338,000 in restitution to defrauded 

pool participants and a $169,000 civil monetary penalty, in addition to four-year 

registration and trading bans, among other relief. 

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT

COUNT ONE

Violations of Section 4b(a)(1)(A) and (C) of the Act, 7 U.S.C. § 6b(a)(1)(A), (C) 

(2018) 

(Fraud by Misrepresentations, Omissions, and Misappropriation)

(All Defendants)

55. Paragraphs 1 through 54 are re-alleged and incorporated herein by 

reference.

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56. 7 U.S.C. § 6b(a)(1)(A) and (C) makes it unlawful:

(1) for any person, in or in connection with any order to make, 

or the making of, any contract of sale of any commodity in 

interstate commerce or for future delivery that is made, or to be 

made, on or subject to the rules of a designated contract market, 

for or on behalf of any other person . . .

(A) to cheat or defraud or attempt to cheat or defraud the 

other person . . . [or]

(C) willfully to deceive or attempt to deceive the other 

person by any means whatsoever in regard to any order or 

contract or the disposition or execution of any order or 

contract, or in regard to any act of agency performed, with 

respect to any order or contract for . . . the other person . . . 

.

57. By reason of the conduct described above, Defendants CTAX Partners and 

CTAX Series, by and through their officers, employees and agents, and Defendant 

Mankad, in or in connection with any order to make, or the making of, any contract of 

sale of any commodity in interstate commerce or for future delivery that is made, or to be 

made, on or subject to the rules of a designated contract market, for or on behalf of any 

other person, knowingly or recklessly: (1) cheated or defrauded or attempted to cheat or 

defraud pool participants; and (2) deceived or attempted to deceive pool participants by 

any means. Defendants Mankad and CTAX Series did so by, for example, (1) making 

the material misrepresentation that only CTAs who were experienced, successful traders 

would trade CTAX Pool funds and omitting Mankad’s unauthorized trading; (2) 

concealing trading losses by intentionally delaying account statements; (3) 

misrepresenting that Mankad would act as a fiduciary when Mankad in fact authorized 

and personally benefited from excessive and unauthorized commissions to CTAX 

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Partners, which Mankad controlled, and omitting that CTAX Partners (through Mankad) 

was extracting unauthorized commissions. Defendants Mankad and CTAX Partners (by 

and through Mankad) did so by, for example, misappropriating CTAX Pool funds by 

extracting commissions that were, without justification, disproportionately higher for at 

least one sub-account Mankad traded than for sub-accounts traded by CTAs.

58. By reason of the foregoing, Defendants CTAX Partners and CTAX Series, 

by and through their officers, employees and agents, and Defendant Mankad violated 7 

U.S.C. § 6b(a)(1)(A) and (C). 

59. The foregoing acts, misrepresentations, omissions, and failures occurred 

within the scope of Defendant Mankad’s employment or office with CTAX Partners and 

CTAX Series. Therefore, CTAX Partners and CTAX Series are liable for Mankad’s acts, 

misrepresentations, omissions, and failures in violation of 7 U.S.C. § 6b(a)(1)(A) and (C), 

pursuant to 7 U.S.C. § 2(a)(1)(B) (2018) and 17 C.F.R. § 1.2 (2020).

60. Defendant Mankad controls CTAX Partners and CTAX Series, directly or 

indirectly, and did not act in good faith or knowingly induced, directly or indirectly, 

CTAX Partners’ and CTAX Series’ conduct alleged in this Count. Therefore, under 7 

U.S.C. § 13c(b) (2018), Mankad is liable for CTAX Partners’ and CTAX Series’

violations of 7 U.S.C. § 6b(a)(1)(A) and (C).

61. Each misrepresentation, omission of material fact, and misappropriation, 

including but not limited to those specifically alleged herein, is alleged as a separate and 

distinct violation of 7 U.S.C. § 6b(a)(1)(A) and (C).

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COUNT TWO

Violation of Section 4o(1)(A)-(B) of the Act, 7 U.S.C. § 6o(1)(A)-(B) (2018)

(Fraud and Deceit by CPOs and APs of CPOs)

(Defendants CTAX Series and Mankad)

62. Paragraphs 1 through 54 are re-alleged and incorporated herein by 

reference.

63. Section 1a(11)(A)(ii) of the Act, 7 U.S.C. § 1a(11)(A)(ii) (2018), defines a 

CPO, in relevant part, as “any person . . . who is registered with the Commission as a 

[CPO].”

64. During the Relevant Period, Defendant CTAX Series was registered with 

the Commission as a CPO and was thus a CPO as defined by 7 U.S.C. § 1a(11)(A)(ii). 

65. Regulation 1.3, 17 C.F.R. § 1.3 (2020), defines an AP of a CPO as any 

natural person associated with:

(3) A [CPO] as a partner, officer, employee, consultant, or agent 

(or any natural person occupying a similar status or performing 

similar functions), in any capacity which involves (i) the 

solicitation of funds, securities, or property for a participation in 

a commodity pool or (ii) the supervision of any person or persons 

so engaged[.]

66. During the Relevant Period, Defendant Mankad was associated with CTAX 

Series, a CPO, as a partner, officer, employee, consultant, or agent in a capacity that 

involved the solicitation of funds, securities, or property for participation in a commodity 

pool, or the supervision of any person or persons so engaged. In addition, during the 

Relevant Period, Mankad was registered with the Commission as an AP of CTAX Series, 

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a CPO. Therefore, Defendant Mankad was an AP of a CPO as defined by 17 C.F.R. 

§ 1.3. 

67. 7 U.S.C. § 6o(1)(A)-(B) prohibits CPOs and APs of CPOs, by use of the 

mails or any means or instrumentality of interstate commerce, directly or indirectly, from 

employing devices, schemes or artifices to defraud any client or participant or 

prospective client or participant, or engaging in transactions, practices, or courses of 

business which operate as a fraud or deceit upon any client or participant or prospective 

client or participant.

68. By reason of the conduct described above, Defendant CTAX Series, by and 

through its officers, employees and agents, and Defendant Mankad, through use of the 

mails or any means or instrumentality of interstate commerce: (1) knowingly or 

recklessly employed devices, schemes or artifices to defraud pool participants and 

prospective pool participants, or (2) engaged in transactions, practices, or courses of 

business which operated as a fraud or deceit upon pool participants or prospective pool 

participants. Defendants Mankad and CTAX Series did so by, for example, (1) making 

the material misrepresentation that only CTAs who were experienced, successful traders 

would trade CTAX Pool funds and omitting Mankad’s unauthorized trading; (2) 

concealing trading losses by intentionally delaying account statements; (3) 

misrepresenting that Mankad would act as a fiduciary when Mankad in fact authorized 

and personally benefited from excessive and unauthorized commissions to CTAX 

Partners, which Mankad controlled, and omitting that CTAX Partners (through Mankad) 

was extracting unauthorized commissions. Defendant Mankad did so by, for example, 

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misappropriating CTAX Pool funds by extracting commissions that were, without 

justification, disproportionately higher for at least one sub-account Mankad traded than 

for sub-accounts traded by CTAs.

69. By reason of the foregoing, Defendant CTAX Series, by and through its 

officers, employees and agents, and Defendant Mankad violated 7 U.S.C. § 6o(1)(A)-(B). 

70. The foregoing acts, misrepresentations, omissions, and failures occurred 

within the scope of Defendant Mankad’s employment or office with CTAX Series. 

Therefore, Defendant CTAX Series is liable for Mankad’s acts, misrepresentations, 

omissions, and failures in violation of 7 U.S.C. § 6o(1)(A)-(B), pursuant to 7 U.S.C. § 

2(a)(1)(B) and 17 C.F.R. § 1.2.

71. Defendant Mankad controls CTAX Series, directly or indirectly, and did 

not act in good faith or knowingly induced, directly or indirectly, CTAX Series’ conduct 

alleged in this Count. Therefore, under 7 U.S.C. § 13c(b), Mankad is liable for CTAX 

Series’ violations of 7 U.S.C. § 6o(1)(A)-(B).

72. Each misrepresentation, omission of material fact, and misappropriation, 

including but not limited to those specifically alleged herein, is alleged as a separate and 

distinct violation of 7 U.S.C. § 6o(1)(A)-(B).

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COUNT THREE

Violation of Section 9(a)(4) of the Act, 7 U.S.C. § 13(a)(4) (2018)

(False Statements to the NFA)

(Defendants CTAX Series and Mankad)

73. Paragraphs 1 through 54 are re-alleged and incorporated herein by 

reference.

74. 7 U.S.C. § 13(a)(4) makes it unlawful for 

“[a]ny person willfully to falsify, conceal, or cover up by any 

trick, scheme, or artifice a material fact, make any false, 

fictitious, or fraudulent statements or representations, or 

make or use any false writing or document knowing the same 

to contain any false, fictitious, or fraudulent statement or 

entry to a . . . futures association designated or registered 

under this chapter acting in furtherance of its official duties 

under this chapter.”

75. By reason of the conduct described above, Defendant CTAX Series, by and 

through its officers, employees and agents, and Defendant Mankad willfully falsified, 

concealed, or covered up by any trick, scheme, or artifice a material fact, made false, 

fictitious, or fraudulent statements or representations, or made or used any false writings 

or documents knowing the same to contain any false, fictitious, or fraudulent statements 

or entries to the NFA, a registered futures association, acting in furtherance of its official 

duties in connection with an audit of CTAX Series.

76. By reason of the foregoing, Defendant CTAX Series, by and through its 

officers, employees and agents, and Defendant Mankad violated 7 U.S.C. § 13(a)(4).

77. The foregoing acts, misrepresentations, omissions, failures, and fraudulent 

document submissions occurred within the scope of Defendant Mankad’s employment or 

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office with CTAX Series. Therefore, CTAX Series is liable for Mankad’s conduct in 

violation of 7 U.S.C. § 13(a)(4), pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2.

78. Defendant Mankad controls CTAX Series, directly or indirectly, and did 

not act in good faith or knowingly induced, directly or indirectly, CTAX Series’ conduct 

alleged in this Count. Therefore, under 7 U.S.C. § 13c(b), Mankad is liable for CTAX 

Series’ violations of 7 U.S.C. § 13(a)(4).

79. Each false, fictitious, or fraudulent statement, representation, omission, or 

document submission, and each act of concealment, including but not limited to those 

specifically alleged herein, is alleged as a separate and distinct violation of 7 U.S.C. § 

13(a)(4).

VI. RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that this Court, as 

authorized by Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), and pursuant to its own 

equitable powers:

A. Find that Defendants CTAX Series and Mankad violated Sections 

4b(a)(1)(A) and (C), 4o(1)(A)-(B), and 9(a)(4) of the Act, 7 U.S.C. §§ 6b(a)(1)(A), (C), 

6o(1)(A)-(B), 13(a)(4) (2018), and that Defendant CTAX Partners violated 7 U.S.C. § 

6b(a)(1)(A), (C); 

B. Enter an order of permanent injunction enjoining Defendants CTAX 

Partners, CTAX Series, and Mankad, and their affiliates, agents, servants, employees, 

successors, assigns, attorneys, and all persons in active concert with them, who receive 

actual notice of such order by personal service or otherwise, from engaging in the 

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conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A), (C), 6o(1)(A)-(B), and 

13(a)(4), in the case of CTAX Series and Mankad, and 7 U.S.C. § 6b(a)(1)(A), (C), in the 

case of CTAX Partners;

C. Enter an order of permanent injunction restraining and enjoining 

Defendants CTAX Partners, CTAX Series, and Mankad, and their affiliates, agents, 

servants, employees, successors, assigns, attorneys, and all persons in active concert with

them, from directly or indirectly:

1) Trading on or subject to the rules of any registered entity (as that term is 

defined by Section 1a(40) of the Act, 7 U.S.C. § 1a(40) (2018));

2) Entering into any transactions involving “commodity interests” (as that 

term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2020)), for accounts 

held in the name of any Defendant or for accounts in which any 

Defendant has a direct or indirect interest; 

3) Having any commodity interests traded on any Defendants’ behalf;

4) Controlling or directing the trading for or on behalf of any other person 

or entity, whether by power of attorney or otherwise, in any account 

involving commodity interests;

5) Soliciting, receiving, or accepting any funds from any person for the 

purpose of purchasing or selling of any commodity interests;

6) Applying for registration or claiming exemption from registration with 

the CFTC in any capacity, and engaging in any activity requiring such 

registration or exemption from registration with the CFTC except as 

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provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2020); 

and

7) Acting as a principal (as that term is defined in Regulation 3.1(a), 

17 C.F.R. § 3.1(a) (2020)), agent, or any other officer or employee of 

any person registered, exempted from registration, or required to be 

registered with the CFTC except as provided for in 

17 C.F.R. § 4.14(a)(9).

D. Enter an order directing Defendants CTAX Partners, CTAX Series, and 

Mankad, as well as any third-party transferee and/or successors thereof, to disgorge, 

pursuant to such procedure as the Court may order, all benefits received including, but 

not limited to, salaries, commissions, loans, fees, revenues, and trading profits derived, 

directly or indirectly, from acts or practices which constitute violations of the Act and

Regulations as described herein, including pre-judgment and post-judgment interest; 

E. Enter an order requiring Defendants CTAX Partners, CTAX Series, and 

Mankad, as well as any successors thereof, to make full restitution to every person who 

has sustained losses proximately caused by the violations described herein, including prejudgment and post-judgment interest; 

F. Enter an order directing Defendants CTAX Partners, CTAX Series, and 

Mankad, as well as any successors thereof, to rescind, pursuant to such procedures as the 

Court may order, all contracts and agreements, whether implied or express, entered into 

between, with or among Defendants CTAX Partners, CTAX Series, and/or Mankad and 

any of the pool participants whose funds were received by Defendants CTAX Partners, 

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CTAX Series, and/or Mankad as a result of the acts and practices that constituted 

violations of the Act and Regulations as described herein; 

G. Enter an order directing Defendants CTAX Partners, CTAX Series, and 

Mankad to pay a civil monetary penalty assessed by the Court, in an amount not to 

exceed the penalty prescribed by 7 U.S.C. § 13a-1(d)(1), as adjusted for inflation 

pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 

2015, Pub. L. 114-74, tit. VII, § 701, 129 Stat. 584, 599-600, see Regulation 143.8, 

17 C.F.R. § 143.8 (2020), for each violation of the Act and Regulations, as described 

herein; 

H. Enter an order requiring Defendants CTAX Partners, CTAX Series, and 

Mankad to pay costs and fees as permitted by 28 U.S.C. §§ 1920, 2413(a)(2) (2018); and

I. Enter an order providing such other and further relief as this Court may 

deem necessary and appropriate under the circumstances. 

Dated: October 8, 2021 Respectfully submitted,

COMMODITY FUTURES TRADING 

COMMISSION

By: /s/ Anthony C. Biagioli

Tom Simek (DC Bar #57268), tsimek@cftc.gov

TRIAL COUNSEL

Anthony C. Biagioli (MO Bar # 72434), 

abiagioli@cftc.gov

Attorneys for Plaintiff 

COMMODITY FUTURES TRADING 

COMMISSION

2600 Grand Boulevard, Suite 210

Kansas City, MO 64108

(816) 960-7700

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