UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of: 

Cody Ryan Porter and KatchPips FX, 

LLC 

Respondents.

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CFTC Docket No. 21-18

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 between October 2019 and May 2021 (“Relevant Period”), Cody Ryan Porter (“Porter”) and 

KatchPips FX, LLC (“KatchPips”) ( collectively the “Respondents”) violated Sections 

4b(a)(2)(A)-(C) and 4o(1)(A) and (B) of the Commodity Exchange Act (“Act”), 7 U.S.C. 

§§ 6b(a)(2)(A)-(C) 6o(1)(A), (B) (2018), and Commission Regulations 4.41(a) and 5.2(b), 17

C.F.R. §§ 4.41(a), 5.2(b) (2020). Additionally, KatchPips violated Sections 2(c)(2)(C)(iii)(I)(cc)

and 4m(1) of the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6m(1) (2018), and Regulation

5.3(a)(2)(i), 17 C.F.R. § 5.3(a)(2)(i) (2020) and Porter violated 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of

the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6k(2) (2018), and Regulation 5.3(a)(2)(ii), 17 C.F.R. §

5.3(a)(2)(ii) (2020). Therefore, the Commission deems it appropriate and in the public interest

that public administrative proceedings be, and hereby are, instituted to determine whether

Respondents 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, Respondents have 

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

Without admitting or denying any of the findings or conclusions herein, Respondents consent 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 acknowledge 

service of this Order.1

1

 Respondents consent to the use of the findings of fact and conclusions of law in this Order in this proceeding and 

in any other proceeding brought by the Commission or to which the Commission is a party or claimant, and agree 

that they shall be taken as true and correct and be given preclusive effect therein, without further proof. 

Respondents do not consent, however, to the use of this Order, or the findings or conclusions herein, as the sole 
2 

II. FINDINGS 

The Commission finds the following: 

A. SUMMARY 

From approximately October 2019 through May 2021 (“Relevant Period”), Respondents, 

who were not registered in any capacity, operated a forex scheme and misappropriated 

approximately $200,000 from eighteen retail customers who falsely believed they were 

customers of a forex commodity pool. 

B. RESPONDENTS 

Cody Ryan Porter is a resident of Las Vegas, Nevada and is the managing member and 

founder of KatchPips FX, LLC. Porter has never been registered with the Commission in any 

capacity. 

KatchPips FX, LLC is a Nevada corporation formed on February 14, 2020 by Porter 

and located in Las Vegas, Nevada. KatchPips has never been registered with the Commission in 

any capacity. 

C. FACTS 

 During the Relevant Period, Respondents, who were not registered in any capacity, 

operated a fraudulent forex commodity pool and misappropriated approximately $200,000 from 

eighteen retail customers. 

Starting in 2018, Porter began posting videos online about the forex market. By 2019, 

Porter was trading a personal account at an offshore proprietary forex trading firm. Around 

October 2019, Porter began soliciting customers to trade in a forex commodity pool, KatchPips 

FX, LLC2

. In his solicitations of prospective pool participants, KatchPips, by and through 

Porter, stated that pool participants in the forex commodity pool would earn 3%-10% each 

month and that the pool would be traded through a registered retail foreign exchange dealer. 

Instead of placing his pool participants’ funds into a forex commodity pool, KatchPips, by and 

through Porter, misappropriated the vast majority of his pool participants’ money for personal 

expenses such as food, rent, and vacations. To conceal the fraudulent scheme, Porter made 

Ponzi-style payments to some of the pool participants, meaning he paid some pool participants 

using the funds of other participants. KatchPips, by and through Porter, sent at least one 

customer a spreadsheet showing fictional profits from the pool’s forex trading. Neither Porter 

 

basis for any other proceeding brought by the Commission or to which the Commission is a party or claimant, other 

than: a proceeding in bankruptcy or receivership; or a proceeding to enforce the terms of this Order. Respondents 

do not consent to the use of the Offer or this Order, or the findings or conclusions in this Order, by any other party in 

any other proceeding. 

2

 Although not legally formed as an LLC until 2020, Porter began in October 2019, soliciting individuals to 

participate in KatchPips FX LLC as the pool vehicle. Porter had used this entity as the name for various business 

ventures over the years. 
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nor KatchPips ever told the pool participants that Porter was not trading any customer funds in a 

forex commodity pool at a registered retail foreign exchange dealer or anywhere; that KatchPips 

and Porter were not registered, and that KatchPips and Porter were misappropriating their 

money. 

III. LEGAL DISCUSSION 

A. KatchPips was a CPO 

Section 1a(11) of the Act, 7 U.S.C. § 1a(11) (2018), defines a CPO as, among other 

things, any person engaged in a business that is of the nature of a commodity pool and who 

solicits, accepts, or receives from others, funds, securities, or property for the purpose of trading 

commodity interests. For forex, a CPO is defined in Regulation 5.1(d)(1), 17 C.F.R. § 5.1(d)(1) 

(2019), as “any person who operates or solicits funds, securities, or property for a pooled 

investment vehicle that is not an ECP [eligible contract participant] as defined in [7 U.S.C. § 

1a(18)(A)(xi) (2018)], and that engages in retail forex transactions.”3

 

B. Respondents Committed Fraud 

Section 4b(a)(2)(A)-(C) of the Act, 7 U.S.C. § 6b(a)(2)(A)-(C) (2018), make it unlawful 

for any person to (A) cheat or defraud or attempt to cheat or defraud another person, (B) willfully 

to make a false report or statement to another person, or (C) willfully to deceive or attempt to 

deceive another person by any means whatsoever in connection with any futures or retail forex 

transaction. Pursuant to Section 2(c)(2)(C)(iv) of the Act, Section 4b of the Act applies to offexchange leveraged or margined forex transactions that are entered into with non-eligible 

contract participants and do not result in actual delivery within two days, as if they were futures 

contracts. 7 U.S.C. § 2(c)(2)(C)(iv) (2018). Regulation 5.2(b), 17 C.F.R. § 5.2(b) (2018), also 

makes it unlawful, in connection with an off-exchange retail forex transaction, to use the mails or 

any means or instrumentality of interstate commerce (1) to cheat or defraud or attempt to cheat 

or defraud any person; (2) to willfully make a false report or statement; or (3) to willfully 

deceive any person by any means. 

Respondents violated Section 4b(a)(2)(A)-(C) of the Act and Regulation 5.2(b) by 

knowingly making material misrepresentations and omissions to pool participants, by 

misappropriating pool participant funds, and by providing false statements to pool participants. 

 Section 4o(1) of the Act, 7 U.S.C. § 6o(1) (2012), makes it unlawful for a CPO to use 

any means or instrumentality of interstate commerce to (A) employ any device, scheme, or 

artifice to defraud a pool participant or prospective pool participant; or (B) engage in a 

transaction, practice, or course of business that operates as a fraud or deceit upon a pool 

 

3

 7 U.S.C. § 1a(18)(A)(xi) (2018), in relevant part, defines an ECP to mean an individual “acting for its own account 

—who has amounts invested on a discretionary basis, the aggregate of which is in excess of—(I) $10,000,000; or 

(II) $5,000,000 and who enters into the agreement, contract, or transaction in order to manage the risk associated 

with an asset owned or liability incurred, or reasonably likely to be owned or incurred, by the individual.” Most, if 

not all, of the pool participants were not ECPs. 
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participant or prospective pool participant. Violations of Section 4b(a)(2)(A)-(C) of the Act also 

establish liability for CPO fraud under Section 4o(1)(A) of the Act. See CFTC v. Aurifex 

Commodities Research Co., No. 1:06–CV–166, 2008 WL 299002, at *5-6 (W.D. Mich. Feb. 1, 

2008). Regulation 4.41(a), 17 C.F.R. § 4.41(a) (2018), makes it unlawful for any CPO to 

publish or distribute materials that (1) employ any device, scheme or artifice to defraud a pool 

participant or prospective pool participant; or (2) involve any transaction, practice, or course of 

business which operates as a fraud or deceit upon any pool participant or prospective pool 

participant. 

Respondents’ material misrepresentations, material omissions, misappropriation, and 

creation of false statements in violation of Section 4b(a)(2)(A)-(C) of the Act also establish 

liability for CPO fraud under Section 4o(1)(A) of the Act. See CFTC v. Aurifex Commodities 

Research Co., No. 1:06–CV–166, 2008 WL 299002, at *5-6 (W.D. Mich. Feb. 1, 2008). 

C. Respondents Failed to Register 

Section 2(c)(2)(C)(iii)(I)(cc) of the Act makes it unlawful for any person, unless 

registered with the Commission, to operate or solicit funds, securities, or property for any pooled 

investment vehicle that is not an ECP in connection with leveraged or margined forex 

transactions entered into with a person who is not described in item (aa), (bb), (ee), or (ff) of 

Section 2(c)(2)(B)(i)(II) of the Act (describing counterparties such as such as registered futures 

commission merchants). Section 4m(1) of the Act, 7 U.S.C. § 6m(1) (2018), requires anyone 

who is acting as a CPO and makes use of the mails or any means or instrumentality of interstate 

commerce in connection with the person’s business as a CPO to register with the Commission 

unless an exemption from registration applies. KatchPips was not exempt from registration as a 

CPO under any provision of the Act or Commission Regulations. Regulation 5.3(a)(2)(i), 17 

C.F.R. § 5.3(a)(2)(i) (2018), requires any CPO engaged in off-exchange retail forex transactions 

to register with the Commission. Section 4k(2) of the Act, 7 U.S.C. § 6k(2) (2012), and 

Regulation 5.3(a)(2)(ii) require any person associated with a CPO as a partner, officer, 

employee, consultant, or agent, in any capacity involving the solicitation of funds, securities, or 

property for participation in a commodity pool, to register with the Commission. 

During the Relevant Period, KatchPips, through Porter, acted as a CPO because it 

solicited funds for a pooled vehicle that purported to transact in leveraged or margined and offexchange retail forex transactions. This conduct violated Sections 2(c)(2)(C)(iii)(I)(cc) and 

4m(1) of the Act and Regulation 5.3(a)(2)(i) because KatchPips failed to register with the 

Commission as a CPO. 

During the Relevant Period, Porter violated Sections 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of 

the Act and Regulation 5.3(a)(2)(ii) by soliciting funds for CPO KatchPips without being 

registered with the Commission as an AP of KatchPips. 
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IV. FINDINGS OF VIOLATIONS 

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

Respondents violated Sections 4b(a)(2)(A)-(C) and 4o(1) of the Act, 7 U.S.C. §§ 6b(a)(2)(A)-

(C), 6o(1) (2018) and Regulations 4.41(a) and 5.2(b), 17 C.F.R. §§ 4.41(a), 5.2(b) (2020). 

KatchPips violated Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) of the Act, 7 U.S.C. 

§§ 2(c)(2)(C)(iii)(I)(cc), 6m(1) (2018), and Regulation 5.3(a)(2)(i), 17 C.F.R. § 5.3(a)(2)(i) 

(2020), and Porter violated 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of the Act, 7 U.S.C. §§ 

2(c)(2)(C)(iii)(I)(cc), 6k(2) (2018), and Regulation 5.3(a)(2)(ii), 17 C.F.R. § 5.3(a)(2)(ii) (2020). 

V. OFFER OF SETTLEMENT 

Respondents have submitted the Offer in which they, without admitting or denying the 

findings and conclusions herein: 

A. Acknowledge service of this Order; 

B. Admit 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. Waive: 

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

staff in the Commission’s consideration of the Offer; 

6. Any and all claims that he may possess under the Equal Access to Justice Act, 5 

U.S.C. § 504 (2018), and 28 U.S.C. § 2412 (2018), and/or the rules promulgated 

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

pt. 148 (2020), relating to, or arising from, this proceeding; 

7. 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 

8. 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. 
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D. Stipulate that the record basis on which this Order is entered shall consist solely of the 

findings contained in this Order to which Respondents have consented in the Offer; and 

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

1. Makes findings by the Commission that Respondents violated Sections 

4b(a)(2)(A)-(C) and 4o(1) of the Act, 7 U.S.C. §§ 6b(a)(2)(A)-(C) and 6o(1) 

(2018) and Regulations 4.41(a) and 5.2(b), 17 C.F.R. §§ 4.41(a) and 5.2(b) (2020). 

KatchPips violated Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) of the Act, 7 U.S.C. 

§§ 2(c)(2)(C)(iii)(I)(cc), 6m(1) (2018), and Regulation 5.3(a)(2)(i), 17 C.F.R. 

§ 5.3(a)(2)(i) (2020), and Porter violated 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of the Act, 

7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6k(2) (2018), and Regulation 5.3(a)(2)(ii), 17 

C.F.R. § 5.3(a)(2)(ii) (2020); 

2. Orders Respondents to cease and desist from violating Sections 4b(a)(2)(A)-(C) 

and 4o(1) of the Act and Regulations 4.41(a) and 5.2(b); orders KatchPips to cease 

and desist from violating Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) of the Act; and 

Regulation 5.3(a)(2)(i); and orders Porter to cease and desist from violating 

2(c)(2)(C)(iii)(I)(cc) and 4k(2) of the Act, and Regulation 5.3(a)(2)(ii); 

3. Orders Respondents to pay, jointly and severally, restitution in the amount one 

hundred and eighty-seven thousand two hundred and forty dollars ($187,240), plus 

any post-judgment interest within thirty days of the date of the entry of this Order; 

4. Orders Respondents to pay, jointly and severally, a civil monetary penalty in the 

amount of one hundred and eighty-seven thousand two hundred and forty dollars 

($187,240), plus any post-judgment interest within thirty days of the date of the 

entry of this Order; 

5. Appoints the National Futures Association (“NFA”) as Monitor in this matter; 

6. Orders that Respondents are permanently prohibited from, directly or indirectly, 

engaging in trading on or subject to the rules of any registered entity (as that term 

is defined in Section 1a(40) of the Act, 7 U.S.C. § 1a(40) (2018) after the date of 

entry of this Order, and all registered entities shall refuse them trading privileges; 

7. Orders Respondents and their successors and assigns 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. Respondents shall cease and desist from violating Sections 4b(a)(2)(A)-(C) and 4o(1) of 

the Act, 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6o(1) (2018) and Regulations 4.41(a) and 5.2(b), 17 

C.F.R. §§ 4.41(a), 5.2(b) (2020). 
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B. KatchPips shall cease and desist from violating Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) 

of the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6m(1) (2018), and Regulation 5.3(a)(2)(i), 

17 C.F.R. § 5.3(a)(2)(i) (2020). 

C. Porter shall cease and desist from violating Sections 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of the 

Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6k(2) (2018), and Regulation 5.3(a)(2)(ii), 17 

C.F.R. § 5.3(a)(2)(ii) (2020). 

D. Respondents shall pay, jointly and severally restitution in the amount of one hundred and 

eighty-seven thousand two hundred and forty dollars ($187,240) (“Restitution 

Obligation”). If the Restitution Obligation is not paid in full within thirty days of the date 

of the entry of this Order, then post-judgment interest shall accrue on the Restitution 

Obligation beginning on the date of entry of this Order and shall be determined by using 

the Treasury Bill rate prevailing on the date of entry of this Order pursuant to 28 U.S.C. § 

1961 (2018). 

To effect payment by Respondents and the distribution of restitution to Respondents’ 

customers, the Commission appoints NFA as “Monitor.” The Monitor shall receive 

payments of the Restitution Obligation and any post-judgment interest from 

Respondents and make distributions as set forth below. Because the Monitor is not being 

specially compensated for these services, and these services are outside the normal duties 

of the Monitor, it shall not be liable for any action or inaction arising from its 

appointment as Monitor other than actions involving fraud. 

Respondents shall make their respective payments of the Restitution Obligation and any 

post-judgment interest under this Order in the name of the “Cody Ryan Porter/KatchPips 

Settlement Fund” and shall send such payments by electronic funds transfer, or U.S. 

postal money order, certified check, bank cashier’s check, or bank money order to the 

Office of Administration, National Futures Association, 300 South Riverside Plaza, Suite 

1800, Chicago, Illinois 60606, under a cover letter that identifies the paying Respondent 

and the name and docket number of this proceeding. The paying Respondent shall 

simultaneously transmit copies of the cover letter and the form of payment to the Chief 

Financial Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 

1155 21st Street, NW, Washington, D.C. 20581. 

The Monitor shall oversee Respondents’ Restitution Obligation and shall have the 

discretion to determine the manner of distribution of funds in an equitable fashion to the 

Respondents’ customers or may defer distribution until such time as the Monitor may 

deem appropriate. In the event that the amount of payments of the Restitution Obligation 

to the Monitor are of a de minimis nature such that the Monitor determines that the 

administrative cost of making a restitution distribution is impractical, the Monitor may, in 

its discretion, treat such restitution payments as civil monetary penalty payments, which 

the Monitor shall forward to the Commission, as discussed below. To the extent any 

funds accrue to the U.S. Treasury for satisfaction of Respondents’ Restitution 

Obligation, such funds shall be transferred to the Monitor for disbursement in 

accordance with the procedures set forth in this Order. 
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E. Respondents shall pay, jointly and severally, a civil monetary penalty in the amount of 

one hundred and eighty-seven thousand two hundred and forty dollars ($187,240) (“CMP 

Obligation”) within thirty days of the date of the entry of this Order. If the CMP 

Obligation is not paid in full within thirty days of the date of entry of this Order, then 

post-judgment interest shall accrue on the unpaid portion of the CMP Obligation 

beginning on the date of entry of this Order and shall be determined by using the 

Treasury Bill rate prevailing on the date of entry of this Order pursuant to 28 U.S.C. 

§ 1961 (2018). 

Respondents shall pay the CMP Obligation and any post-judgment interest by electronic 

funds transfer, U.S. postal money order, certified check, bank cashier’s check, or bank 

money order. If payment is to be made other than by electronic funds transfer, then the 

payment shall be made payable to the Commodity Futures Trading Commission and sent 

to the address below: 

Commodity Futures Trading Commission 

Division of Enforcement 

C/O ESC/AMK-326; HQ RM 265 

6500 S. MacArthur Blvd. 

Oklahoma City, OK 73169 

(405) 954-6569 office 

(405) 954-1620 fax 

9-AMC-AR-CFTC@faa.gov 

 If payment is to be made by electronic funds transfer, Respondents shall contact Marie 

Thorne or her successor at the above address to receive payment instructions and shall 

fully comply with those instructions. Respondents shall accompany payment of the CMP 

Obligation with a cover letter that identifies the paying Respondent and the name and 

docket number of this proceeding. The paying Respondent shall simultaneously transmit 

copies of the cover letter and the form of payment to the Chief Financial Officer, 

Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, 

Washington, D.C. 20581. 

F. Respondents are permanently prohibited from, directly or indirectly, engaging in trading 

on or subject to the rules of any registered entity (as that term is defined in Section 1a(40) 

of the Act, 7 U.S.C. § 1a(40) (2018), after the date of entry of this Order, and all 

registered entities shall refuse them trading privileges; 

G. Respondents and their successors and assigns shall comply with the following conditions 

and undertakings set forth in the Offer: 

1. Public Statements: Respondents agree that neither they nor any of their 

successors and assigns, agents or employees under their 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 Respondents’: (i) testimonial obligations; or 
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(ii) right to take legal positions in other proceedings to which the Commission is 

not a party. Respondents and their successors and assigns shall comply with this 

agreement, and shall undertake all steps necessary to ensure that all of their agents 

and/or employees under their authority or control understand and comply with 

this agreement. 

2. Partial Satisfaction: Respondents understand and agrees that any acceptance by 

the Commission of any partial payment of Respondents’ restitution payment or 

CMP Obligation shall not be deemed a waiver of their obligation to make further 

payments pursuant to this Order, or a waiver of the Commission’s right to seek to 

compel payment of any remaining balance. 

3. Respondents agree that they shall never, directly or indirectly: 

a. enter into any transactions involving “commodity interests” (as 

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

their own personal account or for any account in which they have a 

direct or indirect interest; 

b. have any commodity interests traded on their behalf; 

c. control or direct 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; 

d. solicit, receive or accept any funds from any person for the purpose 

of purchasing or selling any commodity interests; 

e. apply for registration or claim exemption from registration with the 

Commission in any capacity, and engage in any activity requiring 

such registration or exemption from registration with the 

Commission, except as provided for in Regulation 4.14(a)(9), 17 

C.F.R. § 4.14(a)(9) (2020); and 

f. act 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 (as that term is defined in 7 U.S.C. § 1a(38) (2018)), 

registered, exempted from registration or required to be registered 

with the Commission except as provided for in 17 C.F.R. § 

4.14(a)(9) (2020). 

4. Cooperation with the Monitor: Respondents shall cooperate with the Monitor as 

appropriate to provide such information as the Monitor deems necessary and 

appropriate to identify Respondents’ customers, whom the Monitor, in its sole 

discretion, may determine to include in any plan for distribution of any restitution 

payments. Respondents shall execute any documents necessary to release funds 
that they have in any repository, bank, investment or other financial institution, 

wherever located, in order to make partial or total payment toward the Restitution 

Obligation. 

5. Partial Satisfaction: Respondents understand and agree that any acceptance by 

the Commission or the Monitor of any partial payment of Respondents' 

Restitution Obligation or CMP Obligation shall not be deemed a waiver of their 

obligation to make further payments pursuant to this Order, or a waiver of the 

Commission's right to seek to compel payment of any remaining balance. 

6. Change of Address/Phone: Until such time as Respondents satisfy in full their 

Restitution Obligation and CMP Obligation as set forth in this Order, 

Respondents shall provide written notice to the Commission by certified mail of 

any change to their telephone number and mailing address within ten calendar 

days of the change. 

7. Until such time as Respondents satisfies in full their Restitution Obligation, and 

CMP Obligation, upon the commencement by or against Respondents of 

insolvency, receivership or bankruptcy proceedings or any other proceedings for 

the settlement of Respondents' debts, all notices to creditors required to be 

furnished to the Commission under Title 11 of the United States Code or other 

applicable law with respect to such insolvency, receivership bankruptcy or other 

proceedings, shall be sent to the address below: 

Secretary of the Commission 

Legal Division 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street N.W. 

Washington, DC 20581 

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

By the Commission. 

C12¥-l-,%tMChristopher J. K1rkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: September 28, 2021 

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