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JONMARC BUFFA, CA Bar No. 217324

JEFF LE RICHE, pro hac vice pending

CLEMON D. ASHLEY, pro hac vice pending

Attorneys for Plaintiff

COMMODITY FUTURES

TRADING COMMISSION

2600 Grand Boulevard, Suite 210

Kansas City, MO 64108

Telephone: (816) 960-7700

Facsimile: (816) 960-7750

jbuffa@cftc.gov

jleriche@cftc.gov

cashley@cftc.gov 

THE UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

COMMODITY FUTURES

TRADING COMMISSION, and

ALABAMA SECURITIES 

COMMISSION, ARIZONA 

CORPORATION COMMISSION, 

ARKANSAS SECURITIES 

DEPARTMENT, CALIFORNIA 

DEPARTMENT OF FINANCIAL 

PROTECTION & INNOVATION,

STATE OF CONNECTICUT

DEPARTMENT OF BANKING,

STATE OF FLORIDA, OFFICE 

OF FINANCIAL REGULATION, 

STATE OF HAWAII, 

DEPARTMENT OF COMMERCE 

AND CONSUMER AFFAIRS, 

STATE OF IDAHO, 

DEPARTMENT OF FINANCE, 

OFFICE OF SECRETARY OF 

STATE, ILLINOIS SECURITIES 

DEPARTMENT, INDIANA 

Civil Action No.

COMPLAINT FOR INJUNCTIVE 

RELIEF, CIVIL MONETARY

PENALTIES, AND OTHER 

EQUITABLE RELIEF 

DEMAND FOR JURY TRIAL

2:22-cv-00691

Case 2:22-cv-00691 Document 1 Filed 02/01/22 Page 1 of 38 Page ID #:1
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SECURITIES DIVISION, 

KENTUCKY DEPARTMENT OF 

FINANCIAL INSTITUTIONS, 

STATE OF MARYLAND EX REL 

MARYLAND SECURITIES 

COMMISSIONER, ATTORNEY 

GENERAL DANA NESSEL ON 

BEHALF OF THE PEOPLE OF 

THE STATE OF MICHIGAN, 

MISSISSIPPI SECRETARY OF 

STATE, MISSOURI 

COMMISSIONER OF 

SECURITIES, NEBRASKA 

DEPARTMENT OF BANKING & 

FINANCE, NEW MEXICO 

SECURITIES DIVISION, THE 

PEOPLE OF THE STATE OF 

NEW YORK BY LETITIA 

JAMES, ATTORNEY GENERAL

OF THE STATE OF NEW YORK, 

NORTH CAROLINA 

DEPARTMENT OF THE 

SECRETARY OF STATE, 

OKLAHOMA DEPARTMENT OF 

SECURITIES, OREGON 

DEPARTMENT OF CONSUMER 

AND BUSINESS SERVICES, 

SOUTH CAROLINA ATTORNEY 

GENERAL, SOUTH DAKOTA 

DEPARTMENT OF LABOR AND 

REGULATION, COMMISSIONER 

OF THE TENNESSEE 

DEPARTMENT OF COMMERCE 

& INSURANCE, VERMONT 

DEPARTMENT OF FINANCIAL 

REGULATION, WASHINGTON 

STATE DEPARTMENT OF 

FINANCIAL INSTITUTIONS, and 

THE STATE OF WISCONSIN,

Plaintiffs,

Case 2:22-cv-00691 Document 1 Filed 02/01/22 Page 2 of 38 Page ID #:2
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v.

SAFEGUARD METALS LLC and 

JEFFREY SANTULAN a/k/a 

JEFFREY HILL, 

Defendants.

Plaintiffs Commodity Futures Trading Commission (“CFTC” or 

“Commission”), Alabama Securities Commission (“State of Alabama”), Arizona 

Corporation Commission (“State of Arizona”), Arkansas Securities Department 

(“State of Arkansas”), California Department of Financial Protection & Innovation 

(“State of California”), State of Connecticut Department of Banking (“State of 

Connecticut”), State of Florida, Office of Financial Regulation (“State of Florida”), 

State of Hawaii, Department of Commerce and Consumer Affairs (“State of 

Hawaii”), Idaho Department of Finance (“State of Idaho”), Office of the Secretary of 

State, Illinois Securities Department (“State of Illinois”), Indiana Securities Division

(“State of Indiana”), Kentucky Department of Financial Institutions 

(“Commonwealth of Kentucky”), State of Maryland Ex Rel the Maryland Securities 

Commissioner (“State of Maryland”), Attorney General Dana Nessel on Behalf of the 

People of the State of Michigan (“People of the State of Michigan”), Mississippi 

Secretary of State (“State of Mississippi”), Missouri Commissioner of Securities

(“State of Missouri”), Nebraska Department of Banking & Finance (“State of 

Nebraska”), New Mexico Securities Division (“State of New Mexico”), The People 

of the State of New York by Letitia James, Attorney General of the State of New 

York (“State of New York”), North Carolina Department of the Secretary of State 

(“State of North Carolina”), Oklahoma Department of Securities (“State of 

Oklahoma”), Oregon Department of Business and Consumer Services (“State of 

Oregon”), South Carolina Attorney General (“State of South Carolina”), South 

Dakota Department of Labor & Regulation (“State of South Dakota”), Commissioner 

Case 2:22-cv-00691 Document 1 Filed 02/01/22 Page 3 of 38 Page ID #:3
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of the Tennessee Department of Commerce and Insurance (“State of Tennessee”), 

Vermont Department of Financial Regulation (“State of Vermont”), Washington 

State Department of Financial Institutions (“State of Washington”), and the State of 

Wisconsin (“State of Wisconsin”) (collectively “the States”), by and through their 

undersigned attorneys, hereby allege as follows: 

I. SUMMARY

1. From at least October 2017 and continuing through at least July 2021

(“Relevant Period”), Safeguard Metals LLC (“Safeguard Metals”) and Jeffrey 

Santulan a/k/a Jeffrey Hill (“Santulan”) (collectively “Defendants”) have engaged 

and continue to engage in a scheme to defraud people throughout the United States, 

including in this District and in each of the States. 

2. Defendants fraudulently solicited customers to purchase precious metals, 

primarily consisting of gold and silver coins, that the company marketed and 

classified as either bullion, semi-numismatic, and numismatic precious metals 

(collectively “Precious Metals”). 

3. Defendants grossly misrepresented, among other things, the amount of 

markup the company would charge customers on silver coins that Safeguard Metals 

claimed possess semi-numismatic and numismatic value (“Silver Coins”). 

Specifically, from at least October 2017 to January 2021, Safeguard Metals charged 

customers a markup on Silver Coins that exceeded the maximum possible markup 

disclosed to customers by almost 50% on average. And from January 2021, after 

receiving notice of a law enforcement investigation into Safeguard Metals’ 

operations, and after Safeguard Metals modified its customer agreements to reflect 

that the maximum markup on Silver Coins could be 42% in certain circumstances; 

Safeguard Metals continued charging customers a markup on Silver Coins that still 

exceeded the maximum possible markup disclosed to customers by nearly 10% on 

average. 

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4. Safeguard Metals, by and through its sales representatives or other 

agents, made other material misrepresentations, half-truths, and omissions to 

convince customers to purchase Precious Metals. For example, Safeguard Metals

misrepresented the size, scale, experience, background and history of the firm, its 

agents, and representatives. Safeguard Metals also made materially false and 

misleading statements to customers about the risk and safety of their traditional 

retirement accounts in order to instill fear and convince customers to purchase 

Precious Metals. 

5. Central to its scheme to defraud, Safeguard Metals targeted and 

continues to target and prey on a vulnerable population of mostly elderly or 

retirement-aged persons with little experience investing in Precious Metals. 

Safeguard Metals defrauded customers into transferring proceeds from retirement 

accounts, often consisting of funds from liquidated securities, to self-directed 

individual retirement accounts (“SDIRAs”) for the purchase of Precious Metals. 

Safeguard Metals also fraudulently induced some customers to purchase Precious 

Metals through cash and credit sales (“Cash Accounts”).

6. Safeguard Metals’ customers, particularly customers who purchased 

Silver Coins, generally and almost immediately suffered substantial losses on their 

investments due to the fraudulently overpriced Silver Coins. In total, Defendants 

fraudulently solicited approximately $68 million from more than 450 members of the 

public to purchase Precious Metals. Of that $68 million, $66 million was derived 

from purchases of fraudulently priced Silver Coins. And Safeguard Metals charged 

its customers approximately $26 million dollars in markups on those purchases, as 

part of Defendants’ fraudulent scheme. 

7. To perpetuate the fraud and disguise the nearly immediate and 

substantial losses suffered by customers, Safeguard Metals also attempted to conceal 

its fraud and lull its customers by, among other things, making additional 

misrepresentations about the value of the customers’ Precious Metals accounts. 

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8. Defendants knowingly or recklessly misled customers into purchasing 

Precious Metals, knew or recklessly disregarded that most customers significantly 

overpaid for Silver Coins, and knew or recklessly disregarded that representations 

about customer account values were false. 

9. The acts, misrepresentations, omissions, and failures of Santulan and 

other officers, employees, and agents acting for Safeguard Metals occurred within the 

scope of their employment, agency, or office with Safeguard Metals. Safeguard 

Metals is therefore liable under Section 2(a)(1)(B) of the Commodity Exchange Act 

(“CEA”), 7 U.S.C. § 2(a)(1)(B), and CFTC Regulation 1.2, 17 C.F.R. § 1.2 (2021), as 

a principal for Santulan’s violations of the CEA and CFTC Regulations. 

10. By virtue of this conduct, and as more fully set forth below, Defendants 

have engaged, are engaging, and/or are about to engage in, either intentionally or 

recklessly, violations of the anti-fraud provisions of the CEA, Section 6(c)(1) of the 

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

§ 180.1(a)(1)-(3) (2021). 

11. Accordingly, pursuant to Sections 6c and 6d(1) of the CEA, 7 U.S.C. 

§§ 13a-1, 13a-2(1), the CFTC and States bring this action to enjoin Defendants’ 

unlawful acts and practices, to compel their compliance with the CEA and CFTC 

Regulations, and to enjoin them from engaging in any commodity-related activity, as 

set forth below. Plaintiffs also seek civil monetary penalties and remedial ancillary 

relief, including, but not limited to, restitution, disgorgement, rescission, pre- and 

post-judgment interest, and such other relief as the Court may deem necessary and

appropriate.

II. JURISDICTION AND VENUE

12. This Court has subject matter jurisdiction over this action under 28 

U.S.C. § 1331 (federal question jurisdiction) and 28 U.S.C. § 1345 (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). Section 6c(a) of the 

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CEA, 7 U.S.C. § 13a-1(a), authorizes the CFTC to seek injunctive and other relief 

against any person whenever it appears to the CFTC 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 CEA or any rule, regulation, or order thereunder.

13. Section 6d(1) of the CEA, 7 U.S.C. § 13a-2(1), authorizes the States to 

bring a suit in the district courts of the United States to seek injunctive and other 

relief against any person whenever it appears to the Attorney General and/or 

Securities Administrator of a State, or such other official that a State may designate, 

that the interests of the residents of the State have been, are being, or may be 

threatened or adversely affected because of violations of the CEA or CFTC 

Regulations. 

14. Venue lies properly in this District pursuant to Section 6c(e) of the CEA, 

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 CEA

and CFTC Regulations occurred, are occurring, or are about to occur within this 

District, among other places. 

III. THE PARTIES 

A. PLAINTIFFS 

15. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency charged by Congress with the administration and 

enforcement of the CEA and CFTC Regulations promulgated thereunder. The CFTC 

maintains its principal office at Three Lafayette Centre, 1155 21st Street NW, 

Washington, D.C. 20581.

16. Plaintiff State of Alabama, State of Arizona, State of Arkansas, State of 

California, State of Connecticut, State of Florida, State of Hawaii, State of Idaho, 

State of Illinois, State of Indiana, Commonwealth of Kentucky, State of Maryland, 

People of the State of Michigan, State of Mississippi, State of Missouri, State of 

Nebraska, State of New Mexico, State of New York, State of North Carolina, State of 

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Oklahoma, State of Oregon, State of South Carolina, State of South Dakota, State of 

Tennessee, State of Vermont, State of Washington, State of Wisconsin are authorized 

under Section 6d(1) of the CEA, 7 U.S.C. § 13a-2(1), and their respective State laws, 

to bring this action on behalf of their State and their citizens to enforce the CEA and 

CFTC Regulations.

B. DEFENDANTS

17. Defendant Safeguard Metals LLC initially registered as a Wyoming

limited liability company on October 13, 2017, with its principal office located at 30 

N Gould St., Suite R, Sheridan, Wyoming. Subsequently, on March 26, 2019, 

Safeguard Metals registered as a California limited liability company with its 

principal place of business located at 21550 Oxnard St., 3rd Floor, Woodland Hills,

California. Safeguard Metals has never been registered with the Commission in any 

capacity.

18. Defendant Jeffrey Santulan a/k/a Jeffrey Hill is the sole owner and

sole manager of Safeguard Metals LLC. Santulan is the only signatory on Safeguard 

Metals’ bank accounts. During the Relevant Period, Santulan owned and controlled 

Safeguard Metals, supervised (directly and indirectly) its employees and agents, and 

made hiring and firing decisions on behalf of the company. A resident of Tarzana, 

California, Santulan has never been registered with the Commission in any capacity.

IV. FACTS

A. Safeguard Metals’ Operations

19. Safeguard Metals is a company that marketed, promoted, and sold

Precious Metals, including, but not limited to, Silver Coins. The firm placed 

advertisements on financial media and websites, and promoted its products on social 

media platforms and websites linked to media personalities and financial gurus. 

Safeguard Metals also marketed and promoted Precious Metals through its company 

website, https://www.safeguardmetals.com/. 

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20. Safeguard Metals used the advertisements, social media platforms, and 

websites to generate leads, which resulted in solicitations by telephone to potential 

customers. 

21. Safeguard Metals operated a call center located in Woodland Hills, 

California, staffed by sales representatives known as “Openers” and “Closers.” 

Safeguard Metals distributed lists of potential customers to Openers and Closers 

which permitted the sales representatives to contact potential customers by telephone. 

Using the leads, Openers marketed and promoted Precious Metals to potential 

customers. Once an Opener confirmed a potential customer’s interest in purchasing 

Precious Metals, the potential customer was transferred over to the Closer, and the 

Closer executed the sale of Precious Metals with the customer. 

22. Safeguard Metals operated as an intermediary, essentially controlling all 

buy and sell aspects of customer transactions to maximize its profits. Safeguard 

Metals, by and through its sales representatives or other agents, recommended 

customers form SDIRA accounts and that customers hold Precious Metals at a 

depository instead of taking delivery of the metals themselves. Safeguard Metals told 

customers storing Precious Metals in a depository was the safest way to store the 

precious metals and economically better because the depository was purportedly 

federally insured. 

23. In reality, these representations served as a way for Safeguard Metals to 

control the transaction. Once a customer opened a SDIRA account, often through a 

custodian and depository recommended by Safeguard Metals, Safeguard Metals was

initially the only party authorized to buy or sell Precious Metals in customer SDIRAs. 

Unless a customer knew to remove Safeguard Metals as the designated representative 

on their SDIRA account, the customer could not liquidate their Precious Metals 

holdings without going through the very firm that defrauded them to unwind their 

investments.

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24. Safeguard Metals’ core strategy for profitability was to charge an 

exorbitant markup on sales of Precious Metals, and in particular, on Silver Coins to 

customers. Safeguard Metals purchased Precious Metals from a wholesale 

distributor, and generated nearly all of its profits through what it represented, though 

falsely, to customers as “operating margins”—the difference between Safeguard 

Metals’ cost of acquiring Precious Metals from a wholesale distributer and the prices 

paid by customers, i.e., markup. 

25. To benefit its own self-interest, Safeguard Metals directed the vast 

majority of SDIRA funds into coins that Safeguard Metals typically marked up 

excessively, notwithstanding the customer’s individual investment needs. Safeguard 

Metals accomplished this by pressuring customers to purchase coins that it claimed 

had numismatic or semi-numismatic value. 

26. Numismatic precious metals are rare, of limited availability, and have 

significant broad-based market demand and so have a value substantially more than 

the prevailing market price of the precious metal contained in the bullion. Seminumismatic precious metals refers to bullion that are claimed to exhibit both bullion 

and numismatic traits, such that the value is derived from the precious metal content, 

limited circulation, and some recognized exclusive or collectible value. 

27. Safeguard Metals offered coins with purported semi-numismatic or 

numismatic value in addition to the bullion value and coins with only bullion value. 

In particular, the Silver Coin known as the 1.25 oz Silver Rose Crown Guinea was 

the individual coin most frequently sold to customers. Safeguard Metals claimed the 

Silver Coins it sold to customers, including the 1.25 oz Silver Rose Crown Guinea, 

had semi-numismatic or numismatic value and sold them to customers at a premium 

far above Safeguard Metals’ acquisition cost and the melt value of the bullion. 

28. In regards to gold coins, Safeguard Metals, by and through its sales 

representatives or other agents, most frequently sold the 0.1 oz Gold American Eagle

to customers. Contrary to Silver Coins, which Safeguard Metals claimed to have 

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semi-numismatic or numismatic value, most gold coins were sold as common bullion 

products that lacked external value above and beyond the melt value of the bullion. 

29. Consequently, Safeguard Metals pressured customers to purchase Silver 

Coins and sold vastly more Silver Coins to customers than gold coins. 

Approximately 97%, or $66 million of the $68 million in total revenue Safeguard 

Metals fraudulently solicited from customers was used to purchase Silver Coins. 

30. Safeguard Metals also levied transaction fees to liquidate the Precious 

Metals held in SDIRA accounts. So after fraudulently overcharging customers on the 

front end when the Precious Metals transaction was executed, Safeguard Metals also 

imposed storage fees and a 1% to 3% liquidation fee upon the sale of Precious Metals 

within SDIRA accounts, significantly contributing to customers’ overall transaction 

costs. 

B. Defendants Defrauded Mostly Elderly Customers into Establishing 

SDIRAs and Cash Accounts to Purchase Precious Metals. 

31. Defendants targeted a vulnerable population of mostly elderly or 

retirement-aged persons. Many of these individuals had little experience investing in 

Precious Metals. Nonetheless, Defendants fraudulently solicited them to open 

SDIRAs or Cash Accounts in order to purchase Precious Metals. 

32. Defendants instructed their sales representatives or other agents to 

concentrate their fraudulent solicitations on elderly or retirement-aged persons in 

order to gain access to their retirement savings, including but not limited to, money 

market accounts and retirement savings held in tax advantaged accounts such as: 

Individual Retirement Accounts; employer sponsored 401(k) and 457(b) plans; Thrift 

Savings Plans; annuities; and other long-term retirement savings vehicles (“Qualified 

Retirement Savings”). 

33. As part of the scheme to gain access to customers’ retirement accounts 

and other savings, Defendants published misinformation on Safeguard Metals’

website in 2019 and 2020. Defendants made numerous false and misleading 

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statements of material fact, omitted to state material facts necessary to make the 

statements made not untrue or misleading, or made statements in reckless disregard 

about the firm’s business activities on their website, including, but not limited to, the 

following:

a. Safeguard Metals is rated number one among wealth protection 

firms (with no basis for this assertion); 

b. Safeguard Metals oversees more than $11 billion in assets under 

its management (when, in reality, the firm has sold substantially less than $75 million in Precious Metals and Silver Coins since it 

has been in business); 

c. Safeguard Metals has been in business for more than twenty years

(when, in truth, the startup formed in 2017, but did not appear to have significant operations until 2019); 

d. the number and location of Safeguard Metals’ offices, including office locations in London, England and Beverly Hills, California (when in actuality, the firm only has offices in Woodland Hills, 

California); and 

e. the use of false and fictitious employee names, touting non- existent employees on LinkedIn, misrepresenting employee job titles, and exaggerating employee qualifications and years of 

industry experience.

34. Defendants admitted the foregoing statements and blatant website 

misrepresentations are false.

35. Based on information and belief, Defendants removed the foregoing

statements and blatant website misrepresentations in or about January 2021 after 

becoming informed of a law enforcement investigation, and began to rely on other 

more nuanced misrepresentations, half-truths and omissions as part their solicitation 

scheme, as discussed further below. 

36. Safeguard Metals utilized fraudulent solicitations designed to build trust 

with customers based on representations of political affinity, and through references 

to and statements from financial gurus. 

37. In furtherance of the scheme, Santulan personally solicited customers, 

misrepresenting that Safeguard Metals was “the #1 name in precious metals and lead 

the industry as the fastest growing house, offering the cheapest and purest bullion in 

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the country for the benefit of our clients and we hold all proper and full accreditation 

from the state, federal government, and distributors alike,” with no basis for these 

material misstatements, half-truths or omissions, and in reckless disregard for the 

truth. Santulan also created sales scripts that were used to solicit customers. 

38. Defendants instructed its sales representatives or other agents to employ 

fraudulent solicitations designed to instill fear in elderly and retirement aged 

investors and other customers. To frighten those customers about the risk and safety 

of their investments in Qualified Retirement Savings and traditional accounts, 

Safeguard Metals made repeated material misrepresentations, half-truths, and 

omissions regarding the Money Market Fund Reform regulation promulgated by the 

Securities and Exchange Commission, Money Market Fund Reform Amendments to 

Form PF, 70 Fed. Reg. 47,736 (Aug. 14, 2014), and more recently, the Orderly 

Liquidation Authority promulgated pursuant to Dodd Frank, 12 U.S.C. §§ 5381-5394. 

Safeguard Metals played on the customers’ fears and materially misrepresented these 

provisions, omitting to disclose which asset classes the Money Market Fund Reform 

applies to, and making false and misleading statements about each law’s or 

regulation’s effects, and the extent to which these and other investor protections 

applied. For example, during fraudulent solicitations over the telephone, via email 

and in its sales scripts, Safeguard Metals made the following misrepresentations: 

a. financial institutions can “freeze you out of your retirement 

accounts if there was ever a market crash or correction again,” and 

either “confiscate” or freeze all of the holdings in your retirement 

or investment accounts, particularly during either a liquidity or 

financial crisis. “Banks then will use people’s money to bail 

themselves out.”; 

b. an investor is “just a beneficial owner” and “leases” securities and 

funds held in Qualified Retirement Savings, and further, the 

government “owns” the certificates on securities and funds held in 

these accounts; and

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c. “you’re pretty much in these [Quality Retirement Savings] 

accounts with no types of insurance,” but “the good news is that 

there are loopholes within the law to help protect . . . from it”

through safe and conservative investments in Precious Metals 

through SDIRAs. 

39. Defendants misrepresented that the Money Market Fund Reform and/or

the Orderly Liquidation Authority regulations apply to stocks and certain bonds held 

in Qualified Retirement Savings. They do not.

40. Safeguard Metals misrepresented that the government, not the investor, 

owns the certificates on securities and funds held in a Qualified Retirement Savings 

account. This is false. The beneficial owner is the true owner of an asset or security 

that is under a different legal name and the government does not own the certificates

on securities and funds held in these accounts.

41. Safeguard Metals misrepresented that Qualified Retirement Savings are 

uninsured. In reality, investor protections and insurance are offered through the 

Federal Deposit Insurance Corporation and the Securities Investor Protection 

Corporation. 

42. In 2021, Safeguard Metals misrepresented to customers that a change to 

Rule 22e-3 under the Money Market Fund Reform permits financial institutions to 

permanently freeze the liquidity in accounts, confiscate funds and will never pay 

participants back if the market fails. Furthermore, Safeguard Metals has maintained

the goal of investment firms is “to stop you from being able to redeem your shares, or

redeem the funds that you have in your retirement and stock accounts, by any means 

necessary.” 

43. These and similar misrepresentations made by Safeguard Metals and/or 

Santulan are false and misleading because Defendants failed to disclose to customers 

the narrow circumstances in which a money market fund can be permanently 

suspended, and furthermore, that liquidation follows when redemptions are 

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permanently suspended thereby returning money to shareholders and allowing 

investors to recover funds. 

44. Defendants knew, or were reckless in not knowing, that their

communications with customers contained material misstatements, half-truths, and 

omissions described above. 

C. Safeguard Metals Charged Exorbitant Price Markups on Silver Coins

That Bore No Relation to the Ranges Represented to Customers. 

45. After the SDIRAs and Cash Accounts were opened under false and 

fraudulent pretenses, Defendants executed their core strategy of selling customers

overpriced Silver Coins with enormous price markups, which Defendants referred to 

as “operating margins” when they communicated about the price markups with 

customers. Safeguard Metals grossly misrepresented the “operating margins” that 

they would charge customers in Precious Metals Shipping and Account Agreements 

(“Customer Agreements”) and representations made during sales confirmation calls. 

46. The Customer Agreements purported to establish the terms and 

conditions regarding sales of Precious Metals by Defendants to their customers. 

During the Relevant Period, Safeguard Metals used at least two versions of the 

Customer Agreements – one version prior to January 2021, and subsequently, a 

revised version following purported attempts to implement compliance measures at 

Safeguard Metals. Based on information and belief, Safeguard Metals purportedly 

implemented those compliance measures beginning in or around January 2021 after 

receiving notice of an investigation by law enforcement. 

47. Prior to January 2021, Safeguard Metals’ Customer Agreements 

represented, in pertinent part, the following relating to Safeguard Metals’ “operating 

margins” on metals: 

a. “The operating margin is the difference between Safeguard’s 

approximate acquiring cost of the Precious Metals and the price 

the Client pays.” 

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b. “Safeguard’s operating margin quoted to the Client for most 

common bullion products . . . is typically four percent (4%) for 

cash, and seven percent (7%) for IRA purchases.” 

c. “Operating margin on coins with semi-numismatic or numismatic 

value are rare coins . . . is usually twenty percent (20%) and for 

Proof products is twenty-three percent (23%).”

48. Despite these representations, Safeguard Metals actually sold Silver 

Coins to customers at average “operating margins” of 71%. This vastly exceeded the 

maximum “operating margin” of 23% disclosed in Safeguard Metals’ Customer 

Agreement. These overcharges were material misrepresentations and omissions. 

Further, Santulan admitted to establishing the price of these exorbitantly priced 

Precious Metals during Safeguard Metals’ initial period of operation. 

49. During purported implementation of compliance measures in or about 

January 2021, Safeguard Metals revised its sales confirmation scripts, and its 

Customer Agreements to provide new representations about its “operating margins” 

for Precious Metals. While Safeguard Metals’ representations about its “operating 

margins” varied between the sales confirmation scripts and Customer Agreements, 

the actual “operating margins” charged by the firm far exceeded either representation.

50. After January 2021, Safeguard Metals represented the following 

“operating margins” to customers during sales confirmation calls: 

SAFEGUARD METAL’S OPERATING MARGIN IS 

USUALLY 1% - 23%[.] THIS MAY VARY AND 

EXCEED 40% BASED ON MARKET CONDITIONS. 

51. After January 2021, Safeguard Metals’ Customer Agreements 

represented to customers the following relating to “operating margins”: 

Current operating margins on coins with semi-numismatic 

or numismatic value . . . is usually 23% - 33%. . . . The 

actual operating margin on any particular transaction can be 

any amount usually within, but also could be outside this 

range, but not exceeding 42%.

52. Following the purported implementation of compliance measures in

January 2021, Safeguard Metals’ actual “operating margin” on Silver Coins routinely 

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exceeded 40%, and averaged about 51%. Consequently, despite the inconsistent 

disclosures between sales confirmations and Customer Agreements, the “operating 

margin” on Silver Coins represented in sales confirmations rarely, if ever, fell within 

the usual and customary ranges disclosed to customers and averaged greater than the 

maximum “operating margin” represented in Customer Agreements. These 

overcharges were material misrepresentations and omissions. 

53. Safeguard Metals also provided inconsistent and misleading disclosures 

to customers during the sales confirmation process. In at least one instance, an 

Opener falsely represented to at least one customer that the specified “operating 

margins” only applied to investments exceeding $1 million, and were therefore 

inapplicable to his transaction because his investment fell under that threshold. Later, 

in contrast, a Closer stated during the sales confirmation call that specified “operating 

margins” do in fact apply because the customer is an accredited investor, resulting in 

ambiguous and conflicting disclosures. 

54. Safeguard Metals’ core strategy of selling fraudulently overpriced Silver 

Coins to customers was designed to maximize its profits through “operating margins” 

and commissions and resulted in substantial and nearly immediate customer losses. 

In excess of 97%, or $66 million of the $68 million in total revenue fraudulently 

solicited from customers was used to purchase Silver Coins, which had significantly 

higher “operating margins” compared to gold coins. 

55. Safeguard Metals knowingly or recklessly failed to inform customers of 

the material fact that the exorbitant “operating margins” charged on Silver Coins bore 

no relation to the figures represented in the Customer Agreements, or otherwise 

stated to customers. This had the effect of substantially depleting the values of 

investments held in customers’ SDIRAs and Cash Accounts. Nonetheless, Safeguard 

Metals continued to misrepresent to prospective and current SDIRA and Cash 

Account customers that Precious Metals were a safe and conservative investment 

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even though customers suffered immediate loss on the purchase of Precious Metals

from Safeguard Metals. 

D. Safeguard Metals Misrepresented to Customers How It Earned Profits 

and Lulled Customers by Making Misrepresentations About the Value of 

Customers’ Precious Metals. 

56. As part of the scheme, Safeguard Metals misrepresented and omitted 

material facts regarding how Safeguard Metals earned profits from Precious Metals 

transactions. 

57. During telephone sales calls, Safeguard Metals repeatedly misstated that 

its earnings arose solely from a 1% fee, and later in 2021, a 1% to 3% fee, that 

applied only when customers liquidated investments in Precious Metals. During a 

sales solicitation call with a prospective customer, a Safeguard Metals employee 

stated, in pertinent part, that “We take 1 percent of what we liquidate . . . . It’s our 

only way we make money,” leaving customers with the impression that Safeguard 

Metals did not profit in other respects from their Precious Metals transactions.

58. In reality, and as discussed above, Safeguard Metals also made money 

from charging excessive premiums on Silver Coins. For instance, Safeguard Metals 

earned an estimated 71% “operating margin” on Silver Coins during the 2019 to 2020 

timeframe—about 48% more than the maximum permitted pursuant to the Customer 

Agreement. In 2021, Safeguard Metals earned an estimated 51% “operating margin” 

on Silver Coins, about 9% more than the maximum permitted pursuant to the revised 

Customer Agreement. 

59. Safeguard Metals also falsely asserted “[i]f our clients are making 

money, that’s when we make money.” In fact, Safeguard Metals made money on 

Precious Metals notwithstanding whether its customers made money, and customers 

incurred additional transactional costs far greater than a 1% to 3% liquidation fee. 

Safeguard Metals omitted the true and accurate transaction costs and “operating 

margins” even when customers specifically inquired. 

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60. As part of the scheme to defraud, Safeguard Metals also deceived 

customers and concealed its fraud by hiding that customers significantly overpaid for 

their investments. Instead, Safeguard Metals made further misrepresentations about 

the value of the Precious Metals in customer accounts to placate and calm investors 

who were upset about the losses shown on their SDIRA statements. 

61. Customers received account statements from their SDIRA custodians 

showing account values significantly below the values originally paid to Safeguard 

Metals. The account statements were significantly lower because the SDIRA 

custodians assigned asset values to the coins held based on the melt value of the coin, 

ignoring any purported numismatic or semi-numismatic value. When customers 

confronted Safeguard Metals’ sales representatives about the disparity between their 

original investment and the value assigned by SDIRA custodians, the sales 

representatives rejected lower valuations and misrepresented to customers that values 

did not accurately reflect the resale value of the Precious Metals and Silver Coins, 

and that the actual resale value of their investments were much higher than that 

reported by the SDIRA custodians. (“Post-Purchase Misrepresentations”). 

62. Safeguard Metals, however, knew or recklessly disregarded that the 

resale price of the Silver Coins that it marketed and promoted was much lower than 

the amount customers paid for the Silver Coins. 

63. To further obfuscate customers’ true account values, Safeguard Metals

also lulled customers by telling them to wait or give it at least six months, or in some 

instances, three to five years, to allow their SDIRA accounts to make money.

64. Due to the acts, omissions, and failures of Safeguard Metals, at least two

SDIRA custodians terminated their business relationships with Safeguard Metals and 

no longer conduct business with the company. 

65. In terminating its contract with Safeguard Metals, one custodian stated, 

in pertinent part, that: 

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It has come to our attention that certain trades made in 

accounts represented by Safeguard Metals appear to not be 

in the best interest of the IRA owner as the values of the 

accounts were significantly less after the trade activity than 

the values of the accounts prior to the trades. 

D. Santulan Controlled the Operations of Safeguard Metals and Is Therefore 

Liable for Its Actions. 

66. During the Relevant Period, Santulan was the controlling person of 

Safeguard Metals and held 100% ownership of the company. 

67. Santulan was the sole member of the limited liability company, and no 

one else has ever served as a member. He executed the limited liability company 

registration using the title of “Principal.” 

68. As the controlling person, Santulan made all significant business 

decisions on behalf of Safeguard Metals, and was authorized to make personnel 

decisions about hiring and firing of employees. Prior to October 2020, Santulan

created sales scripts and email templates and distributed customer leads and provided 

training to sales representatives at Safeguard Metals. Santulan determined and set the 

prices at which Safeguard Metals sold Precious Metals and Silver Coins to the public. 

69. For the entirety of the Relevant Period, Santulan was the only signatory 

on Safeguard Metals’ bank accounts and served as the only person authorized to enter 

into financial transactions on behalf of the company. 

70. Santulan did not act in good faith or has knowingly induced Safeguard 

Metals’ fraudulent acts. 

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V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND 

COMMISSION REGULATIONS

COUNT I

Fraud

Violations of Section 6(c)(1) of the CEA, 7 U.S.C. § 9(1), and CFTC Regulation 

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

(Brought by all Plaintiffs)

71. Paragraphs 1 through 70 are realleged and incorporated herein by 

reference.

72. 7 U.S.C. § 9(1) provides, in relevant part:

It shall be unlawful for any person, directly or indirectly, to use or 

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

or a contract of sale of any commodity in interstate commerce, or 

for future delivery on or subject to the rules of any registered 

entity, any manipulative or deceptive device or contrivance, in 

contravention of such rules and regulations as the commission 

shall promulgate . . . .

73. 17 C.F.R § 180.1(a) provides, in relevant part:

It shall be unlawful for any person, directly or indirectly, in 

connection with any swap, or contract of sale of any commodity in 

interstate commerce, or contract for future delivery on or subject 

to the rules of any registered entity, 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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74. By reason of the conduct described above, Defendants, by and through 

Santulan, its officers, employees and agents, directly or indirectly, in connection with 

contracts of sale of commodities in interstate commerce, intentionally or recklessly 

violated 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3).

75. By reason of the conduct described above, the acts, misrepresentations, 

omissions, and failures of Santulan and other officers, employees, and agents acting 

for Safeguard Metals occurred within the scope of their employment, agency, or 

office with Safeguard Metals. Safeguard Metals is therefore liable under Section 

2(a)(1)(B) of the CEA, 7 U.S.C. § 2(a)(1)(B), and CFTC Regulation 1.2, 17 C.F.R. 

§ 1.2 (2021), as a principal for Santulan’s violations of the CEA and CFTC 

Regulations. 

76. Santulan controlled Safeguard Metals and has not acted in good faith or 

has knowingly induced, directly or indirectly, the acts constituting Safeguard Metals’ 

violations alleged in this count. As a result, pursuant to Section 13(b) of the CEA, 

7 U.S.C. § 13c(b), Santulan is liable for Safeguard Metals’ violations of 7 U.S.C. 

§ 9(1) and 17 C.F.R. § 180.1(a)(1)-(3), as controlling person. 

77. Each use or employment or attempted use or employment of any 

manipulative device, scheme, or artifice to defraud; untrue or misleading statement of 

fact, omission of material fact necessary to make statements not untrue or misleading; 

or act of engaging, or attempting to engage, in acts, practices or courses of business 

that operated or would have operated as a fraud or deceit on Safeguard Metals’ 

customers is alleged as a separate and distinct violation of 7 U.S.C. § 9(1) and 

17 C.F.R. § 180.1(a)(1)-(3) 

VI. RELIEF REQUESTED

78. The CFTC and the States respectfully request that this Court, as 

authorized by Sections 6c and 6d(1) of the CEA, 7 U.S.C. §§ 13a-1, 13a-2(1) and 

pursuant to its own equitable powers:

A. Find that Defendants violated Section 6(c)(1) of the CEA, 7 U.S.C. 

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

(3) (2021); 

B. Enter an order of permanent injunction enjoining Defendants 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 

conduct described above, in violation of 7 U.S.C. § 9(1) and 17 C.F.R. 

§ 180.1(a)(1)-(3); 

C. Enter an order of permanent injunction restraining and enjoining 

Defendants 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 CEA, 7 U.S.C. § 1a(40)); 

2) Entering into any transactions involving “commodity interests” 

(as that term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021)), 

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 

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

17 C.F.R. § 4.14(a)(9) (2021); 

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

3.1(a), 17 C.F.R. § 3.1(a) (2021)), 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 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 that constitute violations of 

the CEA or CFTC Regulations, as described herein, including prejudgment and post-judgment interest;

E. Enter an order requiring Defendants, 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 to rescind, pursuant to such 

procedures as the Court may order, all contracts and agreements, 

whether implied or express, entered into between Defendants and any of 

the customers whose funds were received by Defendants as a result of 

Defendants’ violations of the CEA or CFTC Regulations as described 

herein;

G. Enter an order directing Defendants to pay a civil monetary penalty 

assessed by the Court, in an amount not to exceed the penalty prescribed 

by Section 6c(d)(1) of the CEA, 7 U.S.C. § 13a-1(d)(1), as adjusted for 

inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act 

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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 (2021), for each 

violation of the CEA or CFTC Regulations, described herein; 

H. Enter an order requiring Defendants to pay costs and fees as permitted 

by 28 U.S.C. §§ 1920 and 2413(a)(2); and

I. Enter an order providing such other and further relief as the Court deems 

proper. 

VII. DEMAND FOR JURY TRIAL 

79. Plaintiffs hereby demand a jury trial. 

I hereby attest that all other signatories listed, and on whose behalf the filing is 

submitted, concur in the filing’s content and have authorized the filing. 

Dated: February 1, 2022 Respectfully submitted,

COMMODITY FUTURES 

TRADING COMMISSION

By: /s/ JonMarc Buffa 

JONMARC BUFFA

California Bar No. 217324

jbuffa@cftc.gov

JEFF LE RICHE, pro hac vice pending

(Attorney-In-Charge)

Missouri Bar No. 46557

jleriche@cftc.gov

CLEMON D. ASHLEY, pro hac vice pending

Illinois Bar No. 6294839

cashley@cftc.gov

Attorneys for Plaintiff

COMMODITY FUTURES

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TRADING COMMISSION

2600 Grand Boulevard, Suite 210

Kansas City, Missouri 64108

Telephone: (816) 960-7700

Facsimile: (816) 960-7750

FOR THE STATE OF ALABAMA

By: /s/ Stephen P. Feaga 

STEPHEN P. FEAGA, pro hac vice pending

Assistant Attorney General

Alabama Bar No. 7374A60S

Steve.Feaga@asc.alabama.gov

ANNE W. GUNTER, pro hac vice pending

Assistant Attorney General

Alabama Bar. No. 4666N91P

Anne.Gunter@asc.alabama.gov

Attorneys for Plaintiff

ALABAMA SECURITIES COMMISSION

445 Dexter Avenue, Suite 12000

Montgomery, AL 36104

Telephone: (334) 242-2984

Facsimile: (334) 242-0240

FOR THE STATE OF ARIZONA

By: /s/ Christopher Nichols 

CHRISTOPHER NICHOLS, pro hac vice 

pending

Enforcement Attorney 

Arizona Bar No. 029958 

cnichols@azcc.gov

Attorney for Plaintiff

ARIZONA CORPORATION COMMISSION

1300 W. Washington Street, 3rd Floor

Phoenix, AZ 85007

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Telephone: (605) 542-0639

Facsimile: (602) 714-8120

FOR THE STATE OF ARKANSAS

By: /s/ Joseph Joslin 

JOSEPH JOSLIN, pro hac vice pending

Arkansas Bar No. 2014190

Joseph.Joslin@arkansas.gov

Attorney for Plaintiff

ARKANSAS SECURITIES DEPARTMENT

1 Commerce Way, Suite 402

Little Rock, AR 72202

Telephone: (501) 683-0806

Facsimile: (501) 324-9268

FOR THE STATE OF CALIFORNIA

By: /s/ Kelly Suk 

DANIELLE A. STOUMBOS

California Bar No. 264784

Danielle.Stoumbos@dfpi.ca.gov

KELLY SUK 

California Bar No. 301757

Kelly.Suk@dfpi.ca.gov

Attorneys for Plaintiff

CALIFORNIA DEPARTMENT OF 

FINANCIAL PROTECTION & 

INNOVATION

320 West Fourth Street, Suite 750

Los Angeles, California 90013

Telephone: (213) 503-2046

Facsimile: (213) 576-7181

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FOR THE STATE OF CONNECTICUT

By: /s/ James W. Caley 

JAMES W. CALEY, pro hac vice pending

Assistant Attorney General

Connecticut Bar No. 430246

james.caley@ct.gov

Attorney for Plaintiff

STATE OF CONNECTICUT DEPARTMENT 

OF BANKING

260 Constitution Plaza

Hartford, CT 06103-1800

Telephone: (860) 808-5461

Facsimile: (860) 808-5387

FOR THE STATE OF FLORIDA

By: /s/ George C. Bedell III 

GEORGE C. BEDELL III, pro hac vice 

pending

Chief Counsel

Florida Bar No. 363685

George.Bedell@flofr.gov 

Attorney for Plaintiff

FLORIDA OFFICE OF FINANCIAL 

REGULATION

200 East Gaines Street

Tallahassee, FL 32399-0370

Telephone: (813) 218-5353

Facsimile: (813) 272-2498

FOR THE STATE OF HAWAII

By: /s/ Rayni M. Nakamura-Watanabe 

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RAYNI M. NAKAMURA-WATANABE, pro 

hac vice pending

Acting Supervising Attorney

Hawaii Bar No. 9032-0 

rnakamur@dcca.hawaii.gov

Attorney for Plaintiff

STATE OF HAWAII, DEPARTMENT OF 

COMMERCE AND CONSUMER AFFAIRS

335 Merchant Street, Room 205

Honolulu, HI 96813 

Telephone: (808) 586-2740

Facsimile: (808) 586-3977

FOR THE STATE OF IDAHO

OFFICE OF THE ATTORNEY GENERAL

STATE OF IDAHO

LAWRENCE G. WASDEN

By: /s/ Loren Messerly 

LOREN MESSERLY, pro hac vice pending

Deputy Attorney General

Idaho Bar No. 7434

loren.messerly@finance.idaho.gov 

Attorney for Plaintiff

STATE OF IDAHO, DEPARTMENT OF 

FINANCE

P.O. Box 83720

Boise, ID 83720-0031

Telephone: (208) 332-8093 

Facsimile: (208) 332-8099

FOR THE STATE OF ILLINOIS

By:___________________

PAULA K. BOULDON, pro hac vice pending

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Special Assistant Attorney General

Illinois Bar No. 6198150

PBouldon@ILSOS.gov

Attorney for Plaintiff

OFFICE OF THE SECRETARY OF STATE,

ILLINOIS SECURITIES DEPARTMENT

69 W. Washington St., Suite 1220

Chicago, IL 60602

Telephone: (312) 793-3164

Facsimile: (312) 793-1202

FOR THE STATE OF INDIANA

By: /s/ Jefferson S. Garn_______

JEFFERSON S. GARN, pro hac vice pending

Deputy Attorney General

Indiana Bar No. 29921-49

Jefferson.Garn@atg.in.gov

 

Attorney for Plaintiff

INDIANA SECURITIES DIVISION

302 W. Washington St. 

IGCS—5th Floor

Indianapolis, IN 46204

Telephone: (317) 234-7119

Facsimile: (317) 232-7979

FOR THE STATE OF KENTUCKY

By: /s/ Gary A. Stephens 

GARY A. STEPHENS, pro hac vice pending

Assistant General Counsel

Kentucky Bar No. 87740

Gary.Stephens@ky.gov

Attorney for Plaintiff

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KENTUCKY DEPARTMENT OF 

FINANCIAL INSTITUTIONS

500 Mero St. 2SW19

Frankfort, KY 40601

Telephone: (502) 782-9046

Facsimile: (502) 573-8787

FOR THE STATE OF MARYLAND

By: /s/ Max F. Brauer

MAX F. BRAUER, pro hac vice pending

Assistant Attorney General

Maryland State Does Not Use Bar Numbers 

mbrauer@oag.state.md.us

Attorney for Plaintiff

STATE OF MARYLAND EX REL 

MARYLAND SECURITIES 

COMMISSIONER 

200 Saint Paul Place, 25th Floor

Baltimore, MD 21202

Telephone: (410) 576-6950

Facsimile: (410) 576-6532

FOR THE PEOPLE OF THE STATE OF 

MICHIGAN 

By: /s/ Michael S. Hill 

MICHAEL S. HILL, pro hac vice pending

Assistant Attorney General

Michigan Bar No. P73084

HillM19@michigan.gov

Attorney for Plaintiff

ATTORNEY GENERAL DANA NESSEL 

ON BEHALF OF THE PEOPLE OF THE 

STATE OF MICHIGAN 

P.O. Box 30736

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Lansing, MI 48909

Telephone: (517) 335-7632

Facsimile: (517) 335-6755

FOR THE STATE OF MISSISSIPPI

By: /s/ Seth Shannon 

SETH SHANNON, pro hac vice pending

Mississippi Bar No. 103466

seth.shannon@ago.ms.gov

Attorney for Plaintiff

MISSISSIPPI SECRETARY OF STATE

Post Office Box 220

Jackson, MS 39205

Telephone: (769) 237-6406

Facsimile: (601) 359-4231

FOR THE STATE OF MISSOURI

By: /s/ Steven M. Kretzer 

STEVEN M. KRETZER, pro hac vice pending

Missouri Bar No. 56950

Steven.Kretzer@sos.mo.gov 

Attorney for Plaintiff

MISSOURI COMMISSIONER OF 

SECURITIES

600 W. Main Street

Jefferson City, MO 65102 

Telephone: (573) 751-4136

Facsimile: (573) 526-3124

FOR THE STATE OF NEBRASKA

By: /s/ Joshua Shasserre 

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JOSHUA SHASSERRE, pro hac vice pending

Assistant Attorney General

Nebraska Bar No. 23885

Joshua.Shasserre@nebraska.gov

Attorney for Plaintiff

NEBRASKA DEPARTMENT OF BANKING 

& FINANCE

2115 State Capitol

Lincoln, NE 68509

Telephone: (402) 471-2682

Facsimile: (402) 471-3297

FOR THE STATE OF NEW MEXICO

By: /s/ Alissa N. Berger 

ALISSA N. BERGER, pro hac vice pending

New Mexico Bar No. 21769

Alissa.Berger@state.nm.us

Attorney for Plaintiff

NEW MEXICO SECURITIES DIVISION

5500 San Antonio Drive NE

Albuquerque, NM 87109

Telephone: (505) 503-5987

Facsimile: (505) 222-9848

FOR THE PEOPLE OF THE STATE OF 

NEW YORK

LETITIA JAMES

ATTORNEY GENERAL OF THE STATE OF 

NEW YORK

By: /s/ Tatyana Trakht 

TATYANA “TANYA” TRAKHT, pro hac 

vice pending

Assistant Attorney General

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New York State Does Not Use Bar Numbers

Tanya.Trakht@ag.ny.gov

Attorney for Plaintiff

ATTORNEY GENERAL OF THE STATE OF 

NEW YORK

28 Liberty Street, 21st Floor

New York, NY 10005

Telephone: (212) 416-8457

Facsimile: (212) 416-8816

FOR THE STATE OF NORTH CAROLINA

By: /s/ Sherrell Forbes 

SHERRELL FORBES, pro hac vice pending

North Carolina Bar No. 42830

sforbes@sosnc.gov

Attorney for Plaintiff

NORTH CAROLINA DEPARTMENT OF 

THE SECRETARY OF STATE

P.O. Box 29622

Raleigh, NC 27626

Telephone: (919) 814-5532

Facsimile: (919) 814-5596

FOR THE STATE OF OKLAHOMA

By: /s/ Robert Fagnant 

ROBERT FAGNANT, pro hac vice pending

Oklahoma Bar No. 30548

rfagnant@securities.ok.gov

Attorney for Plaintiff

OKLAHOMA DEPARTMENT OF 

SECURITIES

204 N. Robinson Avenue, Suite 400

Oklahoma City, OK 37243

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Telephone: (405) 280-7718

Facsimile: (405) 280-7742

FOR THE STATE OF OREGON

By: /s/ Daniel J. Rice 

DANIEL J. RICE, pro hac vice pending

Oregon Bar No. 084536

Daniel.Rice@doj.state.or.us

Attorney for Plaintiff

OREGON DEPARTMENT OF CONSUMER 

AND BUSINESS SERVICES

350 Winter Street NE, Room 410

Salem, OR 97309

Telephone: (503) 378-4140

Facsimile: (503) 947-0088

FOR THE STATE OF SOUTH CAROLINA

By: /s/ Jonathan Williams 

JONATHAN WILLIAMS, pro hac vice 

pending

South Carolina Bar No. 72509

jwilliams@scag.gov

Attorney for Plaintiff

STATE OF SOUTH CAROLINA

OFFICE OF ATTORNEY GENERAL

P.O. Box 11549

Columbia, SC 29211

Telephone: (803) 734-7208

Facsimile: (803) 734-7208

FOR THE STATE OF SOUTH DAKOTA

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By: /s/ Clayton Grueb 

CLAYTON GRUEB, pro hac vice pending

South Dakota Bar No. 4642

Clayton.grueb@state.sd.us

Attorney for Plaintiff

STATE OF SOUTH DAKOTA 

DEPARTMENT OF LABOR & 

REGULATION

2330 N. Maple Ave. Suite 2

Rapid City, SD 57701

Telephone: (605) 773-3563

Facsimile: (605) 773-5369

FOR THE STATE OF TENNESSEE

HERBERT H. SLATERY III

Attorney General and Reporter

for the State of Tennessee

By: /s/ Kevin M. Kreutz 

KEVIN M. KREUTZ

Acting Assistant Attorney General

California Bar No. 264654

Kevin.Kreutz@ag.tn.gov

Attorney for Plaintiff

Commissioner of the Tennessee Department of 

Commerce and Insurance

Office of Tennessee Attorney General

Financial Division

P.O. Box 20207 

Nashville, TN 37202-0207

Telephone: (615) 253-0694

Facsimile: (615) 741-8151

FOR THE STATE OF VERMONT

By: /s/ Jennifer Rood 

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JENNIFER ROOD, pro hac vice pending

Assistant General Counsel

Vermont Bar No. 5515 

Jennifer.Rood@vermont.gov

Attorney for Plaintiff

VERMONT DEPARTMENT OF 

FINANCIAL REGULATION

89 Main Street

Montpelier, VT 05620

Telephone: (877) 550-3907

Facsimile: (802) 828-1919

FOR THE STATE OF WASHINGTON

By: /s/ Stephen S. Manning 

STEPHEN S. MANNING, pro hac vice 

pending

Washington Bar No. 36965

Stephen.Manning@atg.wa.gov

Attorney for Plaintiff

WASHINGTON STATE DEPARTMENT OF 

FINANCIAL INSTITUTIONS, SECURITIES 

DIVISION

150 Israel Rd. SW

Tumwater, WA 98501

Telephone: (360) 902-8700

Facsimile: (360) 902-0524

FOR THE STATE OF WISCONSIN

JOSHUA L. KAUL

Attorney General

Wisconsin Department of Justice

By: /s/ Laura E. McFarlane 

Laura E. McFarlane, pro hac vice pending

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WI State Bar No. 1089358 

mcfarlanele@doj.state.wi.us 

Attorney for Plaintiff

THE STATE OF WISCONSIN 

Post Office Box 7857

Madison, WI 53707-7857

Telephone: (608) 266-8911

Facsimile: (608) 267-2779

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