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UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of: 

Chad Robert Henderson & 

Prime Agricultural Investors, Inc., 

Respondents. 

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CFTC Docket No. 23-01

ORDER INSTITUTING PROCEEDINGS PURSUANT TO 

SECTION 6(c) AND 6(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 

during the period from at least January, 2018 through at least September, 2019 (the “Relevant 

Period”), Chad Robert Henderson (“Chad Henderson” or “Henderson”) and Prime Agricultural 

Investors, Inc. (“Prime Agricultural Investors”) (collectively, “Respondents”), violated Section 

4b(a)(1)(A) and (C) of the Commodity Exchange Act (“CEA” or “Act”), 7 U.S.C. § 6b(a)(1)(A), 

(C) by fraudulently transferring profitable futures transactions from customer accounts to Mr.

Henderson’s account and, at times, transferring Mr. Henderson’s unprofitable futures transactions

to customer accounts. In addition, during the Relevant Period Prime Agricultural Investors failed

to supervise Henderson in violation of Regulation 166.3, 17 C.F.R. § 166.3 (2021). Therefore, the

Commission deems it appropriate and in the public interest that public administrative proceedings

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

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

In anticipation of the institution of an administrative proceeding, 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, Respondent consents to 

the entry of this Order Instituting Proceedings Pursuant to Section 6(c) and 6(d) of the Act, 

Making Findings, and Imposing Remedial Sanctions (“Order”) and acknowledges service of this 
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Order.1 

The Commission acknowledges the cooperation of Respondents throughout the course of 

the investigation. 

II. FINDINGS 

The Commission finds the following: 

A. SUMMARY 

From January, 2018 to September, 2019, Chad Henderson, in his capacity as an Associated 

person and Principal of Prime Agricultural Investors, at times transferred profitable futures 

transactions from his customers’ commodity interest accounts to his own account. He also at times 

would transfer his own unprofitable futures transactions to his customers’ accounts. In effect, 

Henderson allocated profits to himself that should have gone to his customers and, at times, 

avoided losses that he otherwise would have incurred. 

Accordingly, during the Relevant Period, Respondents violated the Act by improperly 

transferring profitable customer transactions from customer accounts to Mr. Henderson’s personal 

trading account, and also by fraudulently transferring losing transactions from Mr. Henderson’s 

trading account to customer accounts. These transfers violated Section 4b(a)(1)(A) and (C) of the 

CEA, 7 U.S.C. § 6b(a)(1)(A), (C). In addition, during the Relevant Period Prime Agricultural 

Investors failed to diligently supervise Henderson in violation of Commission Regulation 166.3, 17 

C.F.R. § 166.3 (2021). 

B. RESPONDENTS 

Chad Henderson is a registered Associated Person and Principal of Prime Agricultural 

Investors. He is a resident of Brookfield, Wisconsin. 

Prime Agricultural Investors, Inc. is registered Introducing Broker located in Brookfield, 

Wisconsin. 

C. FACTS 

1. Fraud in Connection with Commodity Futures Transactions 

As a principal of Prime Agricultural Investors, Chad Henderson transacted CME futures 

and options for customers, and also for his own trading account. These transactions were cleared 

 

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 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 agrees that they shall be taken as true and correct and 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 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. 
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through a registered Futures Commission Merchant. 

From January, 2018 to September, 2019, Henderson at times transferred profitable futures 

transactions in his customers’ commodity interest accounts to his own account. He also at times 

would transfer his own unprofitable futures transactions to his customers’ accounts. The fraudulent 

transactions included futures transactions in wheat, corn, soybeans, and cattle. 

A number of transactions at issue took the following form. Henderson would get an order, 

usually by telephone, from a customer, who would direct Henderson to transact futures, but would 

give Henderson some leeway regarding the time, price and manner of the transaction. Henderson 

would transact futures consistent with these instructions in the customer’s account. If the 

transaction was not profitable, or not profitable in the short term, Henderson would normally leave 

the transaction in the customer’s account. However, if the market moved rapidly in the customer’s 

favor, Henderson would, in some instances, move the transaction to his own account. Henderson 

could then enter another transaction for the customer at a higher price or, alternatively, tell the 

customer that it had not been possible to transact within the requested price range. In effect, 

Henderson, allocated profits to himself that should have gone to his customers. At times, 

Henderson also transferred losing transactions from his account to customers’ accounts in order to 

avoid losses that he otherwise would have incurred. This conduct constituted fraud and willful 

deception in violation of Section 4b(a)(1) (A) and (C) of the Act. 

Accordingly, during the Relevant Period, Respondents violated the Act by fraudulently 

transferring profitable customer transactions from customer accounts to Chad Henderson’s 

personal trading account and also by fraudulently transferring losing transactions in Chad 

Henderson’s trading account to customer accounts. These transfers violated Section 4b(a)(1)(A) 

and (C) of the CEA, 7 U.S.C. § 6b(a)(1) (A), (C). 

Prime Agricultural Investors is liable, as a principal, for Henderson’s conduct pursuant to 

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

§ 1.2 (2021). 

2. Failure to Diligently Supervise 

Respondent Prime Agricultural Investors failed to adopt internal policies and procedures to 

effectively prevent this type of fraudulent trading activity. It did not, for instance, have a policy 

requiring that someone else in addition to the individual broker review trade transfer requests of 

the kind that Chad Henderson routinely made. Prime Agricultural Investors also failed to 

diligently supervise Chad Henderson in a manner sufficient to detect his repeated violations. 

Prime Agricultural Investors’ failure to implement robust policies and procedures to 

prevent fraudulent trade transfers between employee and customer accounts, and its failure to 

diligently supervise Chad Henderson, constituted failure to diligently supervise in violation of 

Commission Regulation 166.3. 

During the Relevant Period, Prime Agricultural Investors violated Commission Regulation 

166.3, 17 C.F.R. § 166.3 (2021) by failing to put in place controls sufficient to prevent 

Henderson’s improper conduct. 
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III. LEGAL DISCUSSION 

A. Respondents’ Conduct Violated Sections Section 4b(a)(1) (A) and (C) of the Act, 

7 U.S.C. § 6b(a)(1) (A), (C) 

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

willful deception in connection with any contract of sale of any commodity in interstate commerce 

or for future delivery. This section makes it unlawful for any person, in connection with any order 

for future delivery that is made, on or subject to the rules of a designated contract market, for or on 

behalf of any other person to “(A) 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.” 

The intentional allocation of trades to disadvantage customers constitutes fraud under 

Section 4b(a) of the Act. See In re GNP Commodities, Inc., CFTC No. 89-1, 1992 WL 201158, at 

*10 (Aug. 11, 1992), aff’d sub nom. Monieson v. CFTC, 996 F.2d 852 (7th Cir. 1993) (affirming 

ALJ’s finding that respondents directed profitable fills to favored accounts in violation of Section 

4b of the Act, and noting that burden of explaining allocation methodology shifts to respondent 

after Commission presents prima facie case of fraudulent allocation); In re Lincolnwood 

Commodities, Inc., CFTC No. 78-48, 1984 WL 48104, at *21 (Jan. 31, 1984) (concluding that 

respondents fraudulently allocated winning day trades to their accounts and losing day trades to 

customers’ accounts in violation of Section 4b of the Act); see also In re Nikkhah, CFTC No. 95-

13, 2000 WL 622872, at *8-10 (May 12, 2000) (assessing the propriety of an allocation 

methodology for bunched orders). 

Moreover, even allocations that “arbitrarily deprive[] a customer of a profit opportunity 

amounts to fraud” under Section 4b(a) of the Act. Nikkhah, 2000 WL 622872, at *8 (citing United 

States v. Ashman, 979 F.2d 469, 477-78 (7th Cir. 1992)). Accordingly, whatever allocation 

methodology is adopted “must be predetermined and fair, such that no customer or group of 

customers receives consistently favorable or unfavorable treatment.” Id. at *10 (quoting GNP, 

1992 WL 201158, at *9) (“The proper focus is whether the weight of the evidence shows that 

[Respondent] acted with intent by knowingly employing an allocation process that was neither 

predetermined nor fair to all his discretionary account customers. . . .”). 

A violation of Section 4b(a) requires that the wrongdoer act with scienter. See Drexel 

Burnham Lambert, Inc. v. CFTC, 850 F.2d 742, 748 (D.C. Cir. 1988). Scienter “refers to a mental 

state embracing an intent to deceive, manipulate, or defraud.” CFTC v. Rosenberg, 85 F. Supp. 2d 

424, 448 (D.N.J. 2000) (citing Ernst & Ernst v. Hochfelder, 425 U.S. 185, 193 (1976)). 

Recklessness is sufficient to satisfy the scienter requirement of Section 4b of the Act. See, e.g., 

Drexel, 850 F.2d at 748; Rosenberg, 85 F. Supp. 2d at 448. The Commission can establish scienter 

by showing that a defendant made an extreme departure from the standards of ordinary care. CFTC 

v. R.J. Fitzgerald & Co., Inc., 310 F.3d 1321, 1328 (11th Cir. 2002). Scienter cannot be avoided 

“by ignorance brought about by willfully or carelessly ignoring the truth.” CFTC v. Savage, 611 

F.2d 270, 283 (9th Cir. 1979). 

Respondents, during the Relevant Period, on several occasions improperly transferred 

profitable futures transactions in customer accounts to Chad Henderson’s personal trading account, 

and also at times improperly transferred losing transactions in Chad Henderson’s trading account to 

customer accounts. This conduct violated Section 4b(a)(1) (A) and (C). 
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B. Prime Agricultural Investors’ Failure to Diligently Supervise Violated Regulation 166.3, 

17 C.F.R. § 166.3 (2021) 

Commission Regulation 166.3, 17 C.F.R. § 166.3 (2021) imposes on every Commission 

registrant, like Prime Agricultural Investors, an affirmative duty to “diligently supervise the 

handling by its partners, officers, employees and agents . . . of all commodity interest accounts 

carried, operated, advised or introduced by the registrant and all other activities of its partners, 

officers, employees and agents . . . relating to its business as a Commission registrant.” 

A violation of Regulation 166.3 is an independent violation for which no underlying 

violation is necessary. See, e.g., In re Collins, CFTC No. 94-13, 1997 WL 761927, at *10 (Dec. 10, 

1997) (“It is well-settled that a violation under Rule 166.3 is ‘an independent and primary violation 

for which no underlying violation is necessary.’” (citation omitted)); In re GNP Commodities, Inc., 

CFTC No. 89-1, 1992 WL 201158, at *17 n.11 (Aug. 11, 1992) (“Rule 166.3 establishes failure to 

supervise as an independent and primary violation. . . .” (citation omitted)), aff’d in part and 

modified sub nom. Monieson v. CFTC, 996 F.2d 852 (7th Cir. 1993). 

For a registrant to fulfill its duties under Regulation 166.3, it must both design an adequate 

program of supervision and ensure that the program is followed. See GNP Commodities, 1992 WL 

201158, at *17–19 (providing that, even if an adequate supervisory system is in place, Regulation 

166.3 can still be violated if the supervisory system is not diligently administered). As a result, a 

violation of Regulation 166.3 “is demonstrated by showing either that: (1) the registrant’s 

supervisory system was generally inadequate; or (2) the registrant failed to perform its supervisory 

duties diligently.” In re FC Stone, LLC, CFTC No. 15-21, 2015 WL 2066891, at *3 (May 1, 2015) 

(consent order) (citations omitted). 

Accordingly, a “showing that the registrant lacks an adequate supervisory system can be 

sufficient to establish a breach of duty under Regulation 166.3.” Collins, 1997 WL 761927, at *10. 

If the registrant fails to perform its supervisory duties diligently, that is likewise sufficient to 

establish a violation of the supervision requirement. See, e.g., In re Murlas Commodities, Inc., 

CFTC No. 85-29, 1995 WL 523563, at *9 (Sept. 1, 1995); In re Paragon Futures Ass’n, CFTC No. 

88-18, 1992 WL 74261, at *14 (Apr. 1, 1992). Evidence of violations that “should be detected by a 

diligent system of supervision, either because of the nature of the violations or because the 

violations have occurred repeatedly” is probative of a failure to supervise. Paragon Futures, 1992 

WL 74261, at *14. 

Here, Respondent Prime Agricultural Investors failed to adopt internal policies and 

procedures sufficient to prevent the fraudulent trade transfers, and also failed to diligently supervise 

Chad Henderson in a manner sufficient to detect his repeated violations. Accordingly, Respondent 

violated Regulation 166.3. 

IV. FINDINGS OF VIOLATIONS 

Based on the foregoing, the Commission finds that Respondents violated Section 4b(a)(1) 

(A) and (C) of the CEA, 7 U.S.C. § 6b(a)(1) (A), (C). 

The Commission further finds that Respondent Prime Agricultural Investors violated 

Regulation 166.3, 17 C.F.R. § 166.3 (2021). 
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V. OFFER OF SETTLEMENT 

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

findings and conclusions herein: 

A. Acknowledge receipt of service of this Order; 

B. Admit the jurisdiction of the Commission to all the matters set forth in this Order and for 

any action or proceeding brought or authorized by the Commission based on a 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 they may possess under the Equal Access to Justice Act, 

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

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

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

7. Any and all claims that they may possess under the Small Business Regulatory 

Enforcement Fairness Act of 1996, (“SBREFA”), Pub. L. No. 104-121, tit. II, 

§§ 201-253, 110 Stat 847-74 (codified as amended 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 upon 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; 

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 Section 4b(a)(1) (A) 

and (C) of the Commodity Exchange Act, 7 U.S.C. § 6b(a)(1) (A), (C), and that 

Respondent Prime Agricultural Investors violated Regulation 166.3, 17 C.F.R. 

§ 166.3 (2021). 

2. Orders Respondents to cease and desist from violating Section 4b(a)(1) (A) and (C) 
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of the Commodity Exchange Act, 7 U.S.C. § 6b(a)(1) (A), (C), and orders 

Respondent Prime Agricultural Investors to cease and desist from violating 

Regulation 166.3, 17 C.F.R. § 166.3 (2021). 

3. Orders that Respondent Chad Henderson be 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), for a period of three 

years after the date of entry or this Order and all registered entities shall refuse him 

trading privileges during that period. 

4. Orders that Respondents shall pay, jointly and severally, restitution, in the amount of 

four hundred and sixty three thousand four hundred and fifty nine dollars and sixty 

three cents ($463,459.65) (“Restitution Obligation”), plus any post- judgment 

interest; provided, however, that the restitution will be offset by any restitution 

payment made pursuant to the manner delineated by Respondents’ Notice of 

Disciplinary Action issued by the Chicago Mercantile Exchange (“CME”) (the 

“CME Notice”). 

5. Orders that Respondent Chad Henderson shall pay a civil monetary penalty in the 

amount of three-hundred thousand dollars ($300,000) (“Henderson CMP 

Obligation”) and that Respondent Prime Agricultural Investors shall pay a civil 

monetary penalty in the amount of one-hundred thousand dollars ($100,000) 

(“Prime Agricultural Investors CMP Obligation”) (collectively, “CMP 

Obligations”). Prime Agricultural Investors shall be jointly and severally liable for 

the Henderson CMP Obligation. The CMP Obligations should be paid within ten 

business days of the date of the entry of this Order; provided, however, that the 

CMP Obligations will be offset by the amount of any fine made pursuant to the 

CME Notice. 

6. Orders that Respondent Chad Henderson agrees that he shall never, directly or 

indirectly: 

a. Control or direct the trading for himself, or on behalf of any other person 

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

involving commodity interests; 

b. Receive, or accept any funds from any person for the purpose of 

purchasing or selling any commodity interests. 

7. Orders Respondents and their successors and assigns to comply with the conditions 

and undertakings consented to in the Offer and set forth in Part VI of this Order. 

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

Accordingly, IT IS HEREBY ORDERED THAT: 

A. Respondents shall cease and desist from violating Section 4b(a)(1) (A) and (C) of the 

Commodity Exchange Act, 7 U.S.C. § 6b(a)(1) (A), (C), and Respondent Prime 

Agricultural Investors shall cease and desist from violating Regulation 166.3, 17 C.F.R. 

§ 166.3 (2021). 

B. Respondent Chad Henderson is 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) for a period of three years after the date of entry of this Order, 

and all registered entities shall refuse him trading privileges during that period. 

C. Respondents shall pay, jointly and severally, restitution, in the amount of four hundred and 

sixty three thousand four hundred and fifty nine dollars and sixty three cents ($463,459.65) 

(“Restitution Obligation” within ten days of the date of the entry of this Order; provided, 

however, that the restitution will be offset by the amount of any restitution payment made 

pursuant to the CME Notice. If the Restitution Obligation is not paid in full within ten days 

of the date of entry of the Order, then post-judgment interest shall accrue on any unpaid 

portion of the required restitution beginning on the date of entry of the Order and shall be 

determined by using the Treasury Bill rate prevailing on the date of entry of the Order 

pursuant to 28 U.S.C. § 1961. 

Respondent shall offer proof of any payment pursuant to the CME Notice, including the 

amount by which the Restitution Obligation is to be reduced, within ten days of making 

such payment to: 

Paul Hayeck 

Deputy Director, Division of Enforcement 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

D. Orders that Respondent Chad Henderson shall pay a civil monetary penalty in the amount of 

three-hundred thousand dollars ($300,000) (“Henderson CMP Obligation”) and that 

Respondent Prime Agricultural Investors shall pay a civil monetary penalty in the amount of 

one-hundred thousand dollars ($100,000) (“Prime Agricultural Investors CMP Obligation”) 

(collectively, “CMP Obligations”). Prime Agricultural Investors shall be jointly and 

severally liable for the Henderson CMP Obligation. The CMP Obligations should be paid 

within ten business days of the date of the entry of this Order; provided, however, that the 

CMP Obligations will be offset by the amount of any fine made pursuant to the CME 

Notice. If the CMP Obligations are not paid in full within ten days of the date of entry of 

the Order, then post-judgment interest shall accrue on any unpaid portion of the CMP 

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

Treasury Bill rate prevailing on the date of entry of the Order pursuant to 28 U.S.C. § 1961. 

Respondents shall pay their respective CMP Obligations, and any post-judgment interest, by 
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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, 

Respondent shall make the payment payable to the Commodity Futures Trading 

Commission, and sent to the address below: 

MMAC/ESC/AMK326 

Commodity Futures Trading Commission 

Division of Enforcement 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amz-ar-cftc@faa.gov

If payment is to be made by electronic transfer, Respondents shall contact Tonia King 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 Respondent and the name and docket number of this proceeding. 

Respondents 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. 

E. 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, 

assigns, agents or employees under its 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 (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 its agents and/or employees under 

its authority or control understand and comply with this agreement. 

2. Respondent Chad Henderson agrees that he shall never, directly or indirectly: 

a. Control or direct the trading for himself, or on behalf of any other person or 

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

commodity interests; 

b. Receive, or accept any funds from any person for the purpose of purchasing 

or selling any commodity interests. 

3. Respondent Chad Henderson agrees that he shall not, for a period of three years from 

the date of entry of this order, 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 (2021)) for his own personal 

accounts or for any accounts in which he has a direct or indirect interest; 

b. have any commodity interests traded on his behalf; 

c. 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). 

4. Respondent Prime Agricultural Investors agrees to implement procedures and 

internal controls designed to prevent the improper allocation of trades. 

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

Commission of any partial payment of Respondents' CMP Obligations shall not be 

deemed a waiver of its 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 CMP 

Obligations as set forth in this Order, Respondents shall provide written notice to the 

Commission by certified mail of any change to its telephone number and mailing 

address within ten calendar days of the change. 

7. Notices to Creditors: Until such time as Respondents satisfy in full their CMP 

Obligations, 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 

Office of the General Counsel 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, DC 20581 

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

B~3I:~ 

Christopher J. K1rkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: October 20, 2022 

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