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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States Commodity Futures Trading 

Commission,

Plaintiff,

v. 

Purvesh Mankad, et al.,

Defendants.

No. CV-21-01719-PHX-DJH

CONSENT ORDER 

Pending before the Court is Plaintiff Commodity Futures Trading Commission’s 

(“Commission”) Motion for Entry of Consent Order for Permanent Injunction, Civil 

Monetary Penalties, and Other Equitable Relief Against Defendants Purvesh Mankad, 

CTAX Partners, LLC, and CTAX Series, LLC (“Consent Order”). (Doc. 31). In support

of its Motion, the Commission makes the following representations:

1. The Commission has conferred with each Defendant, each of whom agrees to the 

filing of this motion.

2. The Commission and each Defendant have signed the proposed Consent Order.

3. On October 8, 2021, the Commission filed a Complaint for Injunctive Relief, Civil 

Monetary Penalties, Restitution, Disgorgement, and Other Equitable Relief against 

Defendants alleging violations of certain provisions of the Commodity Exchange 

Act, 7 U.S.C. §§ 1 et seq.

4. The proposed Consent Order, if approved by the Court, resolves all aspects of the 

Commission’s case against all Defendants.

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(Id. at 1–2). 

Finding good cause, the Court will adopt the parties’ proposed Consent Order. 

(Doc. 31-1). 

I. INTRODUCTION

On October 8, 2021, the Commission filed a Complaint for Injunctive Relief, Civil 

Monetary Penalties, Restitution, Disgorgement, and Other Equitable Relief against 

Defendants Purvesh Mankad (“Mankad”), CTAX Partners, LLC (“CTAX Partners”), and 

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

together with CTAX Partners and Mankad, “Defendants”) (collectively with the 

Commission, the “Parties”) alleging violations of certain provisions of the Commodity 

Exchange Act, 7 U.S.C. §§ 1-26 (the “Act”). 

II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against Defendants 

without a trial on the merits or any further judicial proceedings, Defendants:

1. Consent to the entry of this Consent Order for Permanent Injunction, Civil 

Monetary Penalties, and Other Equitable Relief Against Defendants (“Consent Order”);

2. Affirm that they have read and agreed to this Consent Order voluntarily, and 

that no promise, other than as specifically contained herein, or threat, has been made by 

the Commission or any member, officer, agent, or representative thereof, or by any other 

person, to induce consent to this Consent Order;

3. Acknowledge service of the summons and Complaint;

4. Admit the jurisdiction of this Court over it and the subject matter of this 

action pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1;

5. Admit the jurisdiction of the Commission over the conduct and transactions 

at issue in this action pursuant to the Act;

6. Admit that venue properly lies with this Court pursuant to 7 U.S.C. § 13a1(e);

7. Waive:

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a. 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 Commission’s 

Regulations (“Regulations”), 17 C.F.R. pt. 148 (2021), relating to, or arising 

from, this action;

b. Any and all claims that they 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 action;

c. Any claim of Double Jeopardy based upon the institution of this action or the 

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

other relief, including this Consent Order; and

d. Any and all rights of appeal from this action;

8. Consent to the continued jurisdiction of this Court over them for the purpose 

of implementing and enforcing the terms and conditions of this Consent Order and for any 

other purpose relevant to this action, even if any Defendant now or in the future resides 

outside the jurisdiction of this Court;

9. Agree that they will not oppose enforcement of this Consent Order on the 

ground, if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil 

Procedure and hereby waive any objection based thereon;

10. Agree that neither they nor any of their agents or employees under their 

authority or control shall take any action or make any public statement denying, directly or 

indirectly, any allegation in the Complaint or the Findings of Fact or Conclusions of Law 

in this Consent Order, or creating or tending to create the impression that the Complaint 

and/or this Consent Order is without a factual basis; provided, however, that nothing in this 

provision shall affect its: (a) testimonial obligations, or (b) right to take legal positions in 

other proceedings to which the Commission is not a party. Defendants shall comply with 

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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;

11. Consent to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except 

as to jurisdiction and venue, which they admit;

12. Consent to the use of the findings and conclusions in this Consent 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; 

13. Do not consent, however, to the use of this Consent Order, or the findings 

and conclusions herein, as the sole basis for any other proceeding brought by the 

Commission or to which the Commission is a party, other than a statutory disqualification 

proceeding; proceeding in bankruptcy or receivership; or proceeding to enforce the terms 

of this Order;

14. Agree to provide immediate notice to this Court and the Commission by 

certified mail, in the manner required by paragraph 89 of Part VI of this Consent Order, of 

any bankruptcy proceeding filed by, on behalf of, or against them, whether inside or outside 

the United States; and

15. Agree that no provision of this Consent Order shall in any way limit or impair 

the ability of any other person or entity to seek any legal or equitable remedy against 

Defendants in any other proceeding.

III. FINDINGS OF FACT AND CONCLUSIONS OF LAW

16. The Court, being fully advised in the premises, finds that there is good cause 

for the entry of this Consent Order and that there is no just reason for delay. The Court 

therefore directs the entry of the following Findings of Fact, Conclusions of Law, 

permanent injunction and equitable relief pursuant to Section 6c of the Act, 7 U.S.C. § 13a1, as set forth herein.

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 THE PARTIES AGREE AND THE COURT HEREBY FINDS:

A. Findings of Fact

1. The Parties to this Consent Order

17. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency that is charged by Congress with administering and enforcing 

the Act and the Regulations.

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

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

CTAX Series.

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

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

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

obligations pursuant to Regulation 4.7, 17 C.F.R. § 4.7 (2021).

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

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

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

Pool.

2. Summary of Findings of Fact 

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

Period”), Mankad and two entities Mankad controlled—CTAX Partners and CTAX 

Series—directly and/or through others, fraudulently solicited funds for, misappropriated 

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

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

3. Mankad Established CTAX and Partnered with an SEC-Registered 

Investment Advisor To Solicit Pool Participants for the CTAX Pool.

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

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

customers to those pools.

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

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

record of performance.

24. Separately during this period, Mankad established Investor Services 

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

opening their own advisory firms.

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

business ventures with Paul Ohanian (“Ohanian”), an SEC-registered investment adviser 

with an established client base, and Scottsdale Wealth Planning, Inc. (“Scottsdale 

Wealth”), Ohanian’s advisory firm. First, Investor Services agreed to provide Scottsdale 

Wealth $30,000 in start-up capital and administrative services in exchange for 30% of 

Scottsdale Wealth’s management fees.

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

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

investment in the CTAX Pool from his clients. In exchange, CTAX would pay Ohanian 2 

percent of the value of Ohanian’s client holdings in the CTAX Pool, as well as 0.5 percent 

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

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

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

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

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

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

clients (at least 12 of whom reside in Arizona) of Ohanian contributed a total of 

approximately $2.15 million.1 One other pool participant—a personal friend of 

Mankad’s—contributed $250,000. 

/ / /

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

their contributions in 2015 and 2016.

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4. Mankad and CTAX Series Represented That Only CTAs Would Trade 

CTAX Pool Funds and Failed To Disclose Mankad’s Unauthorized 

Trading.

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

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

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

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

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

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

disclosure requirements. 

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

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

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

accounts, and was unsuccessful.

31. Mankad’s purported objective in soliciting prospective pool participants was 

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

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

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

Memorandum communicated to pool participants was that CTAX Series, through Mankad, 

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

significant absolute investment returns over the short and long-term” by trading futures. 

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

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

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

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

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

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

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

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CTAX Memorandum made repeated references throughout that CTAX Pool funds would 

be traded by professionals who were experienced, sophisticated, and talented enough to 

achieve the significant returns referenced in the CTAX Memorandum. For example, the 

CTAX Memorandum represented that only a “select group of investment managers” would 

engage in such trading. Nowhere did the CTAX Memorandum state that any non-CTA—

much less Mankad himself, who was an inexperienced and unsuccessful futures trader—

would trade pool funds. The CTAX Memorandum also stated that Mankad was 

accountable to pool participants as a “fiduciary” and was required to exercise “the utmost 

good faith” in all activities relating to the CTAX Pool. Taken together, based on these 

representations, no reasonable pool participant would have expected Mankad himself to 

trade any—much less all—CTAX Pool funds.

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

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

traded CTAX Pool funds. For example, Mankad traded funds totaling approximately 23% 

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

Pool by August 2018. The unauthorized trading by Mankad involved futures in 10-year 

Treasury notes, silver, and mini silver, among other futures contracts.

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

authorize and disclose Mankad’s trading.

5. Mankad’s Trading Resulted in Losses of Almost All of Pool Participants’ 

Contributions.

36. Ohanian repeatedly communicated to Mankad that Mankad was trading 

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

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

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

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

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

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

previous trading strategy.

38. From July through December 2018, due to Mankad’s trading, the CTAX Pool 

lost approximately 89% of its value. Approximately all such losses occurred in accounts 

traded by Mankad, who was the only person trading in the CTAX Pool by August 2018.

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

from Pool Participants.

39. The CTAX Memorandum represented that each pool participant would 

“receive[] a monthly . . . account statement” from CTAX’s third-party compliance advisor 

(“Compliance Advisor”).

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

relevant account information to the Compliance Advisor each month, who prepared 

account statements and sent them to pool participants—each time within approximately 

one month of the conclusion of the trading reflected in the account statements. For 

example, March 2018 CTAX Pool account statements were provided to pool participants 

on May 1, 2018; and April 2018 account statements were provided on May 29, 2018.

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

trading was causing significant losses—Mankad intentionally withheld information that 

Compliance Advisor needed to prepare and send pool participants monthly account 

statements.

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

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

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

due to his embarrassment regarding the losses and desire to give himself time to make the 

money back.

43. Because Mankad intentionally withheld this information, pool participants 

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

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

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

that they would provide accurate monthly account statements.

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

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

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

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

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

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

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

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

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

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

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

reasonably and actually relied on the misrepresentations and material omissions described 

herein. 

7. Mankad and CTAX Partners Misappropriated CTAX Pool Funds 

Through Extraction of Excessive Commissions, and Mankad and CTAX 

Series Misrepresented That Mankad Would Exercise Good Faith with 

Respect to the CTAX Pool and Failed to Disclose the Misappropriation.

47. The CTAX Memorandum expressly noted Mankad’s fiduciary duties to the 

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

consequently must exercise the utmost good faith and integrity in handling the [CTAX 

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

to by pool participants. 

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

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

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

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

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

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

Although the CTAX Memorandum disclosed that pool participants would ultimately pay 

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

CTAX Partners would charge disproportionately higher commissions on the trades 

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

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

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

investment in the CTAX Pool.2 

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

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

Mankad were inconsistent with the express representation in the CTAX Memorandum that 

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

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

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

account traded by Mankad compared to those traded by third-party CTAs. These 

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

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

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

agreed to by pool participants, in the CTAX Memorandum.

50. Compliance Advisor recognized these issues and communicated them to 

Mankad, but Mankad ignored him. On approximately July 9, 2016, Compliance Advisor 

discovered the disparity and asked Mankad, “why as the fiduciary to the pool is this account 

charged above industry normal commission rates? I don’t see this in the retail sector 

anymore and neither does NFA [i.e., the National Futures Association].” Compliance 

2 During the Relevant Period, CTAX Partners, at Mankad’s direction, withdrew from 

the CTAX Pool $401,724.22 in brokerage commissions for sub-accounts Mankad traded. 

During the Relevant Period, CTAX Partners paid $327,189.55, and CTAX Series paid 

$157,869.72, to personal bank accounts owned or controlled by Mankad.

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Advisor communicated to Mankad that the NFA might discover the significant difference 

and might allege rules violations. 

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

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

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

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

funds through charging and receipt of excessive and unauthorized commissions.

8. Mankad and CTAX Series Falsified Documents To Conceal Their 

Misconduct from the NFA.

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

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

documents and information.

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

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

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

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

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

did so to mislead the NFA regarding the date the email was sent—specifically, to make it 

appear that the pool participant received the account statement sooner than he did.

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

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

personal friend—the April 2018 CTAX account statement (purported email dated May 29, 

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

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

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

August-December 2018 CTAX account statements (purported email dated February 25, 

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

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

statements had been provided to this pool participant.

55. In testimony before the Division, Mankad admitted to intentionally falsifying 

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

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

statements at all.

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

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

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

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

B. Conclusions of Law

1. Jurisdiction and Venue

57. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. 

§ 1331 (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (providing that U.S. 

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 

Act, 7 U.S.C. § 13a-1(a), provides that the Commission may bring actions for injunctive 

relief or to enforce compliance with the Act or any rule, regulation, or order thereunder in 

the proper district court of the United States whenever it shall appear to the Commission 

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

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

thereunder.

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

Defendants transacted business in this District and acts and practices in violation of the Act 

occurred within this District.

2. Fraud by Misrepresentations, Omissions, and Misappropriation in 

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

(C) 

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59. 7 U.S.C. § 6b(a)(1)(A) and (C) makes it unlawful:

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

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

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

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

for or on behalf of any other person . . .

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

other person . . . [or]

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

person by any means whatsoever in regard to any order or 

contract or the disposition or execution of any order or 

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

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

.

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

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

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

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

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

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

pool participants; and (2) deceived or attempted to deceive pool participants by any means. 

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

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

7 U.S.C. § 6b(a)(1)(A) and (C). 

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

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

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

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

pursuant to Section 2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B), and Regulation 1.2, 

17 C.F.R. § 1.2 (2021).

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

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

Partners’ and CTAX Series’ conduct alleged in this Count. Therefore, under Section 13(b) 

of the Act, 7 U.S.C. § 13c(b), Mankad is liable for CTAX Partners’ and CTAX Series’ 

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

3. Fraud and Deceit by CPOs and APs of CPOs in Violation of Section 

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

64. Section 1a(11)(A)(ii) of the Act, 7 U.S.C. § 1a(11)(A)(ii), defines a CPO, in 

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

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

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

66. Regulation 1.3, 17 C.F.R. § 1.3 (2021), defines an AP of a CPO as any natural 

person associated with:

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

(or any natural person occupying a similar status or performing 

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

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

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

engaged[.]

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

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

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

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

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

a CPO. Therefore, Defendant Mankad was an AP of a CPO as defined by 17 C.F.R. § 1.3. 

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68. 7 U.S.C. § 6o(1)(A)-(B) prohibits CPOs and APs of CPOs, by use of the 

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

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

client or participant, or engaging in transactions, practices, or courses of business which 

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

participant.

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

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

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

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

participants; or (2) engaged in transactions, practices, or courses of business which 

operated as a fraud or deceit upon pool participants or prospective pool participants. 

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

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

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

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

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

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

§ 2(a)(1)(B) and 17 C.F.R. § 1.2.

72. Defendant Mankad controls CTAX Series, directly or indirectly, and did not 

act in good faith or knowingly induced, directly or indirectly, CTAX Series’ conduct 

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

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

4. False Statements to the NFA in Violation of Section 9(a)(4) of the Act, 

7 U.S.C. § 13(a)(4)

73. 7 U.S.C. § 13(a)(4) makes it unlawful for: 

Any person willfully to falsify, conceal, or cover up by any 

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

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fictitious, or fraudulent statements or representations, or make 

or use any false writing or document knowing the same to 

contain any false, fictitious, or fraudulent statement or entry 

to a . . . futures association designated or registered under this 

chapter acting in furtherance of its official duties under this 

chapter.

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

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

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

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

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

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

duties in connection with an audit of CTAX Series.

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

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

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

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

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

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

77. Defendant Mankad controls CTAX Series, directly or indirectly, and did not 

act in good faith or knowingly induced, directly or indirectly, CTAX Series’ conduct 

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

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

78. Unless restrained and enjoined by this Court, there is a reasonable likelihood 

that Defendants will continue to engage in the acts and practices alleged in the Complaint 

and in similar acts and practices in violation of the Act and Regulations.

/ / /

/ / /

/ / /

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IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED:

79. Based upon and in connection with the foregoing conduct, pursuant to 

Section 6c of the Act, 7 U.S.C. § 13a-1:

a. Defendants and their affiliates, agents, servants, employees, successors, 

assigns, and attorneys acting on their behalf, and all persons acting in active 

concert with them, are permanently restrained, enjoined and prohibited from 

directly or indirectly engaging in fraud by misrepresentations, omissions, or 

misappropriation in violation of Section 4b(a)(1)(A) and (C) of the Act, 7 

U.S.C. § 6b(a)(1)(A), (C);

b. Mankad and CTAX Series and their affiliates, agents, servants, employees, 

successors, assigns, and attorneys acting on their behalf, and all persons in 

active concert with them, are permanently restrained, enjoined, and 

prohibited from directly or indirectly (i) engaging in fraud or deceit by a CPO 

or an AP of a CPO in violation of Section 4o(1)(A)-(B) of the Act, 7 U.S.C. 

§ 6o(1)(A)-(B); and (ii) making false statements to the NFA in violation of 

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

80. Defendants, including any of their affiliates, agents, servants, employees, 

successors, assigns, and attorneys acting on their behalf, and all persons in active concert 

with them, are permanently restrained, enjoined, and prohibited from directly or indirectly:

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

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

b. 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; 

c. Having any commodity interests traded on any Defendant’s behalf;

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d. 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;

e. Soliciting, receiving, or accepting any funds from any person for the purpose 

of purchasing or selling of any commodity interests;

f. Applying for registration or claiming exemption from registration with the 

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

registration or exemption from registration with the CFTC except as 

provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2021); and

g. Acting as a principal (as that term is defined in 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).

V. RESTITUTION AND CIVIL MONETARY PENALTY

A. Restitution

81. Defendants shall pay, jointly and severally, restitution in the amount of one 

million, six hundred thirty-one thousand and seventy-two dollars and twenty-nine cents 

($1,631,072.29) (“Restitution Obligation”), within ten (10) days of the date of the entry of 

this Order.3 If the Restitution Obligation is not paid in full within ten days of the date of 

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.

82. To effect payment by Defendants and the distribution of restitution to 

Defendants’ customers, the Court appoints NFA as “Monitor.” The Monitor shall receive 

3 The Commission has previously ordered Ohanian and Scottsdale Wealth to pay the 

remaining restitution owed to victims. See In re Ohanian, CFTC No. 22-02, 2021 WL 

4757195, at *6-7 (Oct. 8, 2021) (requiring payment of $338,000 in restitution and a 

$169,000 CMP, among other relief). 

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

Defendants 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.

83. Defendants shall make their payments of the Restitution Obligation and any 

post-judgment interest under this Order in the name of the “CTAX 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 Defendant 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, and 

to Charles Marvine, Deputy Director, Commodity Futures Trading Commission, 2600 

Grand Boulevard, Suite 210, Kansas City, MO 64108. 

84. The Monitor shall oversee Defendants’ Restitution Obligation and shall have 

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

the Defendants’ 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 Defendants’ 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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B. Civil Monetary Penalty

85. Defendants shall pay, jointly and severally, a civil monetary penalty in the 

amount of seven hundred and twenty-seven thousand, five hundred and eighty-eight dollars 

and ninety-one cents (“$727,588.91) (“CMP Obligation”), within thirty days of the date of 

entry of this Consent Order. If the CMP Obligation is not paid in full within thirty days of 

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

CMP Obligation beginning on the date of entry of this Consent Order and shall be 

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

Order pursuant to 28 U.S.C. § 1961.

86. Defendants shall pay their 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:

MMAC/ESC/AMK326

Commodity Futures Trading Commission

6500 S. MacArthur Blvd.

HQ Room 266

Oklahoma City, OK 73169

9-amc-ar-cftc@faa.gov 

87. If payment by electronic funds transfer is chosen, Defendants shall contact 

Tonia King or her successor at the above email address to receive payment instructions and 

shall fully comply with those instructions. Defendants shall accompany payment of the 

CMP Obligation with a cover letter that identifies the paying Defendant(s) and the name 

and docket number of this proceeding. Defendants 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, and to Charles Marvine, Deputy Director, Commodity Futures Trading 

Commission, 2600 Grand Boulevard, Suite 210, Kansas City, MO 64108.

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C. Provisions Related to Monetary Sanctions

88. Partial Satisfaction: Acceptance by the Commission of any partial payment 

of Defendants’ Restitution Obligation or CMP Obligation shall not be deemed a waiver of 

Defendants’ obligation to make further payments pursuant to this Consent Order, or a 

waiver of the Commission’s right to seek to compel payment of any remaining balance.

VI. MISCELLANEOUS PROVISIONS

89. Notice: All notices required to be given by any provision in this Consent 

Order shall be sent certified mail, return receipt requested, as follows:

Notice to Commission: 

Charles D. Marvine

Deputy Director

2600 Grand Boulevard, Suite 210

Kansas City, MO 64108

Notice to Defendants:

Jeffry M. Henderson

Greenberg Traurig, LLP

77 West Wacker Drive, Suite 3100

Chicago, IL 60601

hendersonj@gtlaw.com

All such notices to the Commission shall reference the name and docket number of this 

action.

90. Change of Address/Phone: Until such time as Defendants satisfy in full their 

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

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.

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91. Entire Agreement and Amendments: This Consent Order incorporates all of 

the terms and conditions of the settlement among the parties hereto to date. Nothing shall 

serve to amend or modify this Consent Order in any respect whatsoever, 

unless: (a) reduced to writing; (b) signed by all parties hereto; and (c) approved by order 

of this Court.

92. Invalidation: If any provision of this Consent Order or if the application of 

any provision or circumstance is held invalid, then the remainder of this Consent Order and 

the application of the provision to any other person or circumstance shall not be affected 

by the holding.

93. Waiver: The failure of any party to this Consent Order at any time to require 

performance of any provision of this Consent Order shall in no manner affect the right of 

the party at a later time to enforce the same or any other provision of this Consent Order. 

No waiver in one or more instances of the breach of any provision contained in this Consent 

Order shall be deemed to be or construed as a further or continuing waiver of such breach 

or waiver of the breach of any other provision of this Consent Order.

94. Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of 

this action to ensure compliance with this Consent Order and for all other purposes related 

to this action, including any motion by Defendants to modify or for relief from the terms 

of this Consent Order.

95. Injunctive and Equitable Relief Provisions: The injunctive and equitable 

relief provisions of this Consent Order shall be binding upon Defendants, upon any person 

under their authority or control, and upon any person who receives actual notice of this 

Consent Order, by personal service, e-mail, facsimile or otherwise insofar as he or she is 

acting in active concert or participation with Defendants.

96. Authority: Mankad hereby warrants that he is the Managing Member of 

CTAX Partners and CTAX Series; that this Consent Order has been duly authorized by 

CTAX Partners and CTAX Series; and he has been duly empowered to sign and submit 

this Consent Order on behalf of CTAX Partners and CTAX Series.

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97. Counterparts and Facsimile Execution: This Consent Order may be executed 

in two or more counterparts, all of which shall be considered one and the same agreement 

and shall become effective when one or more counterparts have been signed by each of the 

parties hereto and delivered (by facsimile, e-mail, or otherwise) to the other party, it being 

understood that all parties need not sign the same counterpart. Any counterpart or other 

signature to this Consent Order that is delivered by any means shall be deemed for all 

purposes as constituting good and valid execution and delivery by such party of this 

Consent Order.

98. Contempt: Defendants understand that the terms of the Consent Order are 

enforceable through contempt proceedings, and that in any such proceedings it may not 

challenge the validity of this Consent Order. 

99. Agreements and Undertakings: Defendants shall comply with all of the 

undertakings and agreements set forth in this Consent Order.

100. The Clerk of the Court is hereby ordered to enter this Consent Order for 

Permanent Injunction, Civil Monetary Penalties, and other Equitable Relief Against 

Defendants Purvesh Mankad, CTAX Partners, LLC, and CTAX Series, LLC forthwith and

without further notice. 

101. The Clerk of the Court is further ordered to terminate this action. 

Dated this 18th day of October, 2022.

Honorable Diane J. Humetewa

United States District Judge

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