On June 6, the U.S. Commodity Futures Trading Commission (CFTC) filed a civil enforcement action in the U.S. District Court for the Western District of Tennessee against Three Bridges Trading Fund, LLC and its owner, president, and manager, Donald Wray Rodgers.

Three Bridges Trading Fund, LLC is a Tennessee-based company, and Rodgers is from Collierville, Tennessee.

The complaint alleges that the defendants fraudulently solicited and accepted at least $2 million from pool participants for investment in a commodity pool. The defendants misappropriated most of the funds and concealed their fraud by providing false account and trading statements to pool participants, while operating a Ponzi scheme by using some participants' funds to pay other participants.

The complaint states that from January 2022 to November 2022, Rodgers deceived clients by claiming that Three Bridges was a successful commodity pool and making false representations about its trading history. According to the defendants' records, they solicited and accepted at least $2 million from approximately 50 pool participants for trading futures contracts on their behalf.

Additionally, the complaint charges that the defendants commingled pool funds with non-pool assets and directed pool participants to send funds to Rodgers' personal account. Bank records show that Rodgers transferred funds, including pool funds, from Three Bridges' bank account to his personal trading account and traded in his own name. Moreover, Rodgers failed to receive all pool participants' funds in the name of Three Bridges and failed to operate Three Bridges as a separate legal entity.

The complaint also alleges that when trading profits did not materialize, the defendants attempted to cover up their fraud by providing false account documents to pool participants, including creating fake account statements and trade confirmations to falsely explain that Three Bridges had lost participants' funds.

Further allegations state that Three Bridges and Rodgers operated as a commodity pool operator (CPO) by soliciting, accepting, and receiving funds for commodity futures trading, but Three Bridges did not register as a CPO with the CFTC as required. Additionally, Rodgers acted as an associated person (AP) of the CPO without registering with the CFTC as an AP.

In its ongoing litigation against the defendants, the CFTC seeks restitution of ill-gotten gains, civil monetary penalties, disgorgement, trading and registration bans, and permanent injunctions against further violations of the Commodity Exchange Act (CEA) and CFTC regulations.