SEC v. Cast Your Nets Ministries, CYNM Consulting, LLC, Phillip Trujillo, et al. — U.S. Securities and Exchange Commission Litigation Release No. 26195, dated December 16, 2024.
The SEC has filed a subpoena enforcement action against Cast Your Nets Ministries, its subsidiary CYNM Consulting, LLC, and two individuals, Phillip Trujillo and Jeremy Hammonds. The SEC is investigating whether these entities and individuals engaged in a fraudulent and unregistered securities offering, and they are seeking court orders to compel compliance with previously issued subpoenas for documents and testimony.
In Plain English
Imagine you're asked to share some important papers and answer questions about a new club you started. If you refuse, the authorities might ask a judge to force you to cooperate. That's what's happening here: the SEC asked for information about a new investment program, but the people involved haven't fully complied, so the SEC is asking a judge to make them.
Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.
How the Alleged Scheme Worked
- Establish Entities and Offerings Cast Your Nets Ministries, a Washington state non-profit, and its subsidiary CYNM Consulting, LLC, a Delaware LLC, offered investment programs and a crypto asset on their website. These included the 'CYN Legacy Program' for fundraising, the 'CYN Alternative Savings Plan' promising '2% per month' (12% total over 6 months), the 'Alternative Retirement Program' advertising '15% Yearly Returns' or 'a 25% return each year for three years,' and a 'CYN Token' promising to '[d]ouble Your Retirement Savings In Just 5 Years.'
- Initiate SEC Investigation The SEC initiated a formal investigation into whether Cast Your Nets Ministries, CYNM Consulting, Phillip Trujillo (a board member with a prior fraud conviction), and Jeremy Hammonds (COO) were conducting a fraudulent and unregistered securities offering. A Formal Order was issued on April 11, 2024, and later corrected.
- Issue Subpoenas for Information As part of the investigation, the SEC issued administrative subpoenas. On May 20, 2024, a document subpoena was served on CYNM Consulting. On August 6, 2024, a document subpoena was served on Cast Your Nets Ministries. On September 30, 2024, subpoenas for documents and testimony were issued to Phillip Trujillo, and a subpoena for testimony was issued to Jeremy Hammonds.
- Respond with Minimal Compliance Despite repeated attempts to secure compliance, the respondents have largely refused to cooperate. Cast Your Nets Ministries, CYNM Consulting, and Mr. Trujillo produced only ten documents and failed to provide all responsive materials. Neither Mr. Trujillo nor Dr. Hammonds appeared for their scheduled testimony.
- Declare Intent to Defy Subpoenas Counsel for the respondents informed the SEC staff that the respondents would not comply with the subpoenas, would not produce additional documents, and would not appear for testimony. Counsel acknowledged that the respondents were aware the SEC reserved its authority to pursue enforcement in federal court.
- File Subpoena Enforcement Action As a result of the non-compliance, the SEC filed an application in the U.S. District Court for the District of Colorado on December 12, 2024, seeking an order to show cause why the respondents should not be compelled to comply with the administrative subpoenas.
The Enforcement Action
The SEC filed a subpoena enforcement action against Cast Your Nets Ministries, CYNM Consulting, LLC, Phillip Trujillo, and Jeremy Hammonds. The SEC is investigating potential fraudulent and unregistered securities offerings by these parties. The action seeks a court order compelling the respondents to comply with administrative subpoenas for documents and testimony, which they have largely refused to do.
Named in this action: Cast Your Nets Ministries, CYNM Consulting, LLC, Phillip Trujillo, Jeremy Hammonds.