SEC v. Rabindranauth Persaud, No. 1:25-mc-00312, Southern District of New York (July 29, 2025)

Sheldon L. Pollock
Gerald A. Gross
Todd D. Brody
Sheldon Mui
Attorneys for Applicant
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl St., Suite 20-100
New York, New York 10004
(212) 336-00080 (Brody)
E-mail: [email protected]

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------------------------x
SECURITIES AND EXCHANGE COMMISSION,   :
              :
    Applicant,         :   25-MISC-312
- against -            :
              :  ECF CASE
RABINDRANAUTH PERSAUD                   :
              :
    Respondent.           :
--------------------------------------------------------------------x

SECURITIES AND EXCHANGE COMMISSION’S
APPLICATION FOR AN ORDER TO SHOW CAUSE AND
FOR AN ORDER REQUIRING COMPLIANCE WITH SUBPOENAS

The Securities and Exchange Commission (“Commission”), by its undersigned counsel,
respectfully submits this Application for an Order to Show Cause and for an Order Requiring
Compliance with Subpoenas (“Application”), together with a proposed order to show cause, the
supporting memorandum of law, and the Declaration of Sheldon Mui dated July 24, 2025 and the
exhibits thereto based on the following:
1. Respondent Rabindranauth Persaud (“Persaud”) has refused to comply with
Commission investigative subpoenas that lawfully were issued in the Commission’s investigation
titled RRTP Consulting Services, LLC (Internal File No. NY-10882) (the “RRTP Investigation”).
2. On September 18, 2024, the Commission issued an Order Directing Private
Investigation and Designating Officers to Take Testimony (the “Formal Order”) in the RRTP

2

Investigation under Section 20 of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77t] and
Section 21(a) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78u(a)].
3. Pursuant to the Formal Order, the Commission is investigating, among other things,
whether RRTP, its officers, directors, employees, partners, subsidiaries and/or affiliates, and/or
other persons violated the anti-fraud provisions of the Securities Act and the Exchange Act by
making false statements of material fact and omitting to disclose material facts concerning, among
other things, undisclosed trading of securities using investor funds.
4. The Formal Order designates certain individuals as officers of the Commission
empowered to subpoena witnesses, to take evidence, and to require the production of any records
deemed relevant or material to the investigation, under Section 19(c) of the Securities Act [15 U.S.C.
§ 77s(c)] and Section 21(b) of the Exchange Act [15 U.S.C. § 78u(b)].
5. In an informal telephonic interview with the Commission staff on August 8, 2024,
Persaud stated that he was the owner of RRTP.  Persaud is the listed registered agent for RRTP.
The listed address for RRTP is also Persaud’s home address.
6. On October 2, 2024, one of the designated Commission officers issued an
investigative subpoena to Persaud to produce documents in the RRTP Investigation (“the
Document Subpoena”).  The Commission served the Document Subpoena on Persaud by United
Postal Service overnight delivery at his home address.  The Commission also sent the Document
Subpoena to Persaud by email.
7. The Document Subpoena required Persaud to produce documents, including: ( 1) a
list of all companies Persaud owns and controls; (2) all invoices Persaud issued for any services he
provided; (3) identities and contact information for all individuals and entities Persaud provided any
services to; (4) documents concerning the nature of any services Persaud provided; (5) Persaud’s
bank and brokerage account statements; (6) all agreements between Persaud and all individuals and

3

entities concerning the trading of securities; and (7) all of Persaud’s email addresses and telephone
numbers.
8. The Document Subpoena required Persaud to produce all responsive documents by
October 17, 2024.
9. On November 1, 2024, Persaud filed a pro se motion to quash the Document
Subpoena as well as two other investigative subpoenas that were issued to T.D. Bank, N.A. and J. P.
Morgan Chase Bank, N.A.  Persaud v. Securities and Exchange Commission, 24-MC-505 (S.D.N.Y.).
10. On November 20, 2024, Persaud told the Commission officer who had issued the
subpoena that he would not be producing any documents.
11. On March 17, 2025, the court denied Persaud’s motion to quash.  With respect to
the Document Subpoena, the court held that it lacked subject matter jurisdiction over Persaud’s
motion to quash the Document Subpoena.
12. On May 14, 2025, one of the designated Commission officers issued an investigative
subpoena to Persaud to appear for sworn testimony in the RRTP Investigation on June 13, 2025
(the “Testimony Subpoena”).
13. The Commission served the Testimony Subpoena on Persaud by United Postal
Service overnight delivery at his home address.  The Commission also sent the Testimony Subpoena
to Persaud by electronic mail.
14. On May 14, 2025, Persaud emailed the Commission officer that he was out of the
country and could not appear for testimony on June 13, 2025.  The Commission officer responded
by email, requesting that Persaud provide alternative dates for testimony.
15. On May 22 and May 27, 2025, the Commission officer sent emails to Persaud
regarding the Document and Testimony Subpoenas.  On May 27, 2025, Persaud responded by email
that he “won’t be coming in for a verbal interview.”

4

16. Persaud has not provided any documents in response to the Document Subpoena
and has not appeared for testimony.
14. The Commission therefore submits this Application for an Order to Show Cause, in
the form attached, requiring Persaud to show cause why he should not be ordered to comply with
the Document Subpoena by producing all responsive documents to the Commission at its New
York Regional Office, 100 Pearl St., Suite 20-100, New York 10004 and by appearing for sworn
testimony.
15. The Commission further requests that, after a hearing, the Court enter an Order
requiring Persaud to comply with the Document Subpoena within twenty (20) days and to appear
for testimony pursuant to the Testimony Subpoena within thirty (30) days therefrom.
16. The Court has jurisdiction over this matter and venue properly lies within the
Southern District of New York, pursuant to Section 22(b) of the Securities Act [15 U.S.C. § 77v(b)]
and Section 21(c) of the Exchange Act [15 U.S.C. § 78u(c)].
WHEREFORE, the Commission respectfully requests:
I.
That the Court enter an Order to Show Cause, directing Persaud to show cause why this
Court should not enter an Order requiring him to produce all documents responsive to the
subpoena that was issued to him and to appear for testimony.
II.
That the Court enter an Order requiring Persaud to comply fully with the Document
Subpoena and produce responsive documents within twenty (20) days.
III.
That the Court enter an Order requiring Persaud to appear for testimony within thirty (30)
days of producing responsive documents to the Document Subpoena.

5

IV.

That the Court order such other and further relief as may be necessary and appropriate to
achieve compliance with the subpoena within the time period set forth in the proposed Order to
Show Cause.

Dated:  July 24, 2025
  New York, New York

    SECURITIES AND EXCHANGE COMMISSION

    By:    /s/ Todd D. Brody
     Todd D. Brody
     Sheldon L. Pollock
     Gerald A. Gross
     Sheldon Mui
     Attorneys for Applicant
     SECURITIES AND EXCHANGE COMMISSION
     New York Regional Office
     100 Pearl St., Suite 20-100
     New York, New York 10004
     (212) 336-00080 (Brody)
     E-mail: [email protected]

Sheldon L. Pollock 
Gerald A. Gross 
Todd D. Brody 
Sheldon Mui 
Attorneys for Applicant  
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl St., Suite 20-100 
New York, New York 10004 
(212) 336-00080 (Brody)  
E-mail: [email protected] 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
--------------------------------------------------------------------x 
SECURITIES AND EXCHANGE COMMISSION,   : 
              : 
    Applicant,         :  25-MISC-312 

- against -            :   
              :  ECF CASE 
RABINDRANAUTH PERSAUD                 :   
              : 
    Respondent.         : 
--------------------------------------------------------------------x 
 

SECURITIES AND EXCHANGE COMMISSION’S 
APPLICATION FOR AN ORDER TO SHOW CAUSE AND 

FOR AN ORDER REQUIRING COMPLIANCE WITH SUBPOENAS 
 

The Securities and Exchange Commission (“Commission”), by its undersigned counsel, 

respectfully submits this Application for an Order to Show Cause and for an Order Requiring 

Compliance with Subpoenas (“Application”), together with a proposed order to show cause, the 

supporting memorandum of law, and the Declaration of Sheldon Mui dated July 24, 2025 and the 

exhibits thereto based on the following: 

1. Respondent Rabindranauth Persaud (“Persaud”) has refused to comply with 

Commission investigative subpoenas that lawfully were issued in the Commission’s investigation 

titled RRTP Consulting Services, LLC (Internal File No. NY-10882) (the “RRTP Investigation”). 

2. On September 18, 2024, the Commission issued an Order Directing Private 

Investigation and Designating Officers to Take Testimony (the “Formal Order”) in the RRTP 

Case 1:25-mc-00312     Document 1     Filed 07/24/25     Page 1 of 5

mailto:[email protected]


2 
 

Investigation under Section 20 of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77t] and 

Section 21(a) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78u(a)].   

3. Pursuant to the Formal Order, the Commission is investigating, among other things, 

whether RRTP, its officers, directors, employees, partners, subsidiaries and/or affiliates, and/or 

other persons violated the anti-fraud provisions of the Securities Act and the Exchange Act by 

making false statements of material fact and omitting to disclose material facts concerning, among 

other things, undisclosed trading of securities using investor funds.  

4. The Formal Order designates certain individuals as officers of the Commission 

empowered to subpoena witnesses, to take evidence, and to require the production of any records 

deemed relevant or material to the investigation, under Section 19(c) of the Securities Act [15 U.S.C. 

§ 77s(c)] and Section 21(b) of the Exchange Act [15 U.S.C. § 78u(b)]. 

5. In an informal telephonic interview with the Commission staff on August 8, 2024, 

Persaud stated that he was the owner of RRTP.  Persaud is the listed registered agent for RRTP.  

The listed address for RRTP is also Persaud’s home address. 

6. On October 2, 2024, one of the designated Commission officers issued an 

investigative subpoena to Persaud to produce documents in the RRTP Investigation (“the 

Document Subpoena”).  The Commission served the Document Subpoena on Persaud by United 

Postal Service overnight delivery at his home address.  The Commission also sent the Document 

Subpoena to Persaud by email.   

7. The Document Subpoena required Persaud to produce documents, including: (1) a 

list of all companies Persaud owns and controls; (2) all invoices Persaud issued for any services he 

provided; (3) identities and contact information for all individuals and entities Persaud provided any 

services to; (4) documents concerning the nature of any services Persaud provided; (5) Persaud’s 

bank and brokerage account statements; (6) all agreements between Persaud and all individuals and 

Case 1:25-mc-00312     Document 1     Filed 07/24/25     Page 2 of 5



3 
 

entities concerning the trading of securities; and (7) all of Persaud’s email addresses and telephone 

numbers. 

8. The Document Subpoena required Persaud to produce all responsive documents by 

October 17, 2024. 

9. On November 1, 2024, Persaud filed a pro se motion to quash the Document 

Subpoena as well as two other investigative subpoenas that were issued to T.D. Bank, N.A. and J. P. 

Morgan Chase Bank, N.A.  Persaud v. Securities and Exchange Commission, 24-MC-505 (S.D.N.Y.).   

10. On November 20, 2024, Persaud told the Commission officer who had issued the 

subpoena that he would not be producing any documents. 

11. On March 17, 2025, the court denied Persaud’s motion to quash.  With respect to 

the Document Subpoena, the court held that it lacked subject matter jurisdiction over Persaud’s 

motion to quash the Document Subpoena. 

12. On May 14, 2025, one of the designated Commission officers issued an investigative 

subpoena to Persaud to appear for sworn testimony in the RRTP Investigation on June 13, 2025 

(the “Testimony Subpoena”).   

13. The Commission served the Testimony Subpoena on Persaud by United Postal 

Service overnight delivery at his home address.  The Commission also sent the Testimony Subpoena 

to Persaud by electronic mail.   

14. On May 14, 2025, Persaud emailed the Commission officer that he was out of the 

country and could not appear for testimony on June 13, 2025.  The Commission officer responded 

by email, requesting that Persaud provide alternative dates for testimony. 

15. On May 22 and May 27, 2025, the Commission officer sent emails to Persaud 

regarding the Document and Testimony Subpoenas.  On May 27, 2025, Persaud responded by email 

that he “won’t be coming in for a verbal interview.” 

Case 1:25-mc-00312     Document 1     Filed 07/24/25     Page 3 of 5



4 
 

16. Persaud has not provided any documents in response to the Document Subpoena 

and has not appeared for testimony. 

14. The Commission therefore submits this Application for an Order to Show Cause, in 

the form attached, requiring Persaud to show cause why he should not be ordered to comply with 

the Document Subpoena by producing all responsive documents to the Commission at its New 

York Regional Office, 100 Pearl St., Suite 20-100, New York 10004 and by appearing for sworn 

testimony.   

15. The Commission further requests that, after a hearing, the Court enter an Order 

requiring Persaud to comply with the Document Subpoena within twenty (20) days and to appear 

for testimony pursuant to the Testimony Subpoena within thirty (30) days therefrom. 

16. The Court has jurisdiction over this matter and venue properly lies within the 

Southern District of New York, pursuant to Section 22(b) of the Securities Act [15 U.S.C. § 77v(b)] 

and Section 21(c) of the Exchange Act [15 U.S.C. § 78u(c)].   

WHEREFORE, the Commission respectfully requests: 

I. 

That the Court enter an Order to Show Cause, directing Persaud to show cause why this 

Court should not enter an Order requiring him to produce all documents responsive to the 

subpoena that was issued to him and to appear for testimony. 

II. 

That the Court enter an Order requiring Persaud to comply fully with the Document 

Subpoena and produce responsive documents within twenty (20) days. 

III. 

That the Court enter an Order requiring Persaud to appear for testimony within thirty (30) 

days of producing responsive documents to the Document Subpoena. 

Case 1:25-mc-00312     Document 1     Filed 07/24/25     Page 4 of 5



5 
 

IV. 
 

That the Court order such other and further relief as may be necessary and appropriate to 

achieve compliance with the subpoena within the time period set forth in the proposed Order to 

Show Cause. 

 
Dated: July 24, 2025 
  New York, New York 
 

    SECURITIES AND EXCHANGE COMMISSION   
    
 
    By:    /s/ Todd D. Brody   
     Todd D. Brody 
     Sheldon L. Pollock 
     Gerald A. Gross 
     Sheldon Mui  
     Attorneys for Applicant  
     SECURITIES AND EXCHANGE COMMISSION 
     New York Regional Office 
     100 Pearl St., Suite 20-100 
     New York, New York 10004 
     (212) 336-00080 (Brody)  
     E-mail: [email protected] 

Case 1:25-mc-00312     Document 1     Filed 07/24/25     Page 5 of 5

mailto:[email protected]

	RABINDRANAUTH PERSAUD                 :