The Non-Financial Ledger: What a Number Can’t Quantify

Nine people handed over their savings because they trusted someone in their community. That is the detail buried under every dollar figure in this court filing. These were not high-net-worth speculators placing casino bets. They were people in Minnesota and Wisconsin who knew Dendinger personally. He approached them. He called it an opportunity. He promised 6% monthly returns, guaranteed, for fourteen months. Some of them signed promissory notes based on that promise. Others signed Investor Agreements. All of them believed their money was going into an account managed by a professional, someone who had been vetted, someone who knew what he was doing.

He had not been vetted. Rick Miller had never been registered with the CFTC in any capacity. In the fifteen months before Dendinger brought the first round of investor money to him, Miller had turned a profit in exactly three out of nine months he bothered to trade. He showed Dendinger fake trading reports on his phone at an in-person meeting in July 2019. He said he was managing a fund with “millions of dollars” from “multiple individuals.” That was a lie. There was no fund. There were no multiple investors. There was Miller, trading crude oil and S&P 500 futures out of a personal account that was already losing money.

The betrayal compounds the further down the chain you go. When Dendinger collected $250,000 from the second wave of investors in early 2020, he routed it first into a PDM business account, then into his own personal bank account. He wired most of it to Miller. He kept $13,000. That money was never returned. The investors who received any payment at all got partial payments ranging from $500 to $1,500 over several months. Then the payments stopped. When participants asked for their money back, nothing came.

Meanwhile, in May 2020, Miller was emailing Dendinger describing a trading catastrophe. He had lost $128,000 in March alone. Almost half the account in a single month. The investors who handed over their life savings in January and February of that same year had no idea this had already happened when they signed their agreements. Dendinger told them he had watched Miller trade successfully in the live trading room. He repeated Miller’s lies about the fund’s size and performance as if they were facts. None of the nine investors received any disclosure document. Not one of them was warned that futures trading involves substantial risk of total loss. That warning is a legal requirement. These defendants simply chose to skip it.

What stays with you after reading this court document is the specific cruelty of the timeline. The investors from the first round, July 2019, had already been promised 6% per month for twelve months. Before that promise could even be tested, Miller was losing money. By the time the second round of investors came in, the account was already bleeding. By May 2020, it was functionally gone. Dendinger and Miller decided together to keep trading what was left in an attempt to dig out. They didn’t tell the investors. They kept grinding what remained of those nine people’s money into the market until there was nothing left by November 2020. The total loss was $329,666.38.

The court’s order acknowledges that restitution is meant to “restore the status quo.” But no order restores the moment you realized your savings were gone, or the months you spent waiting for partial payments that stopped arriving, or the understanding that someone you trusted sat across from you and lied to your face.

Legal Receipts: What the Documents Actually Say

These are direct quotes from the court’s Findings of Fact and the underlying complaint. No paraphrasing. This is the documented record.

• This establishes that Miller’s recruitment pitch was built on fabricated evidence shown on his phone at a face-to-face meeting, not a misunderstanding or an exaggeration. The reports were false.
• The claim about managing “millions of dollars” from “multiple individuals” was also false. There was no prior investment fund. This was the foundational lie that triggered $400,000 in investor deposits.
• This conduct satisfies the legal standard for fraud under 7 U.S.C. § 6o(1): employing “a device, scheme, or artifice to defraud” a prospective client.

• Miller’s claim that March was “down 12%” directly contradicts the verified Dorman Trading account records, which show net losses of over $128,000 in March 2020. That was nearly 50% of the account balance, not 12%.
• Miller’s claim that April ended at “down 4% overall” also contradicts the records. April trading sustained net losses of over $39,000, approximately 37% of that month’s beginning balance.
• This email proves Miller was still actively deceiving Dendinger even after the account had catastrophically failed. Dendinger then used information from Miller to reassure investors in the second recruitment round.

• This is a private admission that the account was functionally destroyed. The phrase “adding to losing trades” confirms Miller was engaging in high-risk averaging-down behavior with other people’s money.
• Despite this admission, Miller and Dendinger chose to continue trading whatever funds remained. No investors were informed that their money had been almost entirely wiped out. This decision to continue is documented in Findings of Fact ¶36.
• The court record confirms that from June through November 2020, trading “suffered overall losses, depleting the remaining funds from PDM.” The investors found out the money was gone when payments simply stopped.

• The court explicitly rejected any argument that poor trading results are a mitigating factor. The fraud was in the lying, not only in the losing.
• The phrase “those who trusted them with their money” recognizes the personal nature of the harm. These were not anonymous market transactions. Dendinger solicited people he knew personally.
• The court’s language confirms the defendants operated outside every consumer protection mechanism that exists in the commodity futures regulatory structure: no registration, no disclosure documents, no proper record-keeping, no segregation of funds.

The Gap: What Investors Were Told Versus Reality

Dendinger repeated Miller’s claims directly to investors. Here is what the documents show those claims were, and what the verified trading records actually show.

Societal Impact Mapping

Public Health: The Financial Stress Pipeline

Financial fraud at this scale does not end when the money is gone. It initiates a cascade of stress-related harm that public health researchers consistently link to income loss and financial insecurity.

• Nine individuals lost most or all of the funds they contributed. Six of the nine invested between $25,000 and $100,000 based on the $400,000 total and $150,000 first-round figure. Losses of this magnitude among non-wealthy individuals in Minnesota and Wisconsin represent the loss of emergency funds, retirement savings, or working capital that cannot easily be replaced.
• Partial payments to investors ranged from $500 to $1,500 per person over the entire period, totaling just $27,000 distributed across nine investors on a $400,000 loss. The gap between what was promised (6% per month) and what was received (a fraction of principal, then nothing) generated months of financial uncertainty while investors waited for payments that never arrived.
• The defendants also failed to provide any of the required Disclosure Documents, which means investors had no way to assess the actual risk profile of commodity futures trading before committing their money. They were denied the legal minimum of informed consent.
• The scheme persisted from July 2019 through November 2020, meaning investors experienced over 16 months of false hope and continued exposure before the operation collapsed. Research consistently shows that prolonged financial uncertainty, more than a single acute loss event, is most correlated with chronic stress, sleep disruption, and anxiety disorders in affected individuals.

Economic Inequality: Who Gets Targeted by Unregistered Investment Schemes

The structure of this fraud is a textbook exploitation of trust networks in working and middle-class communities. That is who unregistered commodity pool schemes consistently target, because high-net-worth investors have gatekeepers.

• Miller recruited through Craigslist “Financial Services” ads and YouTube. These are not channels used to reach accredited investors or institutional money. They are how you reach people who do not have financial advisors, wealth managers, or legal counsel screening incoming opportunities.
• The guaranteed-return structure, specifically 6% per month for fourteen months, was designed to appeal to people without investment experience. Legitimate regulated funds do not promise fixed monthly returns. This promise is a red flag that professional investors would instantly recognize and reject. The target audience was people who wouldn’t know that.
• Dendinger solicited people he knew personally, described in the court record as “acquaintances.” This is a characteristic feature of affinity fraud, a form of financial crime that specifically exploits existing social trust to bypass the skepticism a stranger would face. The nine investors said yes partly because they trusted Dendinger.
• The total loss of $364,000 net (after partial repayments) will not be easily recovered. The civil penalties ordered, $900,000 against Miller/Flip 2 Futures and $750,000 against PDM, are paper numbers. Both entities are defunct or dissolved. Miller is a private individual in Otsego, Minnesota. The restitution order is a legal right, not a guarantee of recovery.
• The regulatory framework that was supposed to prevent this, mandatory CFTC registration, required disclosure documents, fund segregation rules, record-keeping obligations, was entirely bypassed because no one in a position to enforce it knew the scheme existed until after the money was gone. Regulatory gaps are not random. They are consistently exploited in communities where investors have less access to independent legal and financial counsel.

The Cost of a Life Metric

How It Was Supposed to Work: Required Process vs. What Happened

Federal law under the Commodity Exchange Act imposes specific steps before anyone can solicit investment funds for commodity futures trading. Here is the required process versus what the defendants actually did.

What Now? Here Is What You Can Do

The defendants in this case are ordered to pay restitution and civil penalties. Here is who is responsible, who is watching, and what ordinary people can do about the conditions that made this possible.

Who Is Accountable

• Richard “Rick” Miller, sole owner and operator of Flip 2 Futures, Otsego, MN. Permanently banned from all commodity futures trading by federal court order, December 3, 2024. Jointly and severally liable for $364,000 restitution and $900,000 civil monetary penalty.
• Flip 2 Futures Trading Company LLC, Minnesota. Administratively terminated but the entity can be reactivated. Jointly and severally liable for $364,000 restitution and $900,000 civil monetary penalty with Miller.
• Punch Drunk Marketing LLC, Wisconsin. Dissolved January 2024. Jointly and severally liable for the $364,000 restitution. Separately liable for $750,000 civil monetary penalty.
• Justin Dendinger, Managing Member of Punch Drunk Marketing, deceased September 23, 2023. Charges against him individually were voluntarily dismissed by the CFTC. His estate’s liability through PDM is not extinguished.

Regulatory Watchlist

• CFTC (Commodity Futures Trading Commission): The agency that brought this case. If you have been approached by an unregistered futures trading operation or commodity pool, file a tip at cftc.gov/whistleblower. The CFTC pays whistleblower awards.
• NFA (National Futures Association): Appointed as the restitution Monitor in this case. Verify whether any futures firm or individual you are considering is registered using the NFA’s BASIC database at nfa.futures.org/BasicNet. Flip 2 Futures and PDM would have returned zero results. That is the first check to run.
• SEC (Securities and Exchange Commission): If a scheme crosses into securities territory (pooled investment vehicles, unregistered securities offerings), the SEC’s Office of Investor Education and Advocacy handles complaints at investor.gov.
• Minnesota Department of Commerce: State-level regulator for investment advisers and securities in Minnesota. Contact for complaints involving Minnesota-based actors at mn.gov/commerce.
• Wisconsin Department of Financial Institutions: State regulator for Wisconsin-based entities like PDM. Contact at wdfi.org.
• FBI Financial Crimes: For schemes involving wire fraud, which this case demonstrates in full, the FBI accepts tips at ic3.gov (Internet Crime Complaint Center).

Mutual Aid and Grassroots Action

• Share the NFA BASIC database in community spaces, social media, local Facebook groups, neighborhood apps, and immigrant community networks. The tool that would have exposed this scheme immediately is public and free. Most people have never heard of it.
• Pressure your representatives for mandatory financial literacy education that covers investment fraud, specifically the promise of guaranteed returns as a fraud signal, unregistered adviser red flags, and the right to see credentials before transferring money. Contact your House representative at house.gov/representatives/find-your-representative.
• If you are a victim of a similar scheme, contact the CFTC’s Division of Enforcement directly. The restitution monitor in this case is the NFA at 300 S. Riverside Plaza, Suite 1800, Chicago, IL 60606. Document every communication, every transfer, every promise made to you in writing.
• Support community legal aid organizations in Minnesota and Wisconsin that assist low-income investors recover funds lost to fraud. Legal Aid Society of Minneapolis (lawhelpmn.org) and Legal Action of Wisconsin (legalaction.org) are starting points.
• Organize locally to advocate for stronger state-level commodity fraud statutes. Minnesota and Wisconsin have civil remedies under state law that run parallel to the CFTC action. Local organizing can push for easier private rights of action for defrauded investors.