SEC v. Trudy R. Gilmond (ponzi schemes, 2015)

Judgment entered

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The SEC's December 2015 case against ZeekRewards promoter Trudy Gilmond ended in a final judgment filed on 21 June 2017 in the Western District of North Carolina, entered after she refused to take part in discovery. It orders $1,752,673.47 in disgorgement and $169,084 in interest, to be offset by any restitution or forfeiture in the related Bell v. Disner case.

The record

What was ordered

Civil penalty

—

Disgorgement

$1.8m

Prejudgment interest

$169k

Total relief

$1.9m

Alleged gain

$1.7m

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The complaint, filed December 4, 2015, alleges that Gilmond was one of ZeekRewards' most prolific promoters, serving as a senior field liaison from September 2011 until the site closed in August 2012, and earned more than $1.7 million in commissions and profit-sharing. It charges unregistered offers and sales, acting as an unregistered broker-dealer and fraud.

She is charged as a promoter, not as the operator, of someone else's Ponzi scheme; the allegations are unproven and nothing had been ordered. The record had the status unknown.

This library tags the matter as ponzi schemes because the complaint says about 98 percent of the company's revenues and "profits" came from new investors in classic Ponzi fashion, a seller-of-a-third-party-scheme tag. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

On 27 March 2017 the court sanctioned Gilmond for her refusal to participate in discovery by entering a default judgment, deeming the SEC's allegations true and barring her from opposing its claims. The final judgment of 21 June 2017 enjoins her from violating Sections 5 and 17(a) of the Securities Act and Section 15(a) of the Exchange Act and orders disgorgement of $1,752,673.47, the sums she received, plus prejudgment interest of $169,084. Payment, totalling $1,921,757.47, goes to the court-appointed receiver in the related Bell v. Disner case for harmed investors, and the obligation is offset dollar for dollar by any restitution or forfeiture ordered there. The judgment is a sanction-based default, so the facts were not tried.

For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Ponzi schemes — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2015-12-08 Litigation release published
2. 2017-06-21 Final judgment entered against Gilmond (W.D.N.C.)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• Final judgment as to Trudy R. Gilmond (21 Jun 2017)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.