ORDER INSTITUTING

ADMINISTRATIVE PROCEEDINGS 

PURSUANT TO SECTION 15(b) OF THE 

SECURITIES EXCHANGE ACT OF 1934, 

MAKING FINDINGS, AND IMPOSING 

REMEDIAL SANCTIONS

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 99605 / February 26, 2024

ADMINISTRATIVE PROCEEDING 

File No. 3-21861

In the Matter of

DALE JAY ENGELHARDT,

Respondent.

I .

The Securities and Exchange Commission (“Commission”) deems it appropriate and in 

the public interest that public administrative proceedings be, and hereby are, instituted pursuant to 

Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) against Dale Jay 

Engelhardt (“Respondent”).

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer of 

Settlement (the “Offer”) which the Commission has determined to accept. Solely for the purpose of 

these proceedings and any other proceedings brought by or on behalf of the Commission, or to which 

the Commission is a party, and without admitting or denying the findings herein, except as to the 

Commission’s jurisdiction over him and the subject matter of these proceedings and the findings 

contained in paragraph III.2. below, which are admitted, Respondent consents to the entry of this 

Order Instituting Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange 

Act of 1934, Making Findings, and Imposing Remedial Sanctions (“Order”), as set forth below.
III.

On the basis of this Order and Respondent’s Offer, the Commission finds that:

1. Respondent was engaged by Stephen Thompson, the undisclosed person controlling 

LFS Funding Limited Partnership, to solicit prospective investors to purchase securities issued by 

LFS Funding Limited Partnership and, among other conduct, acted, through this engagement, as a 

broker-dealer without being registered with the Commission as a broker-dealer or while being 

associated with any entity that was so registered as a broker-dealer. Respondent, 59 years old, is a 

resident of the Los Angeles, California, area.

2. On January 22, 2024, a final judgment was entered by consent against Respondent, 

permanently enjoining him from (a) future violations of Sections 5 and 17(a) of the Securities Act of 

1933; Sections 10(b), 15(a)(1), and 15(b)(6)(B)(i) of the Exchange Act; and Exchange Act Rule 10b5; and (b) directly or indirectly, including, but not limited to, through any entity owned or controlled 

by Respondent, soliciting any person or entity to purchase or sell any security in the civil action 

entitled Securities and Exchange Commission v. LFS Funding Limited Partnership, et al., Civil 

Action Number 2:21-cv-04211, in the United States District Court for the Central District of 

California.

3. The Commission’s complaint alleged that, Respondent sold unregistered securities, 

engaged in fraud, and sold securities without being registered with the Commission as a brokerdealer or being associated with any entity that was so registered as a broker-dealer, and did so 

while an order, issued pursuant to Section 15(b)(6)(A) of the Exchange Act, was in effect in 

regard to Respondent.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest 

to impose the sanctions agreed to in Respondent’s Offer.

Accordingly, it is hereby ORDERED, pursuant to Section 15(b)(6) of the Exchange Act, 

that Respondent be, and hereby is, barred from association with any broker, dealer, investment 

adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally recognized 

statistical rating organization; and

Pursuant to Section 15(b)(6) of the Exchange Act, Respondent be, and hereby is, barred from 

participating in any offering of a penny stock, including: acting as a promoter, finder, consultant, 

agent, or other person who engages in activities with a broker, dealer, or issuer for purposes of the 

issuance or trading in any penny stock, or inducing or attempting to induce the purchase or sale of 

any penny stock.

Any reapplication for association by the Respondent will be subject to the applicable laws 

and regulations governing the reentry process, and reentry may be conditioned upon a number of 

factors, including, but not limited to, compliance with the Commission’s order and payment of any 

or all of the following: (a) any disgorgement or civil penalties ordered by a Court against the 

Respondent in any action brought by the Commission; (b) any disgorgement amounts ordered
against the Respondent for which the Commission waived payment; (c) any arbitration award related 

to the conduct that served as the basis for the Commission order; (d) any self-regulatory organization 

arbitration award to a customer, whether or not related to the conduct that served as the basis for the 

Commission order; and, (e) any restitution order by a self-regulatory organization, whether or not 

related to the conduct that served as the basis for the Commission order.

By the Commission.

Vanessa A. Countryman 

Secretary