UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 79881 / January 26, 2017

ADMINISTRATIVE PROCEEDING

File No. 3-16398

____________________________________________

 :

In the Matter of : ORDER DIRECTING 

 : DISBURSEMENT OF FAIR

SANDRA DYCHE, : FUND

 : 

Respondent. :

____________________________________________ :

On September 20, 2015, the Commission published a Notice of Proposed Plan of

Distribution and Opportunity for Comment (“Notice”)1pursuant to Rule 1103 of the

Commission’s Rules on Fair Fund and Disgorgement Plans (“Rules”).

2

The Notice advised 

interested persons that they could obtain a copy of the proposed Plan of Distribution (“Proposed 

Plan”) from the Commission’s public website at http://www.sec.gov/litigation/fairfundlist.htm or 

by submitting a written request to Michael Lim, United States Securities and Exchange 

Commission, 100 F Street, NE, Washington, DC 20549-5876.

The Notice also advised that all persons desiring to comment on the Proposed Plan could 

submit their comments, in writing, no later than thirty (30) days from the date of the Notice (1) to 

the Office of the Secretary, United States Securities and Exchange Commission, 100 F Street, 

NE, Washington, DC 20549-1090; (2) by using the Commission’s Internet comment form 

(http://www.sec.gov/litigation/admin.shtml); or (3) by sending an e-mail to rulecomments@sec.gov. 

 

1 Exchange Act Rel. No. 78889 (Sept. 20, 2016).

2

17 C.F.R. § 201.1103.
2

On October 18, 2016, a letter with two comments was submitted by Sandra Dyche

(“Dyche”) through her counsel. In response to one of Dyche’s comments, the staff modified the 

Proposed Plan to clarify that the administrative proceeding against Dyche was on a neither admit 

nor deny basis (“Plan”). 

On January 24, 2017, the Commission issued an Order Approving Plan of Distribution,

3

which detailed the changes made to the Proposed Plan and approved the Plan.

The Fair Fund is comprised of $1,414,000.00 with the Net Fair Fund4being 

$1,404,665.01. As set forth in paragraph 6, the Plan seeks to distribute the Net Fair Fund to 

certain investors identified by Commission staff during its investigation who were harmed by 

Respondent’s material misstatements and omissions, and misappropriation of funds described in 

the Order.

5

 The methodology for calculating an Eligible Investors’ payment amount is set forth 

in paragraph 13 of the Plan.

The Fund Administrator, Michael S. Lim, Attorney Advisor in the Commission’s 

Division of Enforcement’s Office of Distributions, represents that a verified payment file has 

been prepared pursuant to the Plan, with a list of payees and the amount to be paid to each 

person, with $1,404,665.01 being the total amount to be disbursed. Commission staff have 

reviewed the payment file and request that, pursuant to Rule 1101(b)(6) of the Rules,6the 

Commission direct the payment of $1,404,665.01 from the Fair Fund for distribution by the Fund 

Administrator according to the Plan. Any remaining monies in the Fair Fund will be transferred 

 

3 Exchange Act Rel. No. 79866 (Jan. 24, 2017).

4

 All capitalized terms used but not herein defined shall have the same meanings ascribed to them in the Plan.

5 Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act 

of 1933, Sections 15(b) and 21C of the Securities Exchange Act of 1934, and Section 9(b) of the Investment 

Company Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-And-Desist Order, 

Securities Act Rel. No. 9729 (Feb. 20, 2015).

6

 17 C.F.R. § 201.1101(b)(6).
3

to the U.S. Treasury after a final accounting is approved by the Commission, pursuant to 

paragraph 25 of the Plan.

Accordingly, it is ORDERED that the Commission staff direct the payment of 

$1,404,665.01 from the Fair Fund to be distributed to Eligible Investors pursuant to the Plan.

By the Commission.

Brent J. Fields

Secretary