IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

COMMODITY FUTURES

TRADING COMMISSION,

Plaintiff,

v. 

DAVID SEIBERT, individually and d/b/a 

SEI-EQUITY INVESTMENTS, a/k/a SEI 

EQUITY INVESTMENTS, a/k/a SEIBERT 

EQUITY INVESTMENTS, and d/b/a 

GREAT AMERICA FUNDING, LLC, a/k/a 

GREAT AMERICAN FUNDING, L.L.C., 

a/k/a GREAT AMERICAN FUNDING 

LENDER SERVICES, 

Defendant.

Case No: 1:20-cv-00935-RP

Hon. Judge Robert Pitman 

CONSENT ORDER FOR PERMANENT INJUNCTION AND OTHER EQUITABLE 

RELIEF AGAINST DEFENDANT DAVID SEIBERT, individually and d/ba SEI-EQUITY 

INVESTMENTS, a/k/a SEI EQUITY INVESTMENTS, a/k/a SEIBERT EQUITY 

INVESTMENTS, and d/b/a GREAT AMERICA FUNDING, LLC, a/k/a GREAT 

AMERICAN FUNDING, L.L.C., a/k/a GREAT AMERICAN FUNDING LENDER 

SERVICES

I. INTRODUCTION

On September 8, 2020, Plaintiff Commodity Futures Trading Commission 

(“Commission” or “CFTC”) filed a Complaint against Defendant David Seibert, individually and 

d/b/a SEI-Equity Investments, a/k/a SEI Equity Investments, a/k/a Seibert Equity Investments

(“SEI”), and d/b/a Great America Funding, LLC, a/k/a Great American Funding, L.L.C., a/k/a 

Great American Funding Lender Services (“GAF”), seeking injunctive and other equitable relief, 

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as well as the imposition of civil penalties, for violations of the Commodity Exchange Act 

(“Act”), 7 U.S.C. §§ 1–26 (2018). 

II. CONSENTS AND AGREEMENTS

To effect a partial settlement of the matters alleged in the Complaint against Defendant 

Seibert, without a trial on the merits or any further judicial proceedings, while reserving a 

determination of all monetary relief for further adjudication, including restitution, disgorgement 

and a civil monetary penalty, Defendant Seibert: 

1. Consents to the entry of this Consent Order for Permanent Injunction and Other 

Equitable Relief Against Defendant Seibert (“Consent Order”);

2. Affirms that he has read and agreed to this Consent Order voluntarily, and that no 

promise, other than as specifically contained herein, or threat, has been made by the Commission

or any member, officer, agent, or representative thereof, or by any other person, to induce 

consent to this Consent Order; 

3. Acknowledges service of the summons and Complaint; 

4. Admits the jurisdiction of this Court over him and the subject matter of this action 

pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2018); 

5. Admits the jurisdiction of the Commission over the conduct and transactions at 

issue in this action pursuant to the Act; 

6. Admits that venue properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e);

7. Waives: 

(a) Any and all claims that he may possess under the Equal Access to Justice 

Act, 5 U.S.C. § 504 (2018) and 28 U.S.C. § 2412 (2018), and/or the rules 

promulgated by the Commission in conformity therewith, Part 148 of the 

Regulations, 17 C.F.R. pt. 148 (2019), relating to, or arising from, this 

action;

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(b) Any and all claims that he may possess under the Small Business 

Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, 

§§ 201–253, 110 Stat. 847, 857–74 (codified as amended at 28 U.S.C. 

§ 2412 and in scattered sections of 5 U.S.C. and 15 U.S.C.), relating to, or 

arising from, this action; 

(c) Any claim of Double Jeopardy based upon the institution of this action or 

the entry in this action of any order imposing a civil monetary penalty or 

any other relief, including this Consent Order; and 

(d) Any and all rights of appeal from this action; 

8. Consents to the continued jurisdiction of this Court over him for the purpose of 

implementing and enforcing the terms and conditions of this Consent Order and for any other 

purpose relevant to this action, even if Defendant Seibert now or in the future resides outside the 

jurisdiction of this Court; 

9. Agrees that he will not oppose enforcement of this Consent Order on the ground, 

if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Procedure and 

hereby waives any objection based thereon; 

10. Agrees that neither he nor any of his agents or employees under his authority or 

control shall take any action or make any public statement denying, directly or indirectly, any 

allegation in the Complaint or the Findings of Fact or Conclusions of Law in this Consent Order, 

or creating or tending to create the impression that the Complaint and/or this Consent Order is 

without a factual basis; provided, however, that nothing in this provision shall affect his: 

(a) testimonial obligations, or (b) right to take legal positions in other proceedings to which the 

Commission is not a party. Defendant shall comply with this agreement, and shall undertake all 

steps necessary to ensure that all of his agents and/or employees under their authority or control 

understand and comply with this agreement; 

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11. Consents to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except as to 

jurisdiction and venue, which he admits; 

12. Consents to the use of the findings and conclusions in this Consent Order in this 

proceeding and in any other proceeding brought by the Commission or to which the Commission 

is a party or claimant, and agrees that they shall be taken as true and correct and be given 

preclusive effect therein, without further proof; 

13. Does not consent, however, to the use of this Consent Order, or the findings and 

conclusions herein, as the sole basis for any other proceeding brought by the Commission or to 

which the Commission is a party, other than a: statutory disqualification proceeding; proceeding 

in bankruptcy, or receivership; or proceeding to enforce the terms of this Order; 

14. Agrees to provide immediate notice to this Court and the Commission by certified 

mail, in the manner required by paragraph 48 of Part VI. of this Consent Order, of any 

bankruptcy proceeding filed by, on behalf of, or against him, whether inside or outside the 

United States; and

15. Agrees that no provision of this Consent Order shall in any way limit or impair 

the ability of any other person or entity to seek any legal or equitable remedy against him in any 

other proceeding.

III. FINDINGS OF FACT AND CONCLUSIONS OF LAW

 The Court, being fully advised in the premises, finds that there is good cause for the entry 

of this Consent Order and that there is no just reason for delay. The Court therefore directs the 

entry of the following Findings of Fact, Conclusions of Law, permanent injunction and equitable 

relief pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), as set forth herein. 

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THE COURT HEREBY FINDS: 

A. Findings of Fact 

The Parties to this Consent Order

16. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with administering and enforcing the Act and CFTC

Regulations (“Regulations”), 17 C.F.R. pts. 1-190 (2019).

17. Defendant David Seibert resides in Lakeway, Texas. Seibert has never been 

registered with the CFTC in any capacity. Seibert has done business under the following 

fictitious names: SEI-Equity Investments, a/k/a SEI Equity Investments, a/k/a Seibert Equity 

Investments, and d/b/a Great America Funding, LLC a/k/a Great American Funding, L.L.C., 

a/k/a Great American Funding Lender Services. 

SEIBERT’S FRAUDULENT SCHEME

Seibert’s Representations About his Fraudulent “Bridge Loan” Deals

18. Beginning in at least March 2016, Seibert asked potential participants, many of 

whom reside in Texas, to participate with him as lenders in short-term secured loans that Seibert 

would originate and arrange. 

19. Seibert represented to potential participants that he and his purported company, 

GAF, were engaged in the business of making short-term, high-interest “bridge loans” to 

commercial borrowers in order for the borrowers to make additions or repairs to property or to 

otherwise meet cash needs before permanent financing could be secured. 

20. Seibert told potential participants that he would advise them of lending 

opportunities, complete the due diligence to determine if the borrower was well-qualified and 

that the offered collateral would fully secure the loan, and handle the preparation of the loan 

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documents and the closing of the transaction through a qualified attorney and title company, and 

that GAF would service the loan. 

21. Seibert described the loans as interest-only loans paying interest on a monthly 

basis with a balloon payment of all principal after a term of approximately one year. The offered 

loans were to be secured by a first lien deed of trust on real property, a security interest on the 

assets of the debtor and a personal guarantee. 

The Closing of Seibert’s Deals 

22. When an individual decided to participate in one of Seibert’s deals, Seibert would 

tell them to write a check made payable to him personally or, more frequently, to wire the funds 

to a bank account which he said was held in the name of GAF. In reality, the account was 

Seibert’s personal bank account. The participants’ funds were pooled in Seibert’s bank account 

and commingled there with funds from other participants and with Seibert’s personal funds. 

23. After the deals “closed,” Seibert sent binders of documents to participants 

purporting to show that the loan transaction had been documented and closed by a law firm 

through a title company as escrow agent. Among the documents enclosed in these binders were 

the loan agreement, the personal guarantee of a principal of the borrowing company, a first lien 

deed of trust and a promissory note in the original principal sum that was purportedly executed 

by the borrower. 

24. After the closing, Seibert paid the participants monthly “interest” payments on the 

loans, with participants presuming them to be paid by the borrower in the loan deal. In reality, 

the payments derived from funds of other participants. 

Seibert’s Misappropriation and Fraud 

25. Seibert received approximately $10 million in funds from at least eight

participants that was deposited into his personal bank account. 

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26. Seibert used the majority of his pooled participants’ funds to trade commodity 

interests in his trading account. Seibert used additional participants’ funds for various personal 

expenses. 

27. Seibert never disclosed to the participants that instead of using their funds to 

make bridge loans, he was actually pooling their funds with those of other participants and using 

them to trade commodity interests. Nor did he disclose that he was using additional participants’

funds for personal expenses described above. 

28. On March 9, 2017, Seibert opened a commodity trading account in the name of 

David Seibert at a futures commission merchant (“FCM”) (“FCM A”). His account application at 

FCM A stated that he was employed as a financial advisor for “Seibert Equity Investments” 

earning an income of $300,000 annually and that all of the funds in the account belonged to him. 

29. From March 2017 to April 2019, Seibert deposited $8,645,198 into his personal 

commodity trading account at FCM A. The vast majority, if not all, of the deposited funds were 

participants’ funds. 

30. Seibert lost $8,336,148 trading commodity interests in his account at FCM A 

from March 2017 to April 2019. 

B. Conclusions of Law

Jurisdiction and Venue

31. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. § 1331 

(2018) (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (2018) (providing that U.S. 

district courts have original jurisdiction over civil actions commenced by the United States or by 

any agency expressly authorized to sue by Act of Congress). Section 6c(a) of the Act, 7 U.S.C. 

§ 13a-1(a) (2018), provides that the Commission may bring actions for injunctive relief or to 

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enforce compliance with the Act or any rule, regulation, or order thereunder in the proper district 

court of the United States whenever it shall appear to the Commission that any person has 

engaged, is engaging, or is about to engage in any act or practice constituting a violation of any 

provision of the Act or any rule, regulation, or order thereunder. 

32. Venue properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e), because 

Defendant resides in this jurisdiction and the acts and practices in violation of the Act occurred 

within this District.

Fraud by a Commodity Pool Operator 

33. A commodity pool is defined in Section 1a(10) of the Act, 7 U.S.C. § 1a(10) (2018), in part, as:

[A]ny investment trust, syndicate, or similar form of enterprise operated for the purpose of trading in 

commodity interests, including any – 

(i) commodity for future delivery, security futures product, or swap; (ii) agreement, contract, or transaction 

described in section 2(c)(2)(C)(i) of this tile or section 2(c)(2)(D)(i) of this title; (iii) commodity option 

authorized under section 6c of this tile; or (iv) leverage transaction authorized under section 23 of this title.

34. A commodity pool operator (“CPO”) is defined in Section 1a(11) of the Act, 

7 U.S.C. § 1a(11) (2018), in part, as any person: 

[E]ngaged in a business that is of the nature of a commodity pool, investment 

trust, syndicate, or similar form of enterprise, and who, in connection therewith, 

solicits, accepts, or receives from others, funds, securities or property, either 

directly or through capital contributions, the sale of stock or other forms of 

securities, or otherwise for the purpose of trading in commodity interests, 

including any—(I) commodity for future delivery . . . 

35. From at least March 2016 to April, 2019, Seibert has been operating as a CPO in 

that he engaged in a business that is of the nature of an investment trust, syndicate or similar 

form of enterprise, and in connection therewith, solicited, accepted, or received funds, securities, 

or property from others for the purpose of trading commodity interests. 

36. Section 4o(1)(A) of the Act, 7 U.S.C. §6o(1)(A) (2018), provides, in relevant part, 

that it shall be unlawful for a CPO, by use of the mails or any means or instrumentality of 

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interstate commerce, directly or indirectly “to employ any device, scheme or artifice to defraud 

any client . . . or prospective client. . . .” 

37. Section 4o(1)(B) of the Act, 7 U.S.C. § 6o(1)(B) (2018), provides, in relevant 

part, that it shall be unlawful for a CPO, by use of the mails or any means or instrumentality of 

interstate commerce, directly or indirectly “to engage in any transaction, practice, or course of 

business which operates as a fraud or deceit upon any client . . . or prospective client. . . .” 

38. From at least March 2016 to April 2019, Seibert through the use of the mails or 

other means or instrumentalities of interstate commerce (including through the use of telephone 

calls and electronic mail with prospective and existing participants and through the use of 

interstate wire transfers), violated 7 U.S.C. §§ 6o(1)(A) and (B) by: (1) misappropriating 

participant funds for Seibert’s benefit; (2) falsely promising that participants’ funds were 

protected as loans collateralized by real property; and (3) not disclosing to participants that their 

funds were being used for, and lost by, his trading of commodity interests. 

39. Seibert engaged in the acts and practices described herein willfully, knowingly, or 

with reckless disregard for the truth. 

40. Each act of misappropriation, misrepresentation or omission of material facts by 

Seibert constitutes a separate and distinct violation of 7 U.S.C. §§ 6o(1)(A) and (B). 

Failure to Register as a CPO 

41. Section 4m(1) of the Act, 7 U.S.C. § 6m(1) (2018), makes it unlawful for any 

CPO, unless registered with the CFTC, to make use of the mails or any means or instrumentality 

of interstate commerce in connection with its business as a CPO.

42. Seibert has never been registered as a CPO nor does he qualify for a CPO 

registration exemption under either the Act or the CFTC Regulations.

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43. From at least March 2016 to April 2019, Seibert used the mails, wires, or other 

instrumentalities of interstate commerce in or in connection with his business as a CPO while 

failing to register as a CPO and violated 7 U.S.C. § 6m(1).

44. Each instance of soliciting, accepting, or receiving funds, securities or property 

from others, either directly or indirectly through capital contributions, the sale of stock or other 

forms of securities, or otherwise for the purpose of trading in commodity interests by making use 

of the mails or other means or instrumentality of interstate commerce, is a separate and distinct 

violation of 7 U.S.C. § 6m(1).

IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

45. Based upon and in connection with the foregoing conduct, pursuant to Section 6c 

of the Act, 7 U.S.C. § 13a-1 (2018), Seibert is permanently restrained, enjoined and prohibited 

from directly or indirectly:

a. While operating as a commodity pool operator, employing any device, scheme, or 

artifice to defraud any client or prospective client, or engaging in any transaction, 

practice, or course of business which operates as a fraud or deceit upon any client 

or participant or prospective client or participant, in violation of Section 4o(1)(A) 

and (B) of the Act, 7 U.S.C. §§ 6o(a)(A), (B) (2018); and/or 

b. Making use of the mails or any means or instrumentality of interstate commerce 

in connection with its business as a CPO without registration with the CFTC as a 

CPO, in violation of Section 4m(1) of the Act, 7 U.S.C. § 6m(1) (2018). 

46. Seibert is also permanently restrained, enjoined and prohibited from directly or 

indirectly: 

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a. Trading on or subject to the rules of any registered entity (as that term is defined 

in Section 1a(40) of the Act,7 U.S.C. § 1a(40) (2018)); 

b. Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2018)) for his own personal accounts or 

for any account in which he has a direct or indirect interest; 

c. Having any commodity interests traded on his behalf; 

d. Controlling or directing the trading for or on behalf of any other person or entity, 

whether by power of attorney or otherwise, in any account involving commodity 

interests; 

e. Soliciting, receiving or accepting any funds from any person for the purpose of 

purchasing or selling any commodity interests; 

f. Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such 

registration or exemption from registration with the Commission, except as 

provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2019); and/or 

g. Acting as a principal (as that term is defined in Regulation 3.1(a), 17 C.F.R. 

§ 3.1(a) (2019)), agent or any other officer or employee of any person (as that 

term is defined in Section 1a(38) of the Act, 7 U.S.C. § 1a(38) (2018)), registered, 

exempted from registration or required to be registered with the Commission 

except as provided for in 17 C.F.R. § 4.14(a)(9). 

V. RESTITUTION, DISGORGEMENT, AND CIVIL MONETARY PENALTY

47. The issue of relief pursuant to Section 6c of the Act, 7 U.S.C. §13a-1 (2018), 

regarding restitution to Defendant’s defrauded participants, disgorgement and an appropriate 

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civil monetary penalty to be assessed against Defendant Seibert, is still unresolved and is hereby 

reserved for further determination by this Court upon motion of the Commission or by a 

proposed Consent Order. However, Seibert agrees to pay full restitution to defrauded 

participants in an amount to be determined later. 

48. In connection with any Commission motion for restitution, disgorgement and/or 

civil monetary penalties, and at any hearing held on such motion: (a) Defendant Seibert will be 

precluded from arguing the he did not violate the federal laws as agreed to in this Consent Order; 

(b) Defendant Seibert may not challenge the validity of his consent and agreement herein or this 

Consent Order; (c) solely for the purposes of such motion, the Findings of Fact and Conclusions 

of Law of this Consent Order shall be accepted as and deemed true by the Court; and (d) the 

court may determine the issues raised in the motion on the basis of affidavits, declarations, 

excerpts of sworn deposition or investigative testimony, witness testimony, and documentary 

evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the 

Federal Rules of Civil Procedure. In connection with the Commission’s motion for restitution, 

disgorgement and/or civil monetary penalties, the parties may take discovery, including 

discovery from appropriate non-parties. 

VI. MISCELLANEOUS PROVISIONS

49. Notice: All notices required to be given by any provision in this Consent Order 

shall be sent certified mail, return receipt requested, as follows: 

Notice to Commission: 

Robert T. Howell 

Deputy Director

Commodity Futures Trading Commission

Division of Enforcement

525 W. Monroe Street 

Suite 1100 

Chicago, IL 60661

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Notice to Defendant: 

 David Seibert, individually and d/b/a 

SEI-Equity Investments, a/k/a SEI 

 Equity Investments, a/k/a Seibert Equity 

Investments, and d/b/a Great America

Funding, LLC, a/k/a Great American

Funding, LLC a/ka Great American

 Funding Lender Services 

 103 Palos Verdes Dr. 

Lakeway, Texas 78734 

All such notices to the Commission shall reference the name and docket number of this action. 

50. Change of Address/Phone: Until such time as Defendant satisfy in full their 

Restitution Obligation, and CMP Obligation as set forth in this Consent Order, Defendants shall 

provide written notice to the Commission by certified mail of any change to his telephone 

number and mailing address within ten calendar days of the change.

51. Entire Agreement and Amendments: This Consent Order incorporates all of the 

terms and conditions of the settlement among the parties hereto to date. Nothing shall serve to 

amend or modify this Consent Order in any respect whatsoever, unless: (a) reduced to writing; 

(b) signed by all parties hereto; and (c) approved by order of this Court. 

52. Invalidation: If any provision of this Consent Order or if the application of any 

provision or circumstance is held invalid, then the remainder of this Consent Order and the 

application of the provision to any other person or circumstance shall not be affected by the 

holding. 

53. Waiver: The failure of any party to this Consent Order or of any participant at 

any time to require performance of any provision of this Consent Order shall in no manner affect 

the right of the party or participant at a later time to enforce the same or any other provision of 

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this Consent Order. No waiver in one or more instances of the breach of any provision contained 

in this Consent Order shall be deemed to be or construed as a further or continuing waiver of 

such breach or waiver of the breach of any other provision of this Consent Order. 

54. Waiver of Service, and Acknowledgement: Defendant waives service of this 

Consent Order and agrees that entry of this Consent Order by the Court and filing with the Clerk 

of the Court will constitute notice to the Defendant of its terms and conditions. Defendant 

further agrees to provide counsel for the Commission, within thirty days after this Consent Order 

is filed with the Clerk of Court, with an affidavit or declaration stating that Defendant has 

received and read a copy of this Consent Order. 

55. Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of this 

action to ensure compliance with this Consent Order and for the determination of damages under 

Section 6c of the Act, and for all other purposes related to this action, including any motion by 

Defendant to modify or for relief from the terms of this Consent Order. 

56. Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Consent Order shall be binding upon Defendant, upon any person under his

authority or control, and upon any person who receives actual notice of this Consent Order, by 

personal service, e-mail, facsimile or otherwise insofar as he or she is acting in active concert or 

participation with Defendant.

57. Counterparts and Facsimile Execution: This Consent Order may be executed in 

two or more counterparts, all of which shall be considered one and the same agreement and shall 

become effective when one or more counterparts have been signed by each of the parties hereto 

and delivered (by facsimile, e-mail, or otherwise) to the other party, it being understood that all 

parties need not sign the same counterpart. Any counterpart or other signature to this Consent 

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Order that is delivered by any means shall be deemed for all purposes as constituting good and 

valid execution and delivery by such party of this Consent Order. 

58. Contempt: Defendant understands that the terms of the Consent Order are 

enforceable through contempt proceedings, and that, in any such proceedings he may not 

challenge the validity of this Consent Order. 

59. Cooperation: Defendant has cooperated fully, and agrees that he will continue to 

cooperate fully with the Commission, including the Commission’s Division of Enforcement, in 

this action, and in any current or future Commission investigation or action related thereto. 

Defendant also agrees that he will cooperate in any investigation, civil litigation, or 

administrative matter related to, or arising from, the subject matter of this action. 

60. Agreements and Undertakings: Defendant shall comply with all of the 

undertakings and agreements set forth in this Consent Order. 

IT IS SO ORDERED on this _____day of ________________________, 2020. 

 _________________________________ 

 

 UNITED STATES DISTRICT JUDGE

There being no just reason for delay, the Clerk of the Court is hereby ordered to enter this 

Consent Order for Permanent Injunction and Other Equitable Relief Against Defendant, David 

Seibert, individually and d/b/a SEI-Equity Investments, a/k/a SEI Equity Investments, a/k/a 

Seibert Equity Investments, and d/b/a Great American Funding, LLC, a/k/a Great American 

Funding, L.L.C., a/k/a Great American Funding Lender Services, forthwith and without further 

notice. 

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