SEC v. LFS Funding Limited Partnership, Stephen Thompson, Steven Comisar, Dale Engelhardt and Ross Erskine (undisclosed control blocks, 2021)

Alleged — pending

These are allegations. SEC has filed an action; nothing in it has been proven, and the respondents have not been found liable. Everything described on this page is what the regulator alleges, not what a court has found. See our editorial policy.

✓ Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In May 2021 the SEC sued LFS Funding Limited Partnership and four individuals over an unregistered offering. Final consent judgments followed against Thompson (May 2021), Comisar (November 2021) and Engelhardt (October 2023), and partial summary judgment against Erskine in August 2023; no final outcome for the partnership itself or for Erskine's remedies was found.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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 Securities and Exchange Commission announced on May 20, 2021 (litigation release 25093) a complaint in the Central District of California against LFS Funding Limited Partnership, Thompson, Comisar, Engelhardt and Erskine.

The SEC alleges that from May 2018 to May 2019 the defendants raised more than $618,000 from investors in limited partnership interests said to fund two medical clinics, that Thompson held undisclosed de facto control while others were named nominal general partners to conceal his involvement, and that the offering documents and Forms D hid that over $170,000 would go in commissions to unregistered salespeople and that Thompson was skimming through mark-ups by a supplier he controlled. It charges Section 5, Section 17(a), Section 10(b) and Rule 10b-5 against all, and unregistered-broker violations against the three salespeople. LFS Funding and Thompson consented to permanent injunctions, Thompson also to a solicitation bar; the release gives no result for the other three and no money amounts. These are allegations for the three still litigating.

This library tags the matter as undisclosed control blocks. The record showed the status as settled, which holds for only two of five defendants, and a single partnership name in the defendant field.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Outcome so far. In the Central District of California, a final judgment of 25 May 2021 against Stephen Thompson, who consented, imposes injunctions, an officer-and-director bar and a US$96,384 penalty. A final judgment of 3 November 2021 against Steven Comisar orders disgorgement of US$6,000 with interest and a US$6,000 penalty. A final judgment of 24 October 2023 against Dale Engelhardt orders US$54,620 in disgorgement and a US$109,240 penalty. On 25 August 2023 the court granted the SEC partial summary judgment against Ross Erskine.

The sources opened do not show a final judgment against the partnership, which is named first, or the remedies for Erskine, so the record stays at filed and no money figures are entered for the matter as a whole. Checked on 2026-10-04: no further outcome found on SEC pages.

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.

• Undisclosed control blocks — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2021-05-20 Litigation release published
2. 2021-05-25 Final judgment against Stephen Thompson (US$96,384 penalty)
3. 2021-11-03 Final judgment against Steven Comisar
4. 2023-08-25 Partial summary judgment granted against Ross Erskine
5. 2023-10-24 Final judgment against Dale Engelhardt

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 Stephen Thompson
• Final judgment as to Steven Comisar
• Order granting partial summary judgment (Erskine)
• Final judgment as to Dale Engelhardt

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. If this matter has since resolved, been withdrawn or been dismissed, we want to know: submit a correction.