FINRA

Without admitting or denying the findings, Engelmann consented to the sanctions and to the entry of findings that without his member firm's knowledge or approval he borrowed a total of $115,000 from two firm customers through an LLC he partly owned. The findings stated that Engelmann borrowed the funds to finance real estate ventures. The terms of the loans were set forth in promissory notes. In addition, Engelmann falsely stated on firm compliance questionnaires that he had not borrowed money from any firm customer. Engelmann has fully and timely repaid the loan from the first customer and has made all payments due to the second customer to date, as required by the promissory note.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$5,000.00

Suspension

All Capacities

Four months

11/2/2020

3/1/2021

LPL Financial LLC

Discharged

Received loans from clients, in violation of LPL policy.

CLIENT ALLEGES FAILURE TO FOLLOW INSTRUCTIONS REGARDING MUTUAL FUND INVESTMENT. ACTIVITY DATES: 9/30/2008-11/13/2008.

$18,866.57

$18,866.57

IN LATE SEPTEMBER OF 2008, THE CLIENTS CONTACTED ME, DESIRING TO SELL THEIR MUTUAL FUND INVESTMENTS. I ENTERED THE TRADE AT THAT TIME IN THE PRESENCE OF THE CLIENTS (IN A SUBSEQUENT CONVERSATION, THEY ACKNOWLEDGED WITNESSING ME INPUT THE TRADES). HOWEVER, FOR WHATEVER REASON, CHASE'S TRADING DESK NEVER RECEIVED THE ORDERS. THE CLIENTS CONTACTED ME IN MID-NOVEMBER, 2008 TO INFORM ME THAT THEIR ACCOUNT WAS STILL INVESTED. AFTER CONFIRMING THAT THE TRADES HAD NOT TAKEN PLACE, I PLACED A SELL ORDER AND FORWARDED THE MATTER TO MY SUPERVISOR TO RESOLVE THE ISSUE. BECAUSE OF THE EXTREME VOLATILITY IN THE MARKETS DURING THIS TIME PERIOD, THE LOSSES AMOUNTED TO A LARGE AMOUNT.