Constrafor, Inc. v. Federal Deposit Insurance Corporation, as receiver for Signature Bank

CourtDistrict Court, S.D. New York
DecidedSeptember 12, 2025
Docket1:24-cv-04402
StatusUnknown

This text of Constrafor, Inc. v. Federal Deposit Insurance Corporation, as receiver for Signature Bank (Constrafor, Inc. v. Federal Deposit Insurance Corporation, as receiver for Signature Bank) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Constrafor, Inc. v. Federal Deposit Insurance Corporation, as receiver for Signature Bank, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CONSTRAFOR, INC., Plaintiff, -against- 24-CV-4402 (JGLC) FEDERAL DEPOSIT INSURANCE OPINION AND ORDER CORPORATION, as receiver for Signature Bank, Defendant.

JESSICA G. L. CLARKE, United States District Judge:

Plaintiff Constrafor Inc. filed this action against the Federal Deposit Insurance Corporation, as Receiver for Signature Bank, alleging that the bank improperly withheld funds belonging to it. In 2022, under an agreement between Constrafor and a third party, the third party received funds owed to Constrafor in its account at Signature Bank. Constrafor never received those funds because Signature Bank blocked the third party’s payment to Constrafor. Separately, that same year, Constrafor wired funds to the same third-party’s account at Signature Bank. That transaction was canceled, and those funds were supposed to be returned to Constrafor. The third party accidentally initiated a duplicate return which led Constrafor to remit the purchase amount back to the third party a second time. Although Plaintiff’s wires into the Signature Bank account were successful, neither of the attempted returns were. Constrafor has repeatedly attempted to recoup its funds from the Signature Bank account both before and after the bank went into receivership, but has been unsuccessful. As a result, Constrafor brings this action, asserting claims for money had and received and conversion. On October 23, 2024, Defendant moved to dismiss Plaintiff’s claims in their entirety. As set forth in more detail below, Defendant’s motion to dismiss is GRANTED in part and DENIED in part, and Plaintiff’s motion for leave to amend is DENIED as futile. FACTUAL BACKGROUND The following facts are, unless otherwise noted, taken from the Complaint1 and presumed 0F to be true for the purposes of this motion. See LaFaro v. N.Y. Cardiothoracic Grp., PLLC, 570 F.3d 471, 475 (2d Cir. 2009). On April 26, 2022, Plaintiff Constrafor Inc. (“Constrafor” or “Plaintiff”) entered a Subcontractor Receivables Purchase Agreement (“SRPA”) with StructureTech New York, Inc. (“STNY”). ¶ 7. Pursuant to the SRPA, Constrafor agreed to purchase invoices issued by STNY to third-party debtors. ¶ 8. The Agreement further obligated STNY to act as Constrafor’s agent for the collection of purchased receivables and designated STNY as Constrafor’s attorney-in-fact to demand, take, collect, sue for, and receive all payments made concerning the purchased receivables. ¶¶ 11–12. The Agreement also required STNY to hold payments received from account debtors in trust for Constrafor and to remit these amounts to Constrafor within two business days of receipt. ¶ 13. Around June 16, 2022, STNY, acting as Plaintiff’s collection agent and trustee under the

SRPA, received a $523,012.71 deposit from Leeding Builders Group LLC (the “Leeding Deposit”) into its account at Signature Bank. ¶ 9. The Leeding Deposit was made pursuant to an invoice STNY issued and sold to Constrafor under the SRPA. ¶ 10. As such, the deposit should have been remitted to Plaintiff under the SRPA. However, the funds were withheld by Signature Bank. ¶¶ 14–15. Around July 14, 2022, Plaintiff remitted $880,660.72 by wire to STNY’s account at Signature Bank for the purchase of an invoice STNY had issued to Lions Group II LLC. ¶¶ 16– 17. On July 15, 2022, Plaintiff canceled the invoice purchase due to discrepancies identified in

1 All ¶ references herein refer to the Complaint at ECF No. 1 unless otherwise noted. the transaction and initiated a return of the funds by STNY. ¶¶ 18–19. Two days later, on July 17, 2022, STNY erroneously initiated a second and duplicate return of $880,660.72. ¶ 19. To fix the duplicate transaction, Plaintiff wired STNY $880,660.72, which was deposited into STNY’s account at Signature Bank. ¶ 20.

Neither the first nor second return wires were processed by Signature Bank, and they were never received by Constrafor. ¶ 21. To rectify the issue, on July 20, 2025, STNY attempted to return $1,761,321.44 (the “Lions Group Funds,” together with the Leeding Deposit, the “Subject Funds”) to Constrafor by executing a Funds Transfer Request. ¶ 22. The transfer was unsuccessful, however, because it was blocked by Signature Bank, which seized the funds. ¶ 23. In total, Signature Bank has held $2,284,334.15 in funds that were meant for Constrafor. ¶ 25. On March 12, 2023, Signature Bank, suffering financial instability, was placed under Federal Deposit Insurance Corporation (“FDIC”) receivership, and the FDIC took control of Signature Bank’s assets and liabilities. ¶¶ 27–28. In attempts to secure the return of its funds, Plaintiff submitted claims to the FDIC

seeking the return of $2,284,334.15 plus interest around July 23, 2022, and again on October 7, 2022. ¶¶ 29, 34–35. Despite Plaintiff’s demands, the FDIC would not return any funds to Plaintiff. ¶¶ 30, 36. Following the appointment of the FDIC as receiver for Signature Bank, Plaintiff also submitted a claim against the receivership to recover the Subject Funds. ¶ 37. Thereafter, as the parties agree, “[s]ubstantially all of the assets of Signature [Bank] were eventually purchased by, and the deposits were assumed by, Flagstar Bank, N.A. (“Flagstar”).” ECF No. 12 at 6; ECF No. 29-5 at 8. On April 12, 2024, Plaintiff was notified that the FDIC disallowed its claim to the Subject Funds, asserting that Plaintiff’s claim was a “general unsecured claim.” ¶ 37. PROCEDURAL HISTORY On June 8, 2024, Constrafor filed this action against the FDIC, as Receiver for Signature Bank. ECF No. 1. Defendant FDIC moved to dismiss the Complaint on October 23, 2024. ECF Nos. 11, 12 (“MTD Mem.”). The following week, Defendant filed a motion to stay discovery

pending the Court’s decision on the motion to dismiss, which Plaintiff opposed on October 31, 2024. ECF Nos. 14, 16. Based on the parties’ submissions, on November 25, 2024, the Court stayed discovery until resolution of Defendant’s motion to dismiss. ECF No. 19. On December 3, 2024, Plaintiff filed its opposition to Defendant’s motion to dismiss and Defendant replied on December 20, 2024. ECF Nos. 22 (“MTD Opp.”), 23. Nearly two months later, on February 12, 2025, Plaintiff sought the Court’s instruction regarding amending its Complaint to add Flagstar Bank, N.A. (“Flagstar”) as a defendant. ECF No. 24. On February 13, 2025, the Court ordered Defendant to respond to Plaintiff’s request, ECF No. 25, and the following day, Defendant filed a letter stating it took “no position on what procedure Plaintiff pursues in seeking to assert claims against Flagstar.” ECF No. 26. Accordingly, the Court

granted Plaintiff leave to file a motion seeking leave to amend its Complaint. ECF No. 27. On February 28, 2025, Plaintiff filed its motion for leave to amend its complaint along with a proposed Amended Complaint (“PAC”). ECF No. 29. Defendants filed their opposition on March 14, 2025, and Plaintiff replied on March 21, 2025. ECF Nos. 30, 32. On June 3, 2025, Plaintiff informed the Court that if their motion to amend remained undecided by June 9, 2025, Plaintiff would need to file a separate related action against Flagstar to preserve claims within the statutory period, which Plaintiff could later discontinue or consolidate upon the Court’s determination of their motion to amend the Complaint. ECF No. 33. On June 5, 2025, the Court permitted Plaintiff to file a separate action against Flagstar because it would not rule on the parties’ pending motions before June 9, 2025. ECF No. 34. Plaintiff filed that separate action against Flagstar. See Constrafor Inc. v. Flagstar Bank, N.A., No. 25-CV-4961 (JGLC), ECF No. 3 (S.D.N.Y. 2025). LEGAL STANDARD

I.

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Constrafor, Inc. v. Federal Deposit Insurance Corporation, as receiver for Signature Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/constrafor-inc-v-federal-deposit-insurance-corporation-as-receiver-for-nysd-2025.