Consumer Financial Protection Bureau v. Stratfs, LLC (f/k/a Strategic Financial Solutions, LLC)

District Court, W.D. New York·Decided November 13, 2024·No. 1:24-cv-00040·Unknown

Opinion

SE FILES SO /~ | NOV13 2024 UNITED STATES DISTRICT COURT \ etap □□ WESTERN DISTRICT OF NEW YORK * Li oe Loewen □ □□

CONSUMER FINANCIAL PROTECTION, 24-CV-40-EAW-MJR BUREAU, e¢ al., DECISION AND ORDER Plaintiffs, V.

STRATFS, LLC (f/k/a STRATEGIC FINANCIAL SOLUTIONS, LLC), ef a/., Defendants, and

STRATEGIC ESOP, et al., Relief Defendants.

On September 4, 2024, the Court-appointed receiver Thomas W. McNamara (the “Receiver’) filed a “Second Interim Application for Order Approving Fees and Expenses of the Receiver and Professionals” that have rendered services on the Receiver’s behalf from March 1, 2024 through July 31, 2024 (“Second Fee Application”). (Dkt. No. 432) Specifically, the Receiver asks the Court to approve the payment of (1) fees and expenses of the Receiver and staff to be paid to TWM Receiverships, Inc. dba Regulatory Resolutions as follows: March fees of $111,541.50 and expenses of $6,077.52; April fees of $104,420.00 and expenses of $4,619.69; May fees of $104,213.50 and expenses of $9,198.66; June fees of $76,447.50 and expenses of $4,441.40; July fees of $58,841.50 and expenses of $7,291.39; (2) fees and expenses for the Receiver’s counsel, McNamara Smith LLP as follows: March fees of $81,448.50 and expenses of $2,462.75; April fees of $88,261.00 and expenses of $1,073.46; May fees of $29,818.50 and expenses of $59.95:

June fees of $20,863.50 and expenses of $842.27; July fees of $25,546.00 and expenses of $18.61; (3) fees and expenses for the Receiver’s counsel, Hodgson Russ LLP as follows: March fees of $52,350.50 and expenses of $29.44: April fees of $56,239.50; May fees of $20,846.00 and expenses of $632.77; June fees of $13,505.50; July fees of $20,556.00; (4) fees and expenses of the Receiver’s counsel, Ballard Spahr LLP as follows: May fees of $23,190.75 and expenses of $37.45; June fees of $8,533.35; July fees of $7,201.35 and expenses of $24.75: (5) fees and expenses for the Receiver’s counsel, Hilgers Graben LLP as follows: March fees of $24,830.00 and expenses of $514.44; April fees of $21,377.50; May fees of $3,967.50; June fees of $4,657.50; July fees of $440.00; (6) fees for the Receiver’s forensic accountants Mercadien, P.C. as follows: March fees of $26,488.00; April fees of $14,069.50; May fees of $22,850.25; June fees of $4,283.00; July fees of $6,094.50; and (7) fees and expenses for the Receiver’s data forensic consultants Bright Labs Services, LLC (Ankura) as follows: March fees of $11,571.00 and expenses of $7,997.68; April fees of $2,179.00 and expenses of $7,981.12; May fees of $6,896.50 and expenses of $8,353.04; June fees of $4,972.50 and expenses of $8,183.76; July fees of $1,776.50 and expenses of $17,287.91. (/d.) For the following reasons, the Court grants the Receiver’s Second Fee Application in its entirety. The Receiver was initially appointed by District Judge Lawrence J. Vilardo, pursuant to the Temporary Restraining Order (“TRO”), on January 11, 2024. (Dkt. No. 12) The Receiver’s appointment was confirmed, and the temporary designation removed, by this Court, pursuant to the Preliminary Injunction (“PI”) entered on March 4, 2024. (Dkt. No. 184) The Receiver has continued to serve in this capacity from March 4, 2024 through

the present. On May 22, 2024, this Court granted the Receiver’s First Interim Application for Order Approving Fees and Expenses of the Receiver and Professionals that have rendered services on the Receiver’s behalf from January 1, 2024 through February 29, 2024 (“First Fee Application”). (Dkt. No. 358) This Decision and Order assumes familiarity with the Court’s Decision and Order granting the Receiver’s First Fee Application, the PI, and the other prior proceedings and filings in this case." "A receiver appointed by a court who reasonably and diligently discharges his duties is entitled to be fairly compensated for services rendered and expenses incurred. The amount of the compensation is to be determined by the court in the exercise of its reasonable discretion." SEC v. Byers, 590 F. Supp. 2d 637, 644 (S.D.N.Y. 2008) (citations omitted). "This presumption of reasonable compensation extends to a receiver's counsel and professionals." SEC v. Platinum Mgmt. (NY) LLC, No. 16-CV-6848, 2018 U.S. Dist. LEXIS 165797 (E.D.N.Y. Sept. 26, 2018). Indeed, the PI here specifically provides that the “Receiver and all personnel hired by the Receiver as herein authorized, including counsel to the Receiver and accountants, are entitled to reasonable compensation for the performance of duties pursuant to this Order, and for the cost of actual out-of-pocket expenses incurred by them, from the Assets now held by or in possession or control of, or which may be received by the Receivership Defendants.”* (Dkt. No. 184, Section XV)

1 The Blust Family Irrevocable Trust (the “Blust Trust”) was the only party to file a response in opposition to the Receiver’s Second Fee Application. (Dkt. No. 436) The Blust Trust partially opposes the Second Fee Application to the extent that assets of the Blust Trust may be used to pay the fees and expenses of the Receiver and his team. (/d.) The Blust Trust also argues that because its appeal of the Court’s Decision and Order granting the Receiver’s First Fee Application remains pending, funds from the Blust Trust should not be dissipated. (/d.) 2 The PI further authorizes the Receiver to “[c]Jhoose, engage, and employ attorneys, accountants, appraisers, and other independent contractors and technical specialists as the Receiver deems advisable or necessary in the performance of duties and responsibilities[.]” (Dkt. No. 184, Section IX.X)

The Court considers several factors in determining a reasonable fee, including "(1) the complexity of problems faced, (2) the benefits to the receivership estate, (3) the quality of the work performed, and (4) the time records presented." Platinum Mgmt. (NY) LLC, 2018 U.S. Dist. LEXIS 165797, *12 (quotations omitted). The Court may also consider "the reasonableness of the hourly rate charged and the reasonableness of the number of hours billed." SEC v. Amerindo Inv. Advisors Inc., 05 Civ. 5231, 2015 U.S. Dist. LEXIS 197890 (S.D.N.Y. Sept. 14, 2015) (citations omitted). The Court previously noted that, during the time period of the First Fee Application, the Receiver faced extremely complex factual, legal, and administrative issues in performing his duties.? (Dkt. No. 358, pgs. 3-5) These challenges have remained throughout the period of the Second Fee Application. Since March 4, 2024, the Receiver and his team have devoted substantial time and effort to stopping the expansive and excessively complicated law firm debt relief program provided by defendant StratFS, LLC and its related entities (collectively “defendants”). The Receiver’s efforts included managing the termination of the majority of defendants’ employees and the coordination of their insurance, COBRA, 401k accounts, and other benefits. Also during this period, the receiver and his team have provided continued customer support services to the over 50,000 consumers who were already enrolled in defendants’ law firm debt relief program at the time the PI was issued.

3 As this Court previously noted, the Receiver was assigned extensive duties under the PI, including managing all receivership assets; identifying any additional receivership defendants not already part of the lawsuit; managing defendants’ large and multi-layered debt relief business; making disbursements from the receivership estate as necessary; and maintaining a chain of custody of defendants’ significant records and data. (Dkt. No. 358, pgs. 3-4; Dkt. No. 184, Section IX)

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Consumer Financial Protection Bureau v. Stratfs, LLC (f/k/a Strategic Financial Solutions, LLC), (W.D.N.Y. 2024).

Consumer Financial Protection Bureau v. Stratfs, LLC (f/k/a Strategic Financial Solutions, LLC) (Consumer Financial Protection Bureau v. Stratfs, LLC (f/k/a Strategic Financial Solutions, LLC)) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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