Daly v. Federal Deposit Insurance Corporation, as Receiver for First Republic Bank

CourtDistrict Court, N.D. California
DecidedSeptember 17, 2024
Docket3:24-cv-00242
StatusUnknown

This text of Daly v. Federal Deposit Insurance Corporation, as Receiver for First Republic Bank (Daly v. Federal Deposit Insurance Corporation, as Receiver for First Republic Bank) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daly v. Federal Deposit Insurance Corporation, as Receiver for First Republic Bank, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ROBERT A. DALY, Case No. 24-cv-00242-EMC

8 Plaintiff, ORDER GRANTING IN PART AND 9 v. DENYING IN PART DEFENDANT’S MOTION TO DISMISS 10 FEDERAL DEPOSIT INSURANCE CORPORATION, 11 Docket No. 36 Defendant. 12 13 14 Plaintiff Robert A. Daly, Jr. has filed suit against the Federal Deposit Insurance 15 Corporation (“FDIC”), as receiver for First Republic Bank (“Bank”). Mr. Daly previously worked 16 for the Bank.1 According to Mr. Daly, the Bank fraudulently induced him to accept employment 17 “mere weeks before [it] failed.” Compl. ¶ 1. Now pending before the Court is the FDIC’s motion 18 to dismiss. Having considered the parties’ briefs as well as the oral argument of counsel, the 19 Court hereby GRANTS in part and DENIES in part the motion to dismiss. 20 I. FACTUAL & PROCEDURAL BACKGROUND 21 In his complaint, Mr. Daly alleges as follows. 22 Mr. Daly is a financial adviser. See Compl. ¶ 11. In late 2022, the Bank began to recruit 23 him.2 See Compl. ¶ 12. 24 1 In his complaint, Mr. Daly suggests he was an employee of the Bank. See Compl. ¶ 1. 25 However, the FDIC asserts that he was an independent contractor. See Mot. at 15; Barter Decl., Ex. A (Promoter Agreement entered into between First Republic Investment Management, Inc. (a 26 Bank affiliate) and Mr. Daly) (referring to Mr. Daly as a consultant and independent contractor).

27 2 The FDIC, as noted above, asserts that Mr. Daly was not an employee of the Bank but rather 1 Through its senior executives, the Bank made misrepresentations to Mr. Daly to induce 2 him to accept employment. Implicitly, these misrepresentations were made during the recruitment 3 process given that they were made to induce Mr. Daley to accept employment. For example, they

4 (a) repeatedly tout[ed] the Bank’s safe business model, assuring investors and prospective employees that it was strongly-positioned 5 to weather a variety of economic conditions; (b) contend[ed] that the Bank had a robust lending platform, referral network, and an 6 attractive payout for cash balances; and (c) contend[ed] that the Bank had competitive home mortgage rates and it would be 7 aggressive in winning any mortgage business. 8 Compl. ¶ 27. 9 These representations were false. 10 • For instance, when Mr. Daly presented the Bank with a customer who was 11 interested in a $95 million loan, the Bank said it was not funding large loans any 12 longer. See Compl. ¶ 17; see also Opp’n at 9 (asserting that, “during recruitment 13 Mr. Daly discussed a customer interested in a $95 million loan” and “[t]he Bank 14 Agreement describes the relationship between the Bank affiliate and Mr. Daly as follows: 15

1. Solicitation of Clients. As a consultant and independent 16 contractor, and not as an employee of Adviser [the Bank affiliate], Promoter [Mr. Daly] will use its best efforts, in accordance with 17 this Agreement, to solicit and refer as clients to Adviser those individuals or entities that it believes are suitable and appropriate 18 for the investment advisory services provided by Adviser and/or insurance services provided by Adviser’s affiliate. 19

2. Client Relationships. Promoter’s primary role under this 20 Agreement is to introduce and assist each Solicited Client in establishing a relationship with Adviser, which will include 21 introducing prospective clients and providing information about Adviser. 22

Barter Decl., Ex. A (Promoter Agreement ¶¶ 1-2). 23

Mr. Daly would be compensated “for each Solicited Client that enters into and maintains 24 an investment management agreement with Adviser,” specifically, “20% of the gross earned and collected investment advisory fees actually received by Adviser for each Solicited Client.” Barter 25 Decl., Ex. A (Promoter Agreement ¶ 6). In addition, “[f]or each Solicited Client that enters into and purchases an insurance contract with Adviser’s insurance affiliate,” Mr. Daly would be 26 “entitled to receive from the applicable insurance carrier, as the solely responsible payor, a 10% gross-dollar commission earned and vested on each insurance contract that Adviser’s affiliate and 27 Promoter mutually agree will be written for Solicited Clients.” Barter Decl., Ex. A (Promoter 1 had represented to Mr. Daly that [it] was interested in funding the customer’s loan, 2 and would be ultra-competitive in winning the business”). 3 • Also, when Mr. Daly brought a potential $18 million mortgage to the Bank, the 4 Bank effectively ensured that the business would not be won by “quot[ing] the 5 client a mortgage rate 300 bps higher than the market rate.” Compl. ¶ 18. 6 • Finally, less than two weeks after Mr. Daly accepted employment, the S&P Global 7 Ratings “downgraded the Bank’s long-term issuer credit rating and preferred stock 8 issue rating due to risks of deposit outflows leading to increased funding costs.” 9 Compl. ¶ 19. Fitch Ratings also downgraded the Bank’s credit rating on the same 10 day, “observing that ‘[the Bank’s] funding and liquidity profile has changed and 11 represents a “weakest link.”’” Compl. ¶ 19. The market responded to the 12 downgrades, with the Bank’s common stock dropping from $39.63 per share on 13 March 14, 2023, to $31.16 per share on March 15, 2023. See Compl. ¶ 20. The 14 stock continued to decline thereafter. See Compl. ¶ 20. 15 To induce Mr. Daly to accept employment, the Bank also concealed information, including 16 “the risks that rising interest rates posed to the Bank’s net interest income and net interest margin 17 and the value of the Bank’s mortgage loan portfolio.” Compl. ¶ 36. The Bank also downplayed 18 these risks publicly. See Compl. ¶ 9; see also Compl. ¶ 10 (alleging that, “in SEC filings and 19 multiple public statements, the Bank misrepresented the strength of its balance sheet, liquidity and 20 position in the market”). “[T]he Bank understated and concealed the magnitude of the risks facing 21 its business model that would result from any decision by the Federal Reserve System raising the 22 federal funds rate, thereby undermining the value of the Bank’s loan and securities portfolios and 23 liquidity.” Compl. ¶ 10. 24 As a result of (1) the misrepresentations and (2) the omission of material facts, Mr. Daly 25 joined the Bank on March 3, 2023. See Compl. ¶ 16. But, as noted above, less than two weeks 26 after Mr. Daly joined, the S&P Global Ratings and Fitch Ratings downgraded, inter alia, the 27 Bank’s credit rating which led to a decline in the value of the Bank’s stock. 1 with the FDIC. The Bank’s common stock dropped again, this time from $6.19 per share on April 2 27, 2023, to $3.51 per share on April 28, 2023. See Compl. ¶ 22. 3 On May 1, 2023, the FDIC became the receiver for the Bank, and JPMorgan Chase took 4 over the Bank.3 See Compl. ¶¶ 2, 23. 5 On May 2, 2023, the NYSE announced that it was suspending trading in the Bank’s shares 6 and started proceedings to delist the shares. See Compl. ¶ 23. Mr. Daly resigned from the Bank 7 that day. See Compl. ¶ 24. 8 “From the time Mr. Daly joined the Bank on March 3, 2023, until the Bank was seized by 9 the FDIC on May 1, 2023, the Bank continued to falsely represent to Mr. Daly that the Bank was 10 not going to go into receivership and that Mr. Daly would be foolish to leave.” Compl. ¶ 25. 11 After the FDIC became the receiver, Mr. Daly filed a proof of claim with the agency 12 “pursuant to the procedures provided in the Financial Institutions Reform and Recovery and 13 Enforcement Act (‘FIRREA’).” Compl. ¶ 7. On November 16, 2023, the FDIC disallowed the 14 claim. See Compl. ¶ 7. Mr. Daly then initiated this lawsuit on January 12, 2024. 15 Based on, inter alia, the above allegations, Mr. Daly has asserted the following causes of 16 action: 17 (1) Intentional misrepresentation. 18 (2) Fraudulent concealment. 19 (3) Negligent misrepresentation. 20 (4) Promissory fraud.

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Daly v. Federal Deposit Insurance Corporation, as Receiver for First Republic Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daly-v-federal-deposit-insurance-corporation-as-receiver-for-first-cand-2024.