In Re: Appraisal of DFC Global Corp

CourtCourt of Chancery of Delaware
DecidedJuly 8, 2016
DocketCA 10107
StatusPublished

This text of In Re: Appraisal of DFC Global Corp (In Re: Appraisal of DFC Global Corp) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Appraisal of DFC Global Corp, (Del. Ct. App. 2016).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

IN RE APPRAISAL OF DFC GLOBAL CONSOLIDATED CORP. C.A. No. 10107-CB

MEMORANDUM OPINION

Date Submitted: April 28, 2016 Date Decided: July 8, 2016

Geoffrey C. Jarvis and Kimberly A. Evans, GRANT & EISENHOFER P.A., Wilmington, Delaware; Attorneys for Petitioners.

Raymond J. DiCamillo, Susan M. Hannigan and Rachel E. Horn, RICHARDS, LAYTON & FINGER, P.A., Wilmington, Delaware; Meryl L. Young and Colin B. Davis, GIBSON, DUNN & CRUTCHER LLP, Irvine, California; Attorneys for Respondent DFC Global Corporation.

BOUCHARD, C. In this appraisal action, former stockholders of DFC Global Corporation

(“DFC”) petitioned the Court to appraise the fair value of shares they held when

the company was sold to a private equity buyer, Lone Star Fund VIII (U.S.), L.P.

(“Lone Star”) for $9.50 per share in June 2014. Petitioners allege that DFC was

sold at a discount to its fair value during a period of regulatory uncertainty that

temporarily depressed the market value of the company. Using a discounted cash

flow model based on management’s most recent five-year projections, petitioners’

expert calculated a fair value of $17.90 per share. Respondent’s expert used a

discounted cash flow model and a multiples-based comparable companies analysis,

blending the two to calculate a much lower fair value of $7.94 per share.

Respondent also urges the Court to consider the transaction price of $9.50 per

share as the most reliable evidence of fair value.

Although this Court frequently defers to a transaction price that was the

product of an arm’s-length process and a robust bidding environment, that price is

reliable only when the market conditions leading to the transaction are conducive

to achieving a fair price. Similarly, a discounted cash flow model is only as

reliable as the financial projections used in it and its other underlying assumptions.

The transaction here was negotiated and consummated during a period of

significant company turmoil and regulatory uncertainty, calling into question the

reliability of the transaction price as well as management’s financial projections.

1 Thus, neither of these proposed metrics to value DFC stands out as being

inherently more reliable than the other.

In this opinion I conclude that the most reliable determinant of fair value of

DFC’s shares is a blend of three imperfect techniques: a discounted cash flow

model incorporating certain methodologies and assumptions each expert made and

some of my own, the comparable company analysis respondent’s expert

performed, and the transaction price. Giving each equal weight, I conclude that the

fair value of DFC’s shares when the transaction closed was $10.21 per share.

I. BACKGROUND

The facts recited in this opinion are my findings based on the stipulations of

the parties, documentary evidence, and testimony presented at trial. I accord the

evidence the weight and credibility I find it deserves.

A. The Parties

Respondent DFC is a Delaware corporation with headquarters in

Pennsylvania. DFC’s business focuses on alternative consumer financial services,

colloquially known as payday lending. DFC was publicly traded on the NASDAQ

exchange from 2005 until it was acquired by an indirect subsidiary of Lone Star in

a merger transaction (the “Transaction”).1

1 Stipulated Joint Pre-Trial Order (“PTO”) ¶¶ 1, 41-44.

2 Petitioners Muirfield Value Partners, LP, Candlewood Special Situations

Master Fund, Ltd., CWD OC 522 Master Fund, Ltd., Oasis Investments II Master

Fund Ltd., and Randolph Watkins Slifka were stockholders of DFC at the time of

the Transaction. Petitioners collectively hold 4,604,683 shares of DFC common

stock that are eligible for appraisal.2

B. DFC Faces Regulatory and Business Uncertainty

As of mid-2013, DFC was operating its payday lending business in ten

countries through more than 1,500 retail storefront locations and internet

platforms. 3 DFC faced significant competition in each of the countries in which it

operated, although the nature of the competition varied from market to market.4

DFC also was subject to regulations from different regulatory authorities across its

markets. 5 One of the key risks DFC faced was the potential for changes to those

regulations that could increase the cost of doing business or otherwise limit the

company’s opportunities.6

2 PTO ¶¶ 12, 19, 24, 25, 30, 35. 3 JX 295 at 4. 4 Id. at 17. 5 See id. at 18-22. 6 Id. at 24-26.

3 In the United States, for instance, the Consumer Financial Protection Bureau

began to supervise and regulate DFC. The company was unable to predict whether

and to what extent the Consumer Financial Protection Bureau would impose new

rules and regulations on it, which had the potential to adversely affect DFC’s

business in the United States. 7

In the United Kingdom, DFC faced an even greater amount of regulatory

uncertainty as a new regulator, the Financial Conduct Authority (the “FCA”),

prepared to take over regulation of the payday lending industry, effective April 1,

2014. 8 Before then, the Office of Fair Trading (the “OFT”) was DFC’s regulator

in the U.K.

In February 2012, the OFT began an in-depth review of some of the largest

firms in the payday lending business to assess compliance with the Consumer

Credit Act and the OFT’s “irresponsible lending guidance.”9 In November 2012,

the OFT issued debt collection guidance requiring payday lenders to make

disclosures to consumers regarding the use of continuous payment authority and to

avoid using continuous payment authority to collect money from customers who

7 Id. at 26. 8 JX 490 at 30. 9 PTO ¶ 64.

4 were believed to be experiencing financial hardship. 10 Continuous payment

authority is a mechanism by which lenders seek to automatically collect on loans

by continuously accessing customers’ checking accounts in order to withdraw

funds shortly after they appear in the account. 11

In March and April 2013, the OFT sent letters to each of DFC’s U.K.

businesses identifying deficiencies in their businesses and requiring corrective

action. 12 This regulatory environment imposed certain transitional difficulties on

DFC. In an earnings release on April 1, 2013, the company cut earnings guidance

for the fiscal year (ending June 30) from $2.35-$2.45 per share to $1.70-$1.80 per

share, noting that the transition period was causing liquidity problems for

consumers in the United Kingdom, resulting in heightened loan default rates. 13

In August 2013, DFC provided fiscal year 2014 adjusted EBITDA guidance

of $200-240 million, noting that it was providing adjusted EBITDA rather than

earnings per share until DFC had “clearer visibility as to the amount and timing of

these [regulatory] issues.”14 DFC announced that it expected to operate “at a

10 Id. ¶ 72. 11 See Trial Tr. (“Tr.”) 15-16 (Gavin), 412-13 (Kaminski); JX 565 at 4. 12 PTO ¶ 77. 13 Id. ¶ 79. 14 JX 290 at 8.

5 continuing competitive disadvantage in the United Kingdom until all industry

providers are required to operate consistently under the new regulatory

framework.” 15 The company also stated, on the other hand, that it was hopeful that

its market share would increase as some lenders began to face difficulties operating

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In Re: Appraisal of DFC Global Corp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-appraisal-of-dfc-global-corp-delch-2016.