In re Debtor Cachet Financial Services

CourtDistrict Court, C.D. California
DecidedFebruary 6, 2023
Docket2:21-cv-08778
StatusUnknown

This text of In re Debtor Cachet Financial Services (In re Debtor Cachet Financial Services) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Debtor Cachet Financial Services, (C.D. Cal. 2023).

Opinion

Case 2:21-cv-08778-FLA Document 20 Filed 02/06/23 Page 1 of 18 Page ID #:789

JS-6 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 IN RE CACHET FINANCIAL Case No. 2:21-cv-08778-FLA 11 SERVICES, A CALIFORNIA Bankr. Case No. 2:20-bk-10654-VZ 12 CORPORATION, Adv. Pro. Case No. 2:21-ap-01187-VZ

13 Debtor/Plaintiff ORDER DENYING DEFENDANT’S 14 v. MOTION TO WITHDRAW REFERENCE OF ADVERSARY 15 PROCEEDING TO BANKRUPTCY THE BANCORP BANK, A COURT [DKT. 1] 16 DELAWARE-CHARTERED 17 BANKING INSTITUTION, Defendant. 18

19 20

21 22 23 24 25 26 27 28

1 Case 2:21-cv-08778-FLA Document 20 Filed 02/06/23 Page 2 of 18 Page ID #:790

1 RULING 2 Before the court is Defendant The Bancorp Bank’s (“Bancorp” or “Defendant”) 3 Motion to Withdraw Reference of Adversary Proceeding to Bankruptcy Court 4 (“Motion”). Dkt. 1 (“Mot.”). Debtor and Plaintiff Cachet Financial Services 5 (“Cachet” or “Plaintiff”) opposes the Motion. Dkt. 10 (“Opp’n”). On January 23, 6 2022, the court found this matter appropriate for resolution without oral argument and 7 vacated the hearing set for January 28, 2022. Dkt. 14; see Fed. R. Civ. P. 78(b); Local 8 Rule 7-15. 9 On September 25, 2022, Defendants Dime Community Bank (“Dime Bank”), 10 John Romano (“Romano”), and Yuriy Rubinov (“Rubinov”) filed a collective Joinder 11 to Bancorp’s Motion. Dkt. 18. 12 For the reasons stated herein, the court DENIES Bancorp’s Motion in its 13 entirety.1 14 BACKGROUND 15 I. Factual Background2 16 Cachet was a national financial services company focused on processing 17 Automated Clearing House (“ACH”) transactions and providing related services in the 18 payroll industry. AP FAC ¶ 5. Cachet contracted with payroll processing companies, 19 referred to as “Remarketers,” under Remarketer Agreements to provide payroll ACH 20 transactions. Id. ¶ 40. Bancorp is a Delaware chartered commercial bank and a 21 22 1 For purposes of this Motion, the court will cite filings in: (1) In re Debtor Cachet Financial Services, Case No. 2:20-bk-10654-VZ (Bankr. C.D. Cal.) (the “Bankruptcy 23 Action”) as “BA Dkt. #”; (2) Cachet Financial Services v. The Bancorp Bank et al., 24 Case No. 2:21-ap-01187-VZ (Bankr. C.D. Cal.) (the “Adversary Proceeding”) as “AP Dkt. #”; and (3) The Bancorp Bank v. Advanced Payroll Solutions, Inc. et al., Case 25 No. 1:19-cv-02088-MN (D. Del.) (the “Interpleader Action”) as “IA Dkt. #.” 26 2 On May 31, 2022, Cachet filed a First Amended Complaint (“FAC”) in the 27 Adversary Proceeding. AP Dkt. 11 (“AP FAC”). These factual allegations are stated in this Order only to provide background regarding the parties’ dispute and do not 28 represent findings of fact by this court.

2 Case 2:21-cv-08778-FLA Document 20 Filed 02/06/23 Page 3 of 18 Page ID #:791

1 Federal Deposit Insurance Corporation (“FDIC”) insured institution. Id. ¶ 6. Bancorp 2 is also an Originating Depository Financial Institution (“ODFI”) that is permitted to 3 conduct ACH transactions pursuant to the National Automated Clearing House 4 Association (“NACHA”). Id. On or around August 4, 2010, Cachet and Bancorp 5 entered into an ODFI Agreement (“ODFI Agreement”), whereby Bancorp agreed to 6 act as Cachet’s ODFI and facilitate Cachet’s ACH transactions for Cachet’s 7 Remarketer clients. AP FAC ¶ 45; Dkt. 1-2 (“Summers Decl.”), Ex. A. 8 Cachet alleges that beginning in the summer and fall of 2019, several of its 9 clients engaged in fraudulent conduct that led ultimately to the parties’ dispute. See 10 AP FAC ¶¶ 53–57, 67–101. According to Cachet, around August and September of 11 2019, Cachet’s client, MyPayroll HR (“MPHR”), and its principal, Michael Mann 12 (“Mann”), “manipulated” and/or “altered” Cachet’s batch file specifications—“the 13 instructions that dictate the direction, timing and flow of funds”—to steal more than 14 $26 million from Cachet’s accounts (the “MPHR Incident”). Id. ¶¶ 53–56; BA Dkt. 15 511 (Am. Disclosure State.) at 5–6. 16 Around October 2019, Bancorp informed Cachet about suspicious activity 17 occurring with another of Cachet’s clients’ accounts. AP FAC ¶¶ 67–102. Cachet 18 alleges Joshua Rothenberg (“Rothenberg”) and/or Henry Kauftheil (“Kauftheil”) 19 caused batch files to be uploaded to Cachet’s servers that caused the disbursement of 20 approximately $21 million from Cachet’s settlement account to accounts controlled by 21 Cachet’s clients DD Care Management LLC, a New York limited liability company, 22 and DD Care Management LLC, a Florida limited liability company (collectively, 23 “DD Care”), without a corresponding credit to Cachet’s accounts, resulting in a multi- 24 million-dollar theft (the “DD Care Incident”).3 Id.; BA Dkt. 511 at 7. According to 25 Cachet, this was the result of an ongoing fraudulent scheme perpetrated by 26

27 3 Rothenberg, Kauftheil, and DD Care are Defendants in the Adversary Proceeding. 28 AP FAC ¶¶ 7–11.

3 Case 2:21-cv-08778-FLA Document 20 Filed 02/06/23 Page 4 of 18 Page ID #:792

1 Rothenberg and Kauftheil, assisted by Defendant Dime Bank. AP FAC ¶¶ 62–102. 2 On October 23, 2019, Bancorp unilaterally terminated the ODFI Agreement 3 with Cachet and froze the funds in Cachet’s accounts with Bancorp (the “Stake”). Id. 4 ¶ 107. In the Notice of Termination letter, Bancorp stated Cachet “reversed 5 approximately $26 million in ACH credit transactions to employee and corporate 6 accounts associated with MPHR, due to MPHR’s failure to fund such transactions,” in 7 violation of NACHA rules. Summers Decl., Ex. B. According to Bancorp, this 8 resulted in “(i) a funding exposure of $26 million, (ii) Bancorp being compelled to 9 report the matter to its banking regulator, the [FDIC], (iii) Bancorp issuing letters of 10 indemnity to over 1,100 RDFIs, and (iv) NACHA assessing fines totaling $200,000, 11 to date, against Bancorp.” Id. Bancorp also claimed Cachet failed to implement 12 controls to ensure it would not originate credit transactions to its clients unless such 13 transactions were pre-funded, as it had promised following the MPHR Incident, 14 exposing Bancorp to additional financial risk during the DD Care Incident. Id. 15 On November 5, 2019, Bancorp filed the Interpleader Action in the United 16 States District Court for the District of Delaware (the “Delaware District Court”), 17 requesting leave to deposit the Stake with the court, an order discharging Bancorp 18 from liability related to the Stake, and the distribution of the funds to claimants 19 through interpleader proceedings. Dkt. 11-5 (Cachet RJN, Ex. 5). 20 Cachet contends Bancorp’s termination of the ODFI Agreement and Cachet's 21 ability to originate ACH transactions constituted a breach of the agreement. Id. 22 ¶¶ 107–112. According to Cachet, Bancorp engaged in tortious conduct by freezing 23 the funds in Cachet’s accounts with Bancorp, removing and disbursing these funds 24 without authorization, and blocking Cachet’s access to its bank and Remarketer client 25 account information. Id. ¶¶ 104–09; see also BA Dkt. 511 (Am. Disclosure State.) at 26 7. As a result, Cachet was allegedly unable to process ACH transactions for its 27 clients, forced to cease operations as an ACH processor, and became subject to 28 numerous lawsuits from Remarketers, employers, and employees. AP FAC ¶ 120; BA

4 Case 2:21-cv-08778-FLA Document 20 Filed 02/06/23 Page 5 of 18 Page ID #:793

1 Dkt. 511 at 4. 2 Bancorp asserts it validly exercised its option to terminate the ODFI Agreement 3 for safety and soundness reasons, under § 5.2 of the agreement. Dkt. 1-1 (“Mot. Br.”) 4 at 4–5.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
In re Debtor Cachet Financial Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-debtor-cachet-financial-services-cacd-2023.