In the Matter of the Liquidation of Freestone Insurance Company

CourtCourt of Chancery of Delaware
DecidedDecember 24, 2014
DocketCA 9574-VCL
StatusPublished

This text of In the Matter of the Liquidation of Freestone Insurance Company (In the Matter of the Liquidation of Freestone Insurance Company) 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 the Matter of the Liquidation of Freestone Insurance Company, (Del. Ct. App. 2014).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

IN THE MATTER OF THE ) LIQUIDATION OF FREESTONE ) C.A. No. 9574-VCL INSURANCE COMPANY )

MEMORANDUM OPINION

Date Submitted: October 30, 2014 Date Decided: December 24, 2014

Eric Lopez Schnabel, Robert W. Mallard, Alessandra Glorioso, DORSEY & WHITNEY LLP, Wilmington, Delaware; Michael R. Stewart, Michael B. Fisco, FAEGRE BAKER DANIELS LLP, Minneapolis, Minnesota; Attorneys for U.S. Bank National Association.

Christopher P. Simon, Joseph Grey, CROSS AND SIMON, LLC, Wilmington, Delaware; James J. Black, III, Jeffrey B. Miceli, Mark Drasnin, BLACK & GERNGROSS, P.C., Philadelphia, Pennsylvania; Attorneys for the Insurance Commissioner of the State of Delaware as Receiver for Freestone Insurance Company.

LASTER, Vice Chancellor. Freestone Insurance Company (“Freestone”), a Delaware-domiciled insurer, is

currently in receivership under the administration of the Insurance Commissioner of the

State of Delaware (the “Commissioner”). When delinquency proceedings began,

Freestone maintained cash and securities valued at approximately $175 million (the

“Assets”) in a custodial account at U.S. Bank, N.A. As part of the delinquency

proceedings, the court entered an order directing that Freestone be rehabilitated, causing

title to Freestone’s property to vest in the Commissioner as receiver. The court’s

rehabilitation order directed the Commissioner to marshal Freestone’s assets and called

upon third parties to turn over property belonging to Freestone to the Commissioner.

Relying on the rehabilitation order and the authority conferred by the Delaware

Uniform Insurance Liquidation Act (“DUILA”), the Commissioner terminated the

custodial relationship and instructed U.S. Bank to return the Assets. U.S. Bank turned

over approximately $19 million but kept the rest, contending it was security for potential

indemnification claims and present and future expenses. The Commissioner disputed

U.S. Bank’s position and threatened to seek to hold U.S. Bank in contempt of the

rehabilitation order. U.S. Bank then filed the current motion, which seeks an order

establishing its right to retain the Assets or, alternatively, declaring that any amounts

turned over to the Commissioner will be subject to a security interest.

U.S. Bank’s request for an order establishing its right to retain the Assets is

denied. U.S. Bank shall turn over the Assets to the Commissioner. Before doing so, U.S.

Bank may deduct from the Assets the fees and expenses it has incurred for administering

the account. U.S. Bank may not deduct legal expenses. If U.S. Bank chooses not to make

1 a deduction, it shall have a security interest in the Assets equal to the amount of fees and

expenses incurred for administering the account. U.S. Bank is not entitled to retain the

Assets or to have a security interest in the Assets for indemnification claims or future

expenses.

I. FACTUAL BACKGROUND

The factual background is drawn from the submissions made by the parties in

connection with U.S. Bank’s motion. The relevant facts consist of a series of undisputed

events and the details of certain agreements.

A. The Custody Agreement

U.S. Bank held the Assets for Freestone pursuant to an Insurance Custody

Agreement dated July 25, 2013 (the “Custody Agreement” or “CA”). Under the Custody

Agreement, U.S. Bank’s duties were ministerial in nature, see id. § 9, and U.S. Bank had

“no duties or responsibilities except those specifically set forth” in the Custody

Agreement, id. § 1(e). U.S. Bank held the Assets “subject to the instructions of

[Freestone],” and the Assets could be withdrawn “upon the demand of [Freestone].” Id. §

2(b).

In Section 12 of the Custody Agreement, Freestone agreed to “(i) reimburse [U.S.

Bank] for costs incurred by it hereunder, and (ii) pay to [U.S. Bank] fees for its services

under this Agreement . . . .” Id. § 12(a). Under Section 14 of the Custody Agreement,

Freestone agreed to indemnify U.S. Bank and its agents for any “Claim,” defined broadly

to include any cost, loss, claim, liability, or fee arising out of the agreement. Id. § 14(a).

Under Section 17 of the Custody Agreement, “[a]ny fees or expenses [U.S. Bank] incurs

2 in responding to any Legal Action (including, without limitation, attorneys’ and other

professionals’ fees) [could] be charged against the Account.” Id. § 17(l). The term “Legal

Action” was defined to include any “subpoena, restraining order, writ of attachment or

execution, levy, garnishment, search warrant or similar order relating to the Account.” Id.

Under Section 15(a) of the Custody Agreement, either party could terminate the

relationship upon 30 days written notice. Id. § 15(a). At that point, U.S. Bank was

obligated to

follow reasonable [Freestone] instructions concerning the transfer of the Assets; provided that:

....

(ii) Unless required by proper regulatory agency, [U.S. Bank] shall not be required to make any delivery or payment until full payment shall have been made by [Freestone] of all liabilities constituting a charge on or against [U.S. Bank] and until full payment shall have been made to [U.S. Bank] of all its compensation, costs and expenses hereunder; and

(iii) [U.S. Bank] shall have been reimbursed for any advances of monies or securities made hereunder to [Freestone] . . . .

Id. § 15(b).

B. The Commissioner Demands The Return Of The Assets

On April 24, 2014, the Commissioner filed delinquency proceedings against

Freestone. By order dated April 28, 2014, the court placed Freestone into rehabilitation.

Dkt. 4 (the “Rehabilitation Order”). The Rehabilitation Order instructed the

Commissioner to take “exclusive possession and control of” Freestone’s property. Id. ¶ 6.

To facilitate the Commissioner’s efforts, the Rehabilitation Order instructed parties

holding Freestone’s property to turn it over to the Commissioner. Id. ¶ 13.

3 In May 2014, the Commissioner demanded the return of the Assets. U.S. Bank

turned over cash and securities worth approximately $19 million, but kept the remaining

$156 million. U.S. Bank justified its refusal on the theory that it may face potential

claims arising out of its services to Freestone or otherwise be drawn into litigation

involving Freestone. If that happens, then U.S. Bank anticipates making a claim for

indemnification against Freestone under the Custody Agreement. U.S. Bank also

anticipates incurring expenses as it continues to maintain the account.

In addition to its right to indemnification under the Custody Agreement, U.S.

Bank cited trust agreements pursuant to which U.S. Bank held assets to secure

obligations between Freestone and other insurance companies (the “Trust Agreements”).

In each case, either Freestone or another insurance company acted as a reinsurer, and

U.S. Bank held the assets in trust to secure the insurer’s right to payment from the

reinsurer. U.S. Bank provided examples of three Trust Agreements:

● The White Rock Trust Agreement. Pursuant to a trust agreement dated January 1, 2012, White Rock Insurance (SAC) Ltd (“White Rock”) deposited cash and securities with U.S. Bank for the benefit of Freestone. U.S. Bank’s duties and responsibilities under the agreement were “entirely administrative and not discretionary and determined only with reference to this Agreement and Applicable Insurance Law.” Id. § 8(n).

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