PICARD, Trustee for the Liquidation of Bernard L. v. SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f

CourtUnited States Bankruptcy Court, S.D. New York
DecidedSeptember 19, 2022
Docket12-01677
StatusUnknown

This text of PICARD, Trustee for the Liquidation of Bernard L. v. SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f (PICARD, Trustee for the Liquidation of Bernard L. v. SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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PICARD, Trustee for the Liquidation of Bernard L. v. SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f, (N.Y. 2022).

Opinion

--------------------------------------------------------- x In re:

:

: Chapter SIPA Bernard L. Madoff Investment Securities : Case No. 08-01789 LLC, :

Debtor(s). -------------------------------------------------x IRVING H. PICARD, Trustee for the Liquidation of Bernard L. Madoff Investment Securities LLC, Adv. No. 12-01677

v.

SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f/k/a SG Private Banking Suisse S.A.), et al. -------------------------------------------------x

Memorandum Decision Memorializing Oral Ruling upon Record of the September 19, 2022 Hearing

BACKGROUND: On April 29, 2022, the Defendants, OFI MGA Alpha Palmares (“OFI”), Oval Palmares Europlus (“Palmares”) and UMR Select Alternatif (“UMR”) (collectively, the “OFI Funds” or “Defendants”), filed a motion to dismiss. The first argument is that the OFI Funds have no legal existence and lack the capacity to be sued. They also argue that the Court lacks personal jurisdiction over the OFI Finds and that the safe harbor applied to the transfers. The Trustee opposed the motion. The Court held oral argument on the issue of whether the OFI Funds have capacity to be sued on September 19, 2022. The parties waived oral argument on all other issues. See Stip., ECF No. 185. The Court issued an oral ruling upon record of that hearing. This is a memorialization of that oral ruling. The Court assumes familiarity with the background of the BLMIS Ponzi scheme and its SIPA proceeding. See Picard v. Citibank, N.A. (In re BLMIS), 12 F.4th 171, 178–83 (2d Cir. 2021), cert. denied sub nom. Citibank, N.A. v. Picard, 142 S. Ct. 1209, 212 L. Ed. 2d 217 (2022). SUMMARY OF THE LAW: Whether the OFI Funds exist?

Rule 17 of the Federal Rules of Civil Procedure requires that an action “be prosecuted in the name of the real party in interest.” Fed. R. Civ. P. 17(a). Defendants argue that they do not legally exist under French law. According to the motion, the Defendants are “fonds commun de placement” (“FCP”). The motion to dismiss states: Under French law, an FCP has no legal personality. Lecuyer Dec. ¶ 15 (citing Monetary and Financial Code, Art L. 214-8). An FCP is a co-ownership of financial instruments and is a unique form of investment vehicle. Id. at ¶ 16. An FCP is different from a corporation, partnership, association or other form of business entity. Id. at ¶ 17. An FCP has no officers or employees of its own. Id.

at ¶ 21. An FCP is an undivided pool of assets managed exclusively by a management company on behalf of investors who purchase redeemable non- voting units in the FCP. Id. at ¶ 30. The investors are generally referred to as “unit holders.” Id. An FCP is established by a contract between the management company and the custodian bank, both of which create the fund’s regulations. Id. at ¶ 39 (citing Monetary and Financial Code, Art L. 214-8-1). The purchase by an investor of units in an FCP constitutes acceptance by the investor of the FCP’s regulations. Id. at ¶ 31 (citing Monetary and Financial Code, Art L. 214-8-1). The assets of the FCP must be kept in a custodian bank account which is separate and apart from management company accounts. Id. at ¶ 32 (citing Monetary and Financial Code, Art L. 214-9). The

management company has the exclusive right to manage the FCP. Id. at ¶ 40 (citing Monetary and Financial Code, Art L. 214-8). The management company has no interest in the assets of the FCP. Id. The FCP units acquired by an investor represent that investor’s pro rata right in the undivided collection of assets held by the custodian bank. Id. at ¶ 34. The unit holders are liable for the FCP’s debts only to the extent of the FCP’s assets and in proportion to their own pro rata share. Id. at ¶ 35 (citing Monetary and Financial Code, Art L. 214-8-5). In other words, the liability of the unit holders is several, not joint, and each unit holder is only liable for the amount of his individual share of the pooled assets. Id.

In support of this reading of French law, the “non-existent” OFI Funds have submitted the declaration of Herve Lecuyer, a professor at University Panthéon-Assas (Paris 2). Decl. LeCuyer ¶ 1, ECF No. 140. The Court issued an OSC against the OFI Funds and Brian Butler, purported attorney for the Funds. He argues that the OFI Asset Management Company, a management company under French law, authorized it to act on behalf of the OFI Funds. “FCPs have no legal personality and require a management company to take virtually all actions on their behalf, including filing lawsuits.” In re Vivendi Universal, S.A. Sec. Litig., 605 F. Supp. 2d 570, 580 (S.D.N.Y. 2009); see also CODE MONÉTAIRE ET FINANCIER (MONETARY AND FINANCIAL CODE) art. L214-8-8 (“The mutual fund is represented vis-à-vis third parties by the company in charge of its management. This company may take legal action to defend or assert the rights or interests of unitholders.”).1 “FCPs retain ownership of the funds[’] assets and operate similar to

trusts.” Id. The Trustee argues that the OFI Funds can be sued though they must be represented by a management company in court. He has no objection to the management company participating on behalf of the OFI Funds in this action. The Trustee has provided the declaration of Oliver Moriceau, a French attorney. Morceau Decl. ¶ 155, ECF No. 155. Moriceau states that French law vests the management company with authority to act on behalf of an FCP in court. Id. ¶ 6. He also provides examples of case where FCP’s filed lawsuits in U.S. Courts in their own names—though the papers were filed under the authority of OFI Asset Management, the same asset manager that represents the OFI Defendants here. Id. ex. A.

The Court agrees with Moriceau’s interpretation of the French Monetary and Financial Code, which state: “The mutual fund is represented vis-à-vis third parties by the company in charge of its management.” CODE MONÉTAIRE ET FINANCIER (MONETARY & FINANCIAL CODE) art. L214-8-8. The French law does not state that the OFI Funds cannot sue or be sued but only that a management company “may take legal action to defend or assert the rights or interests of unit holders.” Id. In this case, the OFI Defendants are the “real part[ies] in interest” (Fed. R. Civ. P. 17(a)), they are represented by attorneys who were engaged by the management company

1 Available at https://www.legifrance.gouv.fr/codes/section_lc/LEGITEXT000006072026/LEGISCTA000006154126?etatTexte= VIGUEUR&etatTexte=VIGUEUR_DIFF&anchor=LEGISCTA000006154126#LEGISCTA000006154126 to defend the OFI Defendants in this action. This is exactly how the French law contemplates legal actions against FCP’s to go. Personal Jurisdiction The OFI Funds argue that this Court lacks personal jurisdiction over them. The

Trustee has provided evidence that the Defendants received the transfers in a New York bank account. The Trustee relies on the subscription agreements and the use of a New York bank account for the assertion of jurisdiction over the OFI Funds. To survive a motion to dismiss for lack of personal jurisdiction pursuant to Rule 12(b)(2) of the Federal Rules of Civil Procedure, the Trustee “must make a prima facie showing that jurisdiction exists.” SPV Osus Ltd. v. UBS AG, 882 F.3d 333, 342 (2d Cir. 2018) (quoting Penguin Grp. (USA) Inc. v. Am. Buddha, 609 F.3d 30

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PICARD, Trustee for the Liquidation of Bernard L. v. SOCIETE GENERALE PRIVATE BANKING (SUISSE) S.A. (f, Counsel Stack Legal Research, https://law.counselstack.com/opinion/picard-trustee-for-the-liquidation-of-bernard-l-v-societe-generale-nysb-2022.