Steel River Systems, LLC v. Variant Alternative Income Fund, Pier Special Opportunities Fund, LP, and Greenhill Debt Management, LLP

CourtDistrict Court, S.D. New York
DecidedSeptember 3, 2025
Docket1:24-cv-08676
StatusUnknown

This text of Steel River Systems, LLC v. Variant Alternative Income Fund, Pier Special Opportunities Fund, LP, and Greenhill Debt Management, LLP (Steel River Systems, LLC v. Variant Alternative Income Fund, Pier Special Opportunities Fund, LP, and Greenhill Debt Management, LLP) is published on Counsel Stack Legal Research, covering District 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.

Bluebook
Steel River Systems, LLC v. Variant Alternative Income Fund, Pier Special Opportunities Fund, LP, and Greenhill Debt Management, LLP, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

---------------------------------------X

STEEL RIVER SYSTEMS, LLC,

Plaintiff, MEMORANDUM AND ORDER

- against – 24 Civ. 8676 (NRB)

VARIANT ALTERNATIVE INCOME FUND, PIER

SPECIAL OPPORTUNITIES FUND, LP, and GREENHILL DEBT MANAGEMENT, LLP,

Defendants.

NAOMI REICE BUCHWALD UNITED STATES DISTRICT JUDGE

Plaintiff Steel River Systems, LLC (“Steel River”) filed this action against defendants Variant Alternative Income Fund (“Variant”), Pier Special Opportunities Fund, LP (“Pier”), and Greenhill Debt Management, LLP (“Greenhill”) (together, “defendants”) on November 14, 2024. ECF No. 1 (“Compl.”). The next day, Steel River filed an emergency motion seeking a temporary restraining order (“TRO”) and injunctive relief in connection with Variant’s planned sale of plaintiff’s assets under the Uniform Commercial Code (“UCC”), contending that the sale was unlawful because it arose from, and would further defendants’ collection of, usurious and illegal loans. ECF Nos. 3-5. Shortly thereafter, Variant filed a letter agreeing to halt the sale pending resolution of plaintiff’s claims. ECF No. 18. After holding a conference with the parties, the Court issued an Order denying plaintiff’s motion for a TRO as moot, but deferring a decision on plaintiff’s motion for a preliminary injunction pending further briefing from the parties. ECF No. 27. Now pending before this Court are: (1) defendant’s motion to dismiss plaintiff’s complaint, ECF Nos. 41-43; and (2) plaintiff’s

motion for a preliminary injunction enjoining Variant from issuing any additional UCC actions during the pendency of this case, ECF Nos. 3-5. BACKGROUND1 I. Factual Background Steel River is a limited liability company specializing in debt collection, debt purchasing, and master account servicing. Compl. ¶ 1. In March 2022, Greenhill, which acts as an intermediary between lenders and borrowers in the credit and collection industry, approached Steel River with an offer to facilitate a deal. Id. ¶¶ 9-10. Under the proposed arrangement,

1 The relevant facts are drawn from the complaint, Compl., the exhibits attached thereto, Compl., Exs. A-C, and the documentary evidence submitted in connection with plaintiff’s motion for a preliminary injunction, ECF No. 5, Exs. 1-4. See Mullins v. City of New York, 626 F.3d 47, 52 (2d Cir. 2010) (holding that a court may rely on affidavits, depositions, sworn testimony, and hearsay evidence in considering a motion for a preliminary injunction). For the purposes of the instant motion to dismiss, all nonconclusory allegations are accepted as true, Matson v. Bd. of Educ. of City School Dist. of N.Y., 631 F.3d 57, 63 (2d Cir. 2011), and the Court draws all reasonable inferences in plaintiff’s favor, Koch v. Christie’s Int’l PLC, 699 F.3d 141, 145 (2d Cir. 2012).

-2- Variant, a private equity firm and lender, and Pier, a hedge fund and responsive liquidity provider, would lend funds to Steel River to enable it to purchase additional debt portfolios from creditors or secondary sellers. Id. ¶¶ 9-13, 16, 20-23. Steel River would own the receivables and serve as the master servicer in collecting the debts, and Greenhill would serve as the “Manager” of the

agreement. Id. ¶¶ 17-18. Before entering into an agreement, the parties shared projections estimating the total amounts that would be collected on the various purchased portfolios. Id. ¶ 34. All projections estimated that Variant and Pier would receive collections totaling more than 25% of the loan principal for every loan. Id. ¶ 35. On December 22, 2022, the parties entered into a Loan and Servicing Agreement and related promissory note for $2,418,797.84, both of which mirrored the structure proposed by Greenhill. Id. ¶¶ 19, 32; see Compl., Ex. A at 1-150.2 The promissory note had a stated maturity date of December 22, 2024, and provided for a

2 This Agreement contains a forum selection clause, which provides: Any legal action or proceeding with respect to any Loan Document shall be brought exclusively in the courts of the State of New York located in the City of New York, or of the United States of America for the Southern District of New York and, by execution and delivery of this Agreement, each party hereto executing this Agreement hereby accepts for itself and in respect of its property, generally and unconditionally the jurisdiction of the aforesaid courts[.] Loan Agreement § 12.14.

-3- preferred return to Variant and Pier of 115% of the initial principal amount, due 18 months from the funding date of December 22, 2022. See Compl., Ex. A at 2-6 (“Promissory Note dated Dec. 22, 2022”). The promissory note also provided for servicing fees payable to Steel River, consisting of a percentage of the gross collections from the Financed Accounts purchased with the note

proceeds, which would continue until the stated maturity date. Id. at 6.3 The parties agreed that each future loan made under this Loan and Servicing Agreement would be secured by a similar promissory note (collectively, with the Loan and Servicing Agreement, the “Agreement”). Id. ¶¶ 22-24. The parties ultimately executed eight promissory notes under the Agreement between approximately December 22, 2022 and January 12, 2024, with Variant and Pier loaning Steel River a total of $5,617,550.75 during that period.4 See Compl., Ex. A at 1-14, 151- 84. See below:

3 The servicing fees listed in Schedule 1 to the promissory note dated Dec. 22, 2022 vary, initially ranging from between 25-55% of all gross collections for the various types of debt in the purchased accounts. See Promissory Note dated Dec. 22, 2022 at 6. The servicing fees subsequently increased to up to 57.5% of all Gross Collections. Id. 4 Exhibit A to the Complaint is incomplete, as it includes only six of the eight promissory notes executed pursuant to the Agreement, and only three of those promissory notes include the relevant Schedule A. See Ex. A at 1-14, 151-84. However, it appears that the parties executed the eight promissory notes over a period of approximately 13 months, including on: December 22, 2022 (4801); January 13, 2023 (6001); October 5, 2023 (4901); October 9, 2023 (4802); and January 12, 2024 (4803 and 4902). Id. at 1, 11, 85, 151, 165, 179.

-4- Promissory Note Amount 4801 $2,418,797.84 4802 $716,741.87 4803 $615,213.12 4804 $373,843.79 4805 $114,439.21 6001 $592,361.63 4901 $533,819.88 4902 $252,333.41 Total Amount $5,617,550.75 Under the Agreement, all collections on debt portfolios purchased with loan proceeds would be directed to a collection account designated by Steel River. Compl. ¶ 25. Every two weeks, either Steel River or Greenhill, as Manager, would distribute the gross collections5 as follows: (i) First, to pay all Servicing Fees [to Steel River]6 and invoiced Collection Fees [to any third-party collection agency or other third- party service provider]7 relating to such Loan for the proceeding Collection Period; (ii) Second, to any third-party Replacement Servicer or administrator, including any Collateral Administrator, all properly invoiced fees and

5 “Collections” are “all amounts received in the Collection Account in respect of Financed Accounts or other Collateral for a Loan. Compl., Ex. A at 15-102 (“Loan Agreement”) § 1.1. 6 “Servicing Fees” are “the servicing fees payable to [Steel River, as Servicer] for servicing each Portfolio of Financed Accounts purchased with proceeds of a Loan . . ., the amount thereof being determined in accordance with Schedule 1 to the Note[.]” Loan Agreement § 1.1.

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Steel River Systems, LLC v. Variant Alternative Income Fund, Pier Special Opportunities Fund, LP, and Greenhill Debt Management, LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steel-river-systems-llc-v-variant-alternative-income-fund-pier-special-nysd-2025.