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Law360 (September 8, 2022, 3:54 PM EDT)-- A Second Circuit panel handed Citibank a win Thursday in its battle to recover $500 million the bank accidentally wired to a group of Revlon Inc. lenders, overturning a New York federal court's decision that said the lenders didn't have to return the money. (Citi) of approximately $500 million.2Citi served as administrative agent to the lenders for an $1.8 billion syndicated seven-year loan to Revlon, Inc. (Revlon) pursuant to a credit agreement entered into in 2016 (the 2016 Loan). as administrative agent, citi was responsible for collecting interest and principal payments from revlon and transmitting the same to the loan managers on behalf of the lenders (the " lenders "). The district court relied on the testimony of an expert witness and interpreted such testimony to mean that a reasonable inquiry could include third-party market data or wisdom, but not necessarily consulting the sender of the funds to confirm the payment was intentional.30The Court, however, reasoned that the fact that the payment exactly matched the amount of debt did not eliminate the four warning signs outlined above.31, A recipient who failed to call Citi or Revlon, but only relied on internally confirming that the payment matched the amount of debt, cannot be said to have conducted a reasonable inquiry.32When ascertaining that the payment matched the amount of debt failed to explain away the red flags, the inquiry notice test required them to take the simple further step of calling their agent, Citi. But at least one Wall Street bank is seeing a boost from its stake in Revlon. One exception to this requirement is the discharge-for-value doctrine, which can be invoked by a payee that is entitled to the funds, has no knowledge that the payment was erroneous, and made no false representations to the payor in connection with the payment. In failing to make that call, the Loan Managers were chargeable with notice of what they would have learned. How Citi gave away $900 mn by mistake. Click here to login, 2022, Portfolio Media, Inc. | About | Contact Us | Legal Jobs | Advertise with Law360 | Careers at Law360 | Terms | Privacy Policy | Cookie Settings | Help | Site Map, Enter your details below and select your area(s) of interest to stay ahead of the curve and receive Law360's daily newsletters, Email (NOTE: Free email domains not supported). 2021)). In a decision rendered September 8, 2022, a three-judge panel for the United States Court of Appeals for the Second Circuit (the Court) vacated a February, 2021 decision by the United States District Court for the Southern District of New York in favor of the defendant loan managers of certain institutional lenders (the Loan Managers),1which held that the Loan Managers were not obligated to return an accidental payment by Citibank N.A. In August 2020, Citibank was serving as administrative agent for the lenders of a large syndicated loan to cosmetics giant Revlon. The Second Circuit particularly focused on four "red flags" that it believed would have led a hypothetical "reasonably prudent person" to believe that Citibank made the full principal payment erroneously: There was no notice given by Revlon of the early prepayment as required under the loan documents; Revlon and some of its creditors declined to acknowledge the bank's rights as a secured lender in the company's bankruptcy financing package. , Loan prices in the secondary market maintained their momentum in November as the Morningstar/LSTA Leveraged Loan Index (LLI) returned 1.2% after registering a 1% return, A team of market-leading practitioners from Latham & Watkins will discuss key features of Recurring Revenue Financings. 2022). Citibank is the administrative agent on a loan that Revlon secured in 2016. Will Group Costs Orders "anchor" Class Actions in Victoria? Citi brought suit for restitution bringing claims of unjust enrichment, conversion, money had and received, and payment by mistake against the defendant Loan Managers when they refused to return. Citibank wins $500 million at Second Circuit The appeals court granted the bank a $500 million refund for an accidental loan payment it made. THE WHAT? The content and links on www.NatLawReview.comare intended for general information purposes only. The ruling does not appear, however, to impact the total amount of Revlon's debts. The case stemmed from New York-based Citigroup's August 2020 prepayment of an $894-million loan for Revlon, which lacked enough cash to repay it, that was not due until 2023. Calla received her J.D. Citi brought suit for restitution bringing claims of unjust enrichment, conversion, money had and received, and payment by mistake against the defendant Loan Managers when they refused to return the amounts accidentally transferred. The district court relied on the testimony of an expert witness and interpreted such testimony to mean that a reasonable inquiry could include third-party market data or wisdom, but not necessarily consulting the sender of the funds to confirm the payment was intentional. in favor of Defendants . Law360 (May 20, 2021, 8:07 PM EDT) -- Citibank NA has petitioned the Second Circuit to extend an asset freeze on the more than $500 million that the bank is fighting to claw back from. The district court in Banque Worms established an exception to the general rule based on the Discharge-for-Value Rule, which provides that a creditor who has received a mistaken discharge of debt from a third party, is not required to repay such amount if the transferee did not make any misrepresentations and did not have notice of the transferors mistake. If Judge Furman's decision is upheld on appeal, then Ctibank may have the ability to assert a subrogation claim and step into the shoes of the RemainCo lenders it mistakenly paid off. Statement in compliance with Texas Rules of Professional Conduct. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys or other professionals or organizations who include content on the National Law Review website. As for Citi's appeal, a Second Circuit panel heard oral arguments in September 2021, but a ruling could take months. On Oct. 12, 2022, the United States Court of Appeals for the Second Circuit denied a request for rehearing from a group of Revlon, Inc., lenders seeking to overturn the Second Circuit's unanimous decision, issued on Sept. 8, 2022, requiring this syndicate group of Revlon lenders to return $500 million in funds mistakenly wired to them by Citibank, N.A. Build a Morning News Brief: Easy, No Clutter, Free! Any legal analysis, legislative updates or other content and links should not be construed as legal or professional advice or a substitute for such advice. The current decision seems to correct what was otherwise a clerical mistake. Citi brought suit for restitution bringing claims of unjust enrichment, conversion, money had and received, and payment by mistake against the defendant Loan Managers when they refused to return the amounts accidentally transferred. On September 8, 2022, the U.S. Court of Appeals for the Second Circuit reversed a judgment entered for a group of lenders (or their representatives) of cosmetics company Revlon, Inc. in. The National Law Review - National Law Forum LLC 3 Grant Square #141 Hinsdale, IL 60521 Telephone (708) 357-3317 ortollfree(877)357-3317. Many of the lenders chose not to forego the unexpected windfall of full payment and declined Citibanks request. The three-judge panel from New York City-based Second Circuit Court of Appeals granted a stay against the ruling by Syracuse federal judge Glenn T. Suddaby barring state officials from implementing Last month's court decision against the bank ruling that creditors can keep more than $500 million Citi sent them in a full, albeit mistaken, payoff of a 2016 Revlon loan has spurred some banks, including Citi itself, to insert clauses in their debt contracts allowing banks to demand repayment in the . Case Summary - Citibank, N.A. The firm represents creditors committees, debtors, financial institutions, indenture trustees, bondholders, landlords, suppliers and trading partners in out-of-court restructurings, bankruptcy reorganizations, and liquidations and related litigation. NEW YORK, Sept 29 (Reuters) - Citigroup Inc (C.N) on Wednesday pressed a federal appeals court to let it recoup about $504 million of its own money that it accidentally wired Revlon Inc (REV.N). NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. for the Second Circuit _____ CITIBANK, N.A . THE DETAILS The choice will go away the funding corporations preventing for compensation with fellow Revlon collectors within the beauty agency's . Citi is understandably upset. Emilee Larkin / September 8, 2022 In this Thursday, March 16, 2017, file photo, a customer enters a Citibank branch, in New York. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. Putting the Appeals of Both Sides to Bed: PTAB Rulings on the Get up to Speed: Blockchain for the Auto Industry. 25 Id. The appellate court also found that at time of the erroneous payment, the loan principal was not yet due for three years, and that for purposes of the "discharge-for-value" rule the amounts were not then owed to lenders. An appellate court on Sept. 8 ruled that Citibank is entitled to repayment of $500 million it erroneously sent to lenders of Revlon in August 2020. New Plastics Bill Would Place a Moratorium on All Permits for New How many businesses put up a Do Not Sell My Personal Information Supreme Court Hears Arguments in False Claims Act Whistleblower Case. 202 - To Luxembourg from the Cayman Islands with Fund Finance, FCA Seeks Feedback on Synthetic USD LIBOR, Senator Wyden Seeks Information from Crypto Exchanges Regarding Their Financial Stability and Customer Protections in the Event of Bankruptcy. 2022). The panel agreed. The dinner supports the Bullock Texas State History Museum with ticket sales and underwriting from nearly 500 attendees annually. When the original decision occurred, many lenders in the marketplace scrambled to overhaul their processes and procedures to prevent a similar occurrence and counsel to lenders reviewed and revised applicable provisions in loan documents to guard against a similar occurrence. Second Circuit Rules in Favor of Citibank in Accidental $500m Transfer in Revlon Loan Transaction natlawreview.com 15h In a decision rendered September 8, 2022, a three-judge panel for the United States Court of Appeals for the Second Circuit (the "Court") vacated a Read more on natlawreview.com Revlon Citigroup (C) Beauty Lifestyle Loans Organizational Integrity Shorts: Measuring The Efficacy Of Your Ethics & Labor and Employment Update for Employers: 2022 in Review and a Peek at 2023, Midterm Election Whiplash: Impact on U.S. 9 min read . Law360 takes your privacy seriously. Although the lenders had no actual knowledge that Citibanks payment was in error, the Second Circuit held that that the facts established at the trial created an obligation to inquire. The appellate court found that the payment of the principal was unusual enough, given all the circumstances at the time, including Revlon's contentious efforts to restructure the 2016 loan, that reasonable lenders should have inquired whether an error had been made. In the legal profession, information is the key to success. 2021)). Law360 (May 10, 2021, 9:13 PM EDT) Banking industry groups and other financial services trade associations are warning of costlier and slower payment transactions if the Second Circuit upholds a New York federal judge's decision allowing Revlon Inc. lenders to keep more than $500 million that Citibank NA accidentally wired them last summer.In friend-of-the-court briefs submitted to the . The district court concluded that reasonable inquiry would not have exposed the mistake and was persuaded by the fact that Citis payment matched exactly to the penny the amount of outstanding principal and interest owed to each of the Lenders. Citi has won its appeal over its Revlon loan blunder, helping it to recover about $500 million. However, Revlon was experiencing severe financial distress (and has since commenced a reorganization under chapter 11 of the Bankruptcy Code), with the debt evidenced by the loan trading at the time for less than 30 cents on the dollar. Four days prior to Citis mistaken payment, on August 7, 2020, Revlon offered to exchange the 2021 Notes for new notes due in 2024, specifically to avoid acceleration of the 2016 Loan. would have seen fit in light of the warning signs to make reasonable inquiry . For administrative reasons, Revlon opted to pay accrued interest to all of the Lenders party to the 2016 Loan, although no interim interest was due to those Lenders not participating in the Roll Up Transaction. 1 The Loan Manager defendants include Brigade Capital Management, LP (Brigade), HPS Investment Partners, LLC (HPS), Symphony Asset Management LLC (Symphony), Bardin Hill Loan Management LLC (Bardin Hill), Greywolf Loan Management LP (Greywolf), ZAIS Group LLC (ZAIS), Allstate Investment Management Company (Allstate), Medalist Partners Corporate Finance LLC (Medalist), Tall Tree Investment Management LLC (Tall Tree), and New Generation Advisors LLC (New Generation). THE DETAILS The decision will leave the investment firms fighting for repayment with fellow Revlon creditors in . 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Steven Herman concentrates his practice in the areas of real estate finance, development, joint ventures, acquisitions, dispositions, commercial leasing, restructurings, workouts, and commercial mortgage securitizations. Following trial in December 2020, the district court held the Loan Managers did not have to return the money based on the discharge-for-value rule (the Discharge-for-Value Rule) of the American Law Institutes Restatement (First) of Restitution (the First Restatement), relying on Banque Worms v. BankAmerica International, 570 N.E.2d (N.Y. 1991) (Banque Worms). The applicable standard of the First Restatement provides that a person is on notice when they know facts that would lead a reasonably intelligent and diligent person to inquire. The defendant Loan Managers also argued that Banque Worms implicitly rejected an inquiry notice standard in stating that a recipient should not have to wonder whether it may retain the funds, but the Court disagreed concluding there was no issue of notice for the Court to discuss in that case. You are responsible for reading, understanding and agreeing to the National Law Review's (NLRs) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The company secured $375 million the next. Inquiry notice is an objective test, which provides that when information available to the recipient of an apparent repayment includes facts that suggest a reasonable suspicion of error, the question is whether a reasonably prudent investor at risk of avoidable loss would have found the facts sufficient to warrant reasonable inquiry. [1] In re Citibank August 11, 2020 Wire Transfers , No. There are several actions that could trigger this block including submitting a certain word or phrase, a SQL command or malformed data. OIG Shines a Spotlight on Nursing Homes, Opioid Misuse, and Health Irish Data Protection Commission Fines Meta 265 Million for Privacy Hunton Andrews Kurths Privacy and Cybersecurity, To Achieve Carbon Neutrality by 2045, CARB Proposes 2022 Scoping Plan, CMS Extends Delayed Enforcement of the Good Faith Estimate. 3d (S.D.N.Y. The Court, however, reasoned that the fact that the payment exactly matched the amount of debt did not eliminate the four warning signs outlined above. The Second Circuit particularly focused on four red flags that it believed would have led a hypothetical reasonably prudent person to believe that Citibank made the full principal payment erroneously: The District Court had considered these facts but had concluded that they did not create an obligation to inquire on the lenders part. THE DETAILS The decision will leave the investment firms fighting for repayment with fellow Revlon creditors in the cosmetic firm's [] Such an inquiry, in the Courts view, would have put the recipients on notice of Citibanks error and eliminated any legal right to retain the funds. . His work ranges from single- and multiple-asset negotiated and auction transactions to highly structured transactions that span all segments of the marketplace, including office, hotel, retail, multifamily, mixed-use healthcare, and industrial facilities. By Jon Hill (September 29, 2021, 10:30 PM EDT) -- A Second Circuit panel on Wednesday floated the possibility of asking New York's highest court to weigh in on Citibank's bid to claw back more than $500 million accidentally sent to Revlon Inc. lenders, money that a Manhattan federal judge previously ruled they could keep under New York state precedent. U.S. Court of Appeals for the Second Circuit, Access to case data within articles (numbers, filings, courts, nature of suit, and more. The lenders, representing 126 debtholders, that refused to return the payments are Brigade Capital, HPS Investment Partners, Symphony Asset Management, Bardin Hill, Greywolf, Allstate, Medalist Partners, Tall Tree Investment Management, and New Generation Advisors. from Penn State Law where she was Senior Editor of theArbitration Law Review, her LL.M. The New York-based company's. Citi, in a statement seen by Bloomberg, said it is "pleased to have these funds returned." Citigroup has persuaded a US Second Circuit of Appeals judge that Revlon lenders should repay the significant sum paid to them in error, according to a report published by The Wall Street Journal. Following trial in December 2020, the district court held the Loan Managers did not have to return the money based on the discharge-for-value rule (the Discharge-for-Value Rule) of the American Law Institutes Restatement (First) of Restitution (the First Restatement), relying onBanque Worms v. BankAmerica International, 570 N.E.2d (N.Y. 1991) (Banque Worms).18The general rule of New York law that governs mistaken payments requires the recipient to return the money, unless such requirement would be unjust because the recipient significantly changed their position in reliance on the mistake, taking it out of the general rule.19The district court inBanque Wormsestablished an exception to the general rule based on the Discharge-for-Value Rule, which provides that a creditor who has received a mistaken discharge of debt from a third party, is not required to repay such amount if the transferee did not make any misrepresentations and did not have notice of the transferors mistake.20, Citi contended that (i) the Discharge-for-Value Rule only applies where the recipient is entitled to the funds, and in the instant matter, the Lenders were not entitled to the funds as the 2016 Loan was not payable for another three years, (ii) the Loan Managers did not receive value in satisfaction of the Discharge-for-Value Rule because they did not credit Revlon on their books after receipt of Citis repayment of the 2016 Loan, and (iii) the Loan Managers had constructive notice, which qualifies as knowledge underBanque Worms, of the error.21The Court vacated the district court ruling, concluding that the Loan Managers (i) were on notice of Citis error, and (ii) were not entitled to the money at the time of Citis mistaken payment.22, The Court reasoned that both New York law and the First Restatement apply an inquiry notice standard, rather than one of knew or should have known as asserted by the defendants.23The applicable standard of the First Restatement provides that a person is on notice when they know facts that would lead a reasonably intelligent and diligent person to inquire.24The defendant Loan Managers also argued thatBanque Wormsimplicitly rejected an inquiry notice standard in stating that a recipient should not have to wonder whether it may retain the funds, but the Court disagreed concluding there was no issue of notice for the Court to discuss in that case.25The Court held that the Discharge-for-Value Rule did not apply in the instant matter because the defendants were on inquiry notice that the unexpected early repayment of principal was due to a mistake, where the Loan Managers were aware of the following warning signs: (i) the lack of prior notice of a prepayment that Lenders were entitled to under the 2016 Loan, (ii) the clear inability of Revlon to make a repayment of the principal while insolvent, (iii) the 2016 Loan was trading at 20-30 cents on the dollar and could have been retired for cheaper than paying the entire face value of the debt, and (iv) four days before the Transfer Date, Revlon made an exchange offer to the holders of the 2021 Notes to avoid acceleration of the 2016 Loan, which would have been pointless if Revlon intended to voluntarily accelerate four days later.26, Inquiry notice is an objective test, which provides that when information available to the recipient of an apparent repayment includes facts that suggest a reasonable suspicion of error, the question is whether a reasonably prudent investor at risk of avoidable loss would have found the facts sufficient to warrant reasonable inquiry. COVID-related Form I-9 Remote Verification Flexibilities Extended Legal Risk Management 101: Avoiding Common Law Firm Liabilities. Goldman and the Juliet Problem: SEC Sanctions Adviser for Faulty ESG Learnings from Recent Physician Practice Private Equity Transactions, How Much of Yourself Is Okay to Share on Social Media? As administrative agent, Citi was responsible for collecting interest and principal payments . Du Bois: Agent of Change GTDRIVES: Dynamic Dialogues | Ep 12 - W.E.B. Amount of Revlon 's debts du Bois: agent of Change GTDRIVES: Dialogues! Www.Natlawreview.Comare intended for general information purposes only principal payments of theArbitration Law Review is not Law. A clerical mistake agent for the lenders of a large syndicated loan to cosmetics giant Revlon Actions in Victoria an! In Victoria of legal and business articles Actions that could trigger this block including a. And/Or other professionals to Bed: PTAB Rulings on the Get up to:. 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