12 April 2013

Dominion & North South: R. v. Whale, Cropp & another


Paul William Cropp, CEO of both Dominion Finance Group and North South Finance, has been convicted of theft by a person in a special relationship for his involvement in a business rescue which had the effect of reducing by eight cents in the dollar funds available for investors in North South.
Acquitted were director Robert Barry Whale and a senior executive granted name suppression.  Charges against Dominion Finance founder, Terry Butler, were deferred because of ill health.
Justice Lang was to comment that the root cause of the entire problem was funding of a 2004 joint venture intended to separate a Dominion Finance borrower from his failing project.  The Dominion Finance executives charged with criminal offences arising from this business rescue made no personal gain.  When under the pressure of imminent disclosures forced on them by reporting deadlines, steps taken to deal with the issue only compounded their legal problems.  
Both Dominion Finance and North South faced severe liquidity problems in late 2007 and early 2008.  In September 2008, Dominion Finance went into receivership leaving nearly 6000 investors owed some $176 million.   Current estimates have investors recovering less then twenty cents in the dollar.   North South was in receivership two months earlier in July 2008.  First ranking debenture holders received a payout of 55 cents in the dollar over the following two years.
Dominion Finance and North South shared the same directors but operated in slightly different market niches: Dominion lent to commercial property developers usually taking a second ranked security; North South primarily lent on first mortgage security.  Each company was a “related company” in respect of the other and there were constraints on intercompany lending.
Dominion was not permitted to lend funds to any related party without first obtaining consent from PGG Trust, the trustee for debenture holders.  [Securities law requires a trustee to be appointed when companies borrow from the public, with the trustee exercising any oversight specified in its contract with the borrowing company.]  By comparison, North South could lend to related parties without its trustee’s consent provided the transaction value did not amount in aggregate to more than two per cent of North South’s total tangible assets in any twelve month period.
Criminal prosecutions were launched when it was discovered that the two companies on five occasions made related party deals without getting the required  trustee’s consents.
A big drain on liquidity for Dominion had been a Remuera apartment development initiated by a Mr Mathew Ridge.  Six million dollars had been sunk into the project with progress amounting to no more than a hole in the ground.  By June 2004 it was clear to Dominion that Mr Ridge would be unable to finalise the project.  A rescue package was organised by Mr Butler, Dominion’s founder.  He negotiated a joint venture arrangement with a business acquaintance.  Evidence was given that Dominion was to finance the joint venture with Mr Butler required to underwrite the sale of five of the eleven apartments to be constructed.   This underwrite meant Dominion funding to the joint venture was to become a related party dealing needing prior consent from the trustee, PGG Trust.  No prior consent was obtained.
Justice Lang ruled that Mr Whale was not criminally liable for this initial related party financing because while trustee consent was not obtained Mr Whale did not know consent was needed. 
The court was told the project was plagued with delays and by March 2008 Dominion was owed $8.4 million.  There were still four apartments unsold with sale proceeds likely to be less than the loan balance.  In what was described as a heated Dominion Finance board meeting prior to 31 March balance date, Mr Butler claimed he had no personal liability for the apartment sale underwrite.  He claimed to have acted as agent for Dominion; it was a Dominion Finance commitment.  A commercial crisis loomed.  For a number of board members this was their first knowledge of Dominion’s liability.  If the finance company were liable, then full disclosure of its involvement would be needed in the company’s financial statements for the year ended 31 March 2008.  To deal with the immediate problem, an intermediary company was set up: WAFD Ltd.  WAFD agreed to purchase the four remaining apartments for $8.6 million, being the balance owed to Dominion and this purchase was financed with first mortgage finance from an outside source and a second mortgage of $5.2 million from Dominion.  This reduced Dominion’s total exposure on the project by some $3.35 million, but left undecided whether Mr Butler or Dominion Finance was the owner of WAFD.  Ownership carried liability for the loans.  The court was told Dominion subsequently assumed ownership.       
Mr Cropp and Mr Whale faced trial, each charged with theft following allegations they used Dominion Finance money in a related party transaction without getting prior trustee approval.
Mr Cropp was convicted.  Justice Lang ruled that Cropp assisted completion of this transaction in the knowledge that the trustee’s prior consent was required.  PGG, as trustee, was denied the opportunity to consider whether the transaction would benefit Dominion – regardless of whether Dominion or Mr Butler were to be the ultimate of owner of WAFD, it was a related party transaction requiring consent.  Justice Lang was critical of the way Cropp presented the transaction to Dominion’s credit committee, disguising the fact that it was a loan to a related party and that the loan had already been advanced prior to 31 March balance date.
Mr Whale was acquitted.  Justice Lang ruled there was reasonable doubt whether Whale was aware of the requirement for PGG consent.  It was probable or very likely that Mr Whale was by this date aware of the requirement but there was no documentary evidence to prove this point beyond a reasonable doubt.
Questions of related party lending also arose out of North South liquidity being used to fund Dominion’s second mortgage on the WAFD transaction.  In return for an advance of four million dollars, Dominion signed a security sharing agreement giving North South an interest in Dominion’s second mortgage.  This agreement required the consent of a different trustee, Covenant Trustee Company, since under North South’s rules this related party deal exceeded two per cent of the finance company’s total tangible assets.
Mr Cropp was convicted of theft by a person in a special relationship.  He knew North South needed trustee consent and acted in breach of this.  The court was told that Mr Cropp knew Dominion was going to make a loss on the apartment project.  Once North South became involved, it was going to share in the loss.  It was later resolved that North South could not share in the mortgage proceeds until after Dominion had been paid because of, amongst other legal reasons, the earlier failure to get PGG consent to Dominion’s involvement.
Justice Lang said Cropp knew Dominion needed funds to meet obligations to its investors.  Without the WAFD transaction, Dominion would have been in default and required to give notice to PGG as its trustee, to the Stock Exchange and to the market – with the commercial consequences that would have followed.
Mr Cropp was similarly convicted of theft in relation to further security sharing arrangements put in place in April and June 2008 when North South made further advances to Dominion totalling $7.9 million.
Mr Whale was acquitted of charges of theft in relation to each security sharing transaction.  Justice Lang said in one instance Mr Whale had no direct involvement in the transaction and in others where he was involved there was no contemporaneous evidence that was aware of the restriction on North South lending.
R. v. Whale, Cropp and another – High Court (12.04.13)
13.012

05 April 2013

Insurance: O'Loughlin v. Tower Insurance


In a test case on the “repair in red” proposal by one insurance company following the Christchurch earthquakes, the High Court ruled an insurer may choose to pay out on a notional repair even though no repair is intended but it must be a payment based on a realistic assessment of the cost of any repair.  Where a notional repair cost will depend on substantial geotech surveys and a need for stronger earthquake-proof foundations, insurers are likely to opt for a replacement or rebuild elsewhere.
Tower Insurance faced a barrage of adverse publicity when media learnt that the insurer was proposing to pay repair costs rather than replacement costs on homes which were to be abandoned following major earthquakes in Christchurch in 2010 and 2011.
Mr and Mrs O’Loughlin had built an architect designed home on land in Gayhurst Road, Dallington in 1999.  The concrete base slab warped after two severe earthquakes and the building dropped between 0.3 and 0.6 metres after liquefaction affected ground contours.
Their property became part of a government-designated “red zone”: insured property owners were given the option of accepting a government offer for their property; or a government offer for the land alone with the property owner to recover compensation for building damage from their insurer.  The O’Loughlins chose the second option but could not reach agreement with Tower over the level of compensation.  Their insurance cover was described as a Tower Provider House Policy: Maxi Protection .
Justice Asher said red zone designation did not stop a person from getting building consent for a repair or rebuild, did not stop a person from living in the red zone and did not require residents to demolish or repair their homes.  But residents intending to stay have been warned that public utilities like power, water, sewage and roading are unlikely to be maintained or repaired.
The O’Loughlins hired a global claims management company called WorldClaim to negotiate with Tower.  WorldClaim is entitled to 25 per cent of monies recovered from Tower in excess of Tower’s offered $390,000 for repair costs.  WorldClaim assessed repair costs at $1.35 million.
Tower said the O’Loughlin house could be stabilised and then repaired by pumping polystyrene foam under the concrete base slab to fill the voids created by liquefaction.
After hearing evidence from Christchurch City Council, Justice Asher ruled that this proposal was unlikely to get building consent for red zone properties.  A detailed engineering study would probably show new pile foundations would be required.
He said even if building consent were granted, there were apparent risks of the method failing and significant cost overruns resulting.  It was not reasonable to expect Tower to make payment for a notional repair of this type when final costs could not be fixed adequately.
Justice Asher ruled that Tower’s offer of $390,000 for repair costs fell short of its contractual obligations under the insurance policy.
But the court was not able to determine what would be an appropriate payout.
The wording of Tower’s Maxi policy gave Tower the option of repairing the damage or replacement elsewhere.  Justice Asher said Tower had not committed to a repair, it had offered to pay compensation on a notional repair.  It was still open to the insurer to choose compensation based on buying a new home elsewhere or building at an alternative site.  Buying a new home would require finding an existing home elsewhere satisfactory as being in “the same condition and extent” as their red-zoned Dallington home had been when new.  Justice Asher said this does not require Tower to pay for a replacement property which is identical in terms of the position, dimensions, building design and finish as the Dallington property.
Alternatively, Tower could choose to pay for a rebuild.  Justice Asher said this does not require Tower to pay for the cost of a rebuild on the present Dallington site; payment is to be calculated on the cost of a rebuild on an alternative site.
Loughlin v. Tower Insurance – High Court (5.04.13)
13.008