28 November 2016

Securities: Bannock v. Monaco Management

One third of 37 disappointed purchasers buying units in Nelson’s Monaco Village tourist development have a chance of getting their purchase price back after the High Court ruled developer Scott Sanders is personally liable to refund their money. 
Mr Sanders was sued for $7.4 million following allegations units in Monaco Village sold up to twelve years ago amounted to participatory securities sold without a prospectus in breach of the Securities Act.  While the Monaco Hotel and Resort is up and running, investors complain they are not getting promised returns.
Investors in Monaco were asked to provide working capital; buying individual accomodation units within the development.  A management company was set up to manage holiday lets and to account for revenue received.  Local entrepreneur Mike Gepp was the initial promoter.  He bowed out in 2006, short of cash to finish the project.  Mr Sanders picked up the reins.
The High Court was told Mr Sanders was aware Mr Gepp had earlier run foul of the Securities Act by having unit purchasers sign a pooling agreement, having Village revenue pooled for division across all unit holders.  This amounted to a participatory security.  Mr Sanders took a different approach:  subsequent purchasers took title to each unit subject to a lease.  The lease gave management rights to a company controlled by Mr Sanders.  Sales of land do not fall within the Securities Act.  Each unit holder was to receive revenue earned by their unit alone; there would be no pooling.  The High Court subsequently ruled this arrangement was also a participatory security which required a prospectus before sale.  Justice Dunningham said lease terms meant investors took a considerable business risk without having a degree of control over their property in the way an owner of conventional commercial property would.  They had no control over who would be tenants or the terms of holiday lets.  They had no right to terminate the management company’s thirty year lease.  Resource consent for the Village meant the property could be used for tourist accommodation only.  This was not an ordinary purchase of real estate, Justice Dunningham said.  It was a participatory security in a hotel business.  A prospectus was required to inform potential investors of inherent risks prior to purchase.
Since no prospectus was issued, investors were entitled to their money back, with interest.  The Securities Act holds Mr Sanders personally liable for refunds since he was a director of the company selling securities without a prospectus.
Of the 37 investors who sued, eleven are entitled to repayment.  One was denied repayment as a close business associate of Mr Gepp.  He advanced money for the development and built part of the Village.  The remaining investors denied repayment were those who sued out of time, or were subsequent purchasers having bought from a prior purchaser.      
Bannock v. Monaco Management – High Court (28.11.16)

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