Public Hearing - May 16, 2018

    


       1      BEFORE THE NEW YORK STATE SENATE
              STANDING COMMITTEE ON CONSUMER PROTECTION
       2      ------------------------------------------------------

       3                         PUBLIC HEARING

       4                       ON LAWSUIT LENDING

       5      ------------------------------------------------------

       6                       Legislative Office Building
                               Van Buren Hearing Room A - 2nd Floor
       7                       Albany, New York 12210

       8                       May 16, 2018
                               12:00 p.m. to 4:00 p.m.
       9

      10

      11      PRESIDING:

      12         Senator Chris Jacobs, Chair

      13         Senator Robert Ortt, Co-Sponsor

      14

      15      PRESENT:

      16         Senator Marisol Alcantara (RM)

      17         Senator Michael H. Ranzenhofer

      18         Assemblyman William B. Magnarelli
                 (seated in the audience)
      19

      20

      21

      22

      23

      24

      25







                                                                   2
       1
              SPEAKERS:                               PAGE  QUESTIONS
       2
              Tom Stebbins                               9       21
       3      Executive Director
              Adam Morey
       4      Manager of Public Affairs
              Lawsuit Reform Alliance of New York
       5
              Kelly Gilroy                              32       41
       6      Executive Director
              American Legal Finance
       7
              Maya Steinitz                             67       72
       8      Professor of Law,
                University of Iowa College of Law
       9      Also, Visiting Professor of Law,
                Harvard Law School
      10
              Anthony J. Sebok                          82       92
      11      Professor of Law,
                Benjamin N. Cardozo School of Law
      12      Also, Visiting Professor,
                Cornell Law School
      13
              Honorable Anthony L. Coehlo              111      116
      14      Retired Member of
                U.S. House of Representatives
      15      Member, Board of Directors
                Epilepsy Foundation
      16
              Lev Ginsburg                             131      137
      17      Director of Government Affairs
              The Business Council of
      18        New York State, Inc.

      19      James R. Copland                         144
              Senior Fellow Director, Legal Policy
      20      The Manhattan Institute

      21

      22                           ---oOo---

      23

      24

      25







                                                                   3
       1             SENATOR JACOBS:  Good afternoon, everyone.

       2             Thank you for being here.

       3             I'm Senator Chris Jacobs.  I represent the

       4      60th Senate District located in Erie County,

       5      New York.

       6             I serve as the Chair of the Senate Standing

       7      Committee on Consumer Protection, and today's public

       8      hearing.

       9             This public hearing will focus on lawsuit

      10      lending, and how we can better regulate third-party

      11      litigation -- third-party litigation financing in

      12      New York.

      13             A few quick housekeeping items before we

      14      begin.

      15             Each testimony presented today, both oral and

      16      written, will be part of the official public record.

      17             We will hear from seven witnesses.  Speakers

      18      will be asked to keep their remarks to 10 minutes so

      19      that Committee members will have sufficient time to

      20      ask their questions.

      21             The testimony you submitted is in every

      22      member's hands, so they have the opportunity to --

      23      if they haven't read it yet, to read it in its

      24      entirety.

      25             But we did want to make sure that we have







                                                                   4
       1      sufficient time for questions.

       2             The third-party litigation-financing industry

       3      emerged in the 1990s.

       4             In recent months, several media sources,

       5      including "The New York Post" and "The New York

       6      Times," have reported several stories of individuals

       7      that have been forced to forfeit much of their

       8      proceeds from their litigation settlements to

       9      businesses that funded the lawsuits due to very high

      10      interest rates.

      11             However, we can all agree that litigation is

      12      not cheap.

      13             Members of the lawsuit-lending industry claim

      14      they have served a much-needed role in providing

      15      loans to litigants who would otherwise struggle to

      16      make ends meet during their lengthy lawsuits.

      17             Two pieces of legislation have been

      18      introduced to help claimants from excessive interest

      19      rates and fees.

      20             These bills are S3911 and A8653, sponsored,

      21      respectively, by Senator Ortt and Assembly

      22      Member Magnarelli, and A899, sponsored by Assembly

      23      Member Dilan.

      24             The Consumer Protection Committee has called

      25      this public hearing to hear from members of the







                                                                   5
       1      industry, consumer advocates, and experts on this

       2      topic so that they -- that we can reach a solution

       3      that will better protect claimants in our state.

       4             I want to thank my Senate colleagues in their

       5      attendance.

       6             Many of them are still at session, so

       7      I imagine many will be filing in over the next few

       8      minutes.

       9             But, my Ranking Member, Senator Alcantara is

      10      here.  Thank you for being here.

      11             And, Senator Ortt, who is the author of one

      12      of the pieces of legislation that I just referenced.

      13             I wanted to just mention, the members that

      14      are -- the individuals that are here that will be

      15      testifying, I'm just going to list them right now:

      16             Tom Stebbins, executive director, and

      17      Adam Morey, managing (sic) public affairs director,

      18      for the Lawsuit Reform Alliance of New York;

      19             Kelly Gilroy, executive director of the

      20      American Legal Finance Association;

      21             Maya Steinitz, professor of law at the

      22      University of Iowa College of Law, and visiting

      23      professor of law at Harvard Law School;

      24             Anthony Sebok, professor of law at the

      25      Benjamin Cardozo School of Law at Yeshiva







                                                                   6
       1      University, and visiting professor at Cornell Law

       2      School;

       3             The Honorable Anthony -- and I'm going to

       4      maybe mispronounce this -- Coehlo, a retired member

       5      of U.S. House of Representatives from California,

       6      and current member of the board of directors from

       7      the -- for the Epilepsy Foundation;

       8             Lev -- Lev Ginsburg, director of government

       9      affairs for the Business Council of New York;

      10             James Copland, senior fellow director of

      11      legal policy, The Manhattan Institute.

      12             Thank you all for being here today.

      13             At this point in time I would like to --

      14      Member Altantra -- Alcantara is -- is -- she just

      15      wants to get right to work, so no opening remarks,

      16      she said.

      17             But, Senator Ortt did you want to say a few

      18      words before we begin.

      19             And, thank you very much once again.

      20             SENATOR ORTT:  Well, I want to get to work

      21      too, but I wanted to make some opening comments.

      22             I just wanted to thank Senator Jacobs and the

      23      Consumer Protection Committee, Senator Alcantara,

      24      for putting this hearing together.

      25             I think it's important.







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       1             We pass a lot of pieces of legislation

       2      through the New York State Senate and, of course,

       3      the Assembly as well, and, very often, there is no

       4      real public discussion.  There's discussions that

       5      happen in hallways, in closed-door meetings, and

       6      that's certainly a part of what we do.

       7             But I think having a hearing like this where

       8      we have this discussion, because a lot of people

       9      probably don't know what this industry is.  A lot of

      10      senators probably are unfamiliar with it.

      11             And it's very important, I think, if we're

      12      going to have a real substantive discussion, and try

      13      to get to good policy, then we need to educate not

      14      only members of the public, but even the officials

      15      who will be voting on this legislation.

      16             And so I think it's very important.

      17             And I just want to say that, you know, the

      18      goal here really is to -- I think there's a lot of

      19      folks out there who are in this industry, who do a

      20      good job, and serve a very important need.  Probably

      21      not a high need, but there's a very important need

      22      when it arises.

      23             But, of course, like any industry, especially

      24      when it's not regulated or has no sort of oversight,

      25      you have a number of bad actors as well.







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       1             So the goal really is to try to make sure

       2      that we have some oversight, that we are not

       3      encouraging any practices that are untoward, or that

       4      encourage what I would call "unnecessary" lawsuits

       5      or litigation that don't increase the cost, and

       6      certainly don't take advantage of people who are

       7      incredibly vulnerable and have a high risk.

       8             On the same token, if there's lenders out

       9      there who are serving a real important need and

      10      they're doing everything above-board, then I think

      11      having them part of this discussion can only result,

      12      hopefully, in positive legislation and positive

      13      oversight.

      14             So, that's what I'm hoping for, as this is

      15      the first step.

      16             So I want to again thank Senator Jacobs,

      17      I want to thank Senator Alcantara, and I want to

      18      thank all the folks who are coming here to testify

      19      today.

      20             SENATOR JACOBS:  Thank you, Senator.

      21             And now I'd like to call up Tom Stebbins and

      22      Adam Morey, please.

      23             And you know your hierarchy of your

      24      organization better, so whoever wants to go first,

      25      you're more than welcome.







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       1             TOM STEBBINS:  Well, I appreciate that,

       2      Senators.

       3             Thank you very much for having us today.

       4             Chairman Jacobs, Senator Ortt, members of the

       5      Committee, thank you for the opportunity to provide

       6      testimony regarding third-party litigation

       7      financing.

       8             Law suit cash-advance companies currently

       9      operate in New York unchecked and without meaningful

      10      consumer protections.

      11             This is an obvious disservice to some of the

      12      state's most vulnerable citizens, those who have

      13      already fallen victim to the actions of a negligent

      14      party.

      15             The industry targets New Yorkers when they

      16      are at their most desperate, when they are injured,

      17      and may be unable to work or afford their rent.

      18             A quick Internet search for "lawsuit loans"

      19      turns up hundreds of thousands of results from

      20      companies that offer cash advances for pending

      21      lawsuits and claims.

      22             Many funders promise "cash now," offering

      23      approval in just one day.

      24             The interest is often compounded monthly,

      25      with annual interest rates that exceed 100 percent.







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       1             An individual who has entered into one of

       2      these lending contracts may ultimately settle or win

       3      a lawsuit, only to take home a tiny fraction of

       4      their award, or, in some cases, none at all.

       5             "The New York Post" recently uncovered a

       6      story of Theresa Gus, a woman who borrowed $23,000

       7      from two cash-advance law firms:  LawBuck$, spelled

       8      with a dollar sign, and MFL Case Funding.

       9             She passed away before she ever saw a cent of

      10      the $2.1 million settlement she received from a

      11      slip-and-fall case against the City because the

      12      companies had put liens on the total amount, nearly

      13      100 times the original principal of the loan.

      14             Lawsuit-lending companies claim, that because

      15      the advances are contingent on the borrower winning

      16      the case, the product they offer is risky and should

      17      be classified as an investment, not a loan.

      18             This mischaracterization allows them to

      19      charge interest rates that are well beyond

      20      New York's civil and criminal usury rates.

      21             The level of risk that actually exists here

      22      is questionable, and nowhere near anything that

      23      could justify interest rates over 100 percent.

      24             There is no evidence to suggest that the rate

      25      of default on lawsuit loans is higher than it is for







                                                                   11
       1      other financial products.

       2             As LawCash executives told "Crain's New York

       3      Business," the company, quote, uses strict

       4      underwriting screening rules to ensure only about

       5      4 percent of the cases it advances money to are lost

       6      in court, end quote.

       7             In one illustrative example, a Brooklyn

       8      resident, Joseph Gill, borrowed $4,000 from

       9      LawBuck$ -- again, spelled with a dollar sign -- in

      10      order to cover medical expenses while his lawsuit

      11      was pending in court.

      12             At the time Gill's lawsuit settled five years

      13      later, LawBuck$ demanded repayment to the tune of

      14      $116,000, 29 times the original amount that he was

      15      advanced.

      16             The judge who presided over the case in

      17      Brooklyn Supreme Court was incredulous, and ordered

      18      LawBUck$ to explain its loan agreement.

      19             In court papers, the judge presiding over the

      20      case called the interest rate, quote, usurious, and

      21      if not usurious, then unconscionable, end quote.

      22             In another case, Carolyn Williams, a former

      23      nurse in the midst of a disability lawsuit with her

      24      former employer, borrowed $5,000, in her case, to

      25      pay medical bills.







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       1             The lender, U.S. Claims, not spelled with a

       2      dollar sign, did not inform Williams or her lawyer

       3      of their rate of interest to be charged on the loan.

       4             It was not until nearly a year later when she

       5      discovered the annual interest rate was 76 percent.

       6             Williams told "The New York Times" that she

       7      was, quote, definitely misled, and, quote, never

       8      expected that high of a rate, end quote.

       9             After three years, Williams' case remained

      10      unresolved and her loan debt had ballooned to nearly

      11      $19,000.

      12             Due to many legal and ethical considerations

      13      surrounding lawsuit consumer -- consumer lawsuit

      14      financing, state officials around the country have

      15      begun to look into and investigate the legitimacy of

      16      the industry.

      17             Colorado's Attorney General recently

      18      announced that she will be sending out restitution

      19      checks from a $2.3 million settlement her office

      20      reached with LawCash and Oasis Legal Finance.

      21             Here in New York, the Office of the Attorney

      22      General joined with the Consumer Finance Protection

      23      Bureau to file a complaint last year against

      24      RD Legal Funding, a New Jersey-based cash-advance

      25      lawsuit firm -- lawsuit cash-advance firm, for







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       1      allegedly taking advantage of 9/11 first responders

       2      and NFL players with concussion-related

       3      complications by offering high-interest advances on

       4      expected payouts from legal settlements and

       5      compensation funds.

       6             The court filings for this enforcement action

       7      highlight the case of an unnamed 9/11 first

       8      responder who fell victim to this scheme when she

       9      was advanced $18,000 while awaiting a payout from

      10      the Ground Zero Compensation Fund.

      11             After six months, she owed $33,000, an

      12      83 percent increase in less than a year.

      13             Sadly, as media outlets continue to reveal,

      14      the abuse is more widespread than just the stories

      15      mentioned here.

      16             A "New York Times" investigation has

      17      uncovered lenders advertising directly to women with

      18      claims in the "me too." movement.

      19             Another report uncovered a scheme in which

      20      lawyers and lenders convince women to get often

      21      unnecessary and potentially dangerous surgeries in

      22      order to increase the value of their litigation.

      23             This controversial practice is allowed to

      24      continue because lawsuit lending and surgical

      25      funding are not adequately regulated under New York







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       1      law.

       2             This is why the Lawsuit Reform Alliance of

       3      New York supports Senator Ortt's bill, 3911-A, a

       4      bill introduced by Senator Ortt and Assemblyman

       5      William Magnarelli, that would protect consumers

       6      from usurous rates by requiring the lawsuit lenders

       7      and financiers to comply with existing lending laws

       8      that cap consumer interest rates.

       9             To further reduce harms to individuals and

      10      protect the integrity of the civil justice system,

      11      the bill also ensures that lawyers do not have

      12      overlapping financial interests in lending outfits

      13      or arrangements to collect lucrative referral fees.

      14             Such partnerships can encourage frivolous

      15      filings and prolong litigation that should have

      16      settled sooner.

      17             According to "The New York Times," federal

      18      prosecutors are currently investigating whether some

      19      of the existing relationships that lawyers have with

      20      the lenders constitute illegal kickback schemes.

      21             For the above reasons, we urge members of the

      22      Committee to swiftly discharge S3911-A for

      23      consideration by the full Senate.

      24             We also urge the Assembly and the Governor's

      25      Office to pass this legislation and sign it into







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       1      law.

       2             Thank you for your consideration.

       3             SENATOR JACOBS:  Adam, before I allow you to

       4      speak, I just want to recognize, Senator Ranzenhofer

       5      is here.

       6             And it was brought to my attention that

       7      Assemblyman Magnarelli is here in the crowd.  And

       8      you are more than welcome to come up here.

       9             ASSEMBLYMAN MAGNARELLI:  (Inaudible.)

      10             SENATOR JACOBS:  Thank you very much.

      11             Okay.  Adam, thank you.

      12             ADAM MOREY:  Oh, that was our -- that's our

      13      full testimony.

      14             SENATOR JACOBS:  Do you have any questions at

      15      this point for Tom?

      16             Senator Ortt?

      17             SENATOR ORTT:  Yeah, just, do you know what

      18      other states currently regulate lawsuit lending?

      19             TOM STEBBINS:  Yeah, several states have

      20      regulated lawsuit lending.  And a few of them have

      21      actually subjected their -- the litigation

      22      financing, or lawsuit lending, to existing usury

      23      law.

      24             And in one notable example, in Tennessee,

      25      where they were subject to those usury rates, which







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       1      are lower than New York --

       2             New York is at 16 percent.  I believe

       3      Tennessee is 10 percent.

       4             ADAM MOREY:  10 percent, yeah.

       5             TOM STEBBINS:  -- all of the lawsuit lenders

       6      still registered in that state to do business.

       7             So you may hear some testimony today that

       8      lawsuit lenders will not do business where the

       9      regulate -- where the interest rate is capped.

      10             That is false.  According to public records,

      11      they have registered to do business in the states

      12      where this has been regulated.

      13             ADAM MOREY:  And Arkansas is another one.

      14             They have -- those are capped at 17 percent.

      15      We've seen -- there's been no reports that anybody

      16      pulled out there.

      17             SENATOR ORTT:  So -- because, obviously,

      18      there's like two issues here:

      19             There's oversight, which is a general, you

      20      know, it can be a lot of different things;

      21             And then there's caps, which can be part of

      22      oversight.

      23             But both of these states you mentioned are --

      24      or, I guess, would it be fair to say that a number

      25      of the states that do regulate, there are -- there







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       1      is some kind of a cap or set max rate they can

       2      charge, or is that -- would that be not true?

       3             TOM STEBBINS:  Some have their own caps.

       4      Some have caps to existing usury laws.

       5             And that's what we're advocating for: a cap

       6      to existing usury law in New York State.

       7             Existing usury law is 16 percent for civil.

       8      And anything above 25 percent is criminal loan

       9      sharking for which you would go to jail.

      10             SENATOR ORTT:  Thank you.

      11             Senator Alcantara?

      12             SENATOR ALCANTARA:  Thank you, Tom, for your

      13      testimony.

      14             What are the common victims of lawsuit

      15      lending?

      16             TOM STEBBINS:  Well, we see a number of

      17      victims.

      18             I think the 9/11 first responders and the NFL

      19      settlement is most troubling because, what the

      20      lenders often say is, that these loans are risky,

      21      and that there's a certain amount of risk involved,

      22      that they need to charge these 100 percent,

      23      85 percent, whatever it may be.

      24             But in the case of the 9/11 first responders

      25      and the NFL concussion settlement, those were







                                                                   18
       1      settlements, they're making claims.  There's no

       2      litigation risk there at all; and yet, in one of

       3      the cases, we saw an 83 percent increase in just

       4      6 months.

       5             So an 83 percent increase on a claim for

       6      which there is, essentially, no litigation risk,

       7      because it's made against a fund in this particular

       8      case, the 9/11 First Responders Fund.

       9             But we've seen a lot of other cases, just

      10      consumer cases, where somebody takes out $5,000,

      11      and then, you know, over the course of three or

      12      four years, compounding interest on $5,000, they owe

      13      over $100,000.  And they took that initial loan for

      14      their medical costs.  But now, when they get paid

      15      for their injury, there's no money left.

      16             And so we have these lenders using our

      17      justice system for -- as a profit center, and that's

      18      not what it should be for.

      19             It should be for compensating victims.

      20             SENATOR ALCANTARA:  And what is the average

      21      interest rate in the state of New York?

      22             TOM STEBBINS:  Well, on a consumer loan, a

      23      regular consumer loan, as I said, the usury cap is

      24      16 percent.

      25             For these loans, I mean, we've seen it all







                                                                   19
       1      over the map.

       2             I think that we've seen --

       3             ADAM MOREY:  There's been reports of 200-plus

       4      percent.

       5             I think that's in the complaint about

       6      RD Legal Funding.  One of them was, 250 percent was

       7      the rate that somebody was charged.

       8             TOM STEBBINS:  And I can't imagine the

       9      litigation risk, or the risk that any funder would

      10      be taking, to fund something that required a

      11      250 percent return in exchange for that risk.

      12             ADAM MOREY:  And even if the average is

      13      around 50 percent, that's still, you know, double

      14      the criminal usury rate.

      15             SENATOR ALCANTARA:  And what is the length of

      16      time, normally?

      17             Like, let's say I take out a $5,000 loan.

      18             TOM STEBBINS:  Well, generally, litigation

      19      can go from three to five years.  So -- and it's

      20      compounding interest.

      21             And one of the things you may hear today is

      22      that there was a deal with the attorney general back

      23      in, I believe 2005, that says that these lenders

      24      must disclose their loans, and they have a cover

      25      page that discloses the loans.







                                                                   20
       1             But, it's clearly not working.

       2             All the media reports we've seen are from

       3      after 2005, and yet there's still so many people

       4      that are getting roped into these loans, that have

       5      no idea that they're going to be paying 150 percent,

       6      because sometimes these cover pages don't adequately

       7      show what actually the interest rate will be.

       8             They'll talk about how it's compounded

       9      monthly, or something like that.

      10             SENATOR ALCANTARA:  And my last question:  Do

      11      we have a region of the state where they make the

      12      most amount of loans -- of these type of loans?

      13             TOM STEBBINS:  No, and we've seen it all over

      14      the state.

      15             Interestingly, "The New York Post" had a

      16      story about a person in Staten Island who has the

      17      Lawsuit Cash Truck.  I mean, he drives around,

      18      throwing money out of a converted ice cream truck,

      19      essentially saying, that if you've got a lawsuit,

      20      he's got $10,000 for you.

      21             What he, of course, doesn't say is the

      22      interest rate that's on that $10,000.

      23             SENATOR ALCANTARA:  Thank you.

      24             TOM STEBBINS:  Thank you.

      25







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       1             SENATOR JACOBS:  Senator Ranzenhofer, any

       2      questions?

       3             SENATOR RANZENHOFER:  Yes.

       4             Yeah, thank you, Chairman.

       5             Thank you for being here today.

       6             Can you just tell me the basic difference

       7      between Senator Ortt's bill and Assemblyman Dilan's

       8      bill?

       9             TOM STEBBINS:  Caps.

      10             Caps on the interest rate.

      11             So one of the things you'll hear today is the

      12      need for transparency and the need for reporting,

      13      and all that.

      14             And, absolutely, we need all those things.

      15             But without an adequate interest rate cap

      16      there will be no adequate consumer protection.

      17             SENATOR RANZENHOFER:  So you agree with

      18      everything in the Dilan bill, with the exception of

      19      the fact that it doesn't have a cap?

      20             TOM STEBBINS:  Well, it also -- I mean, it

      21      connects it to existing usury law, and so there's a

      22      lot of protections within existing usury law beyond

      23      just the caps.

      24             But, really, the most important thing here is

      25      the caps.







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       1             SENATOR RANZENHOFER:  So you had mentioned

       2      the usury law, and you had mentioned 16 percent.

       3             What is the -- I thought the credit card rate

       4      on a credit card right now is 1.5 percent.

       5             So if I was --

       6             TOM STEBBINS:  So credit cards have a

       7      different lending rate.  Those aren't considered

       8      loans.  Those are regulated in a different way.

       9             SENATOR RANZENHOFER:  -- yeah, but that would

      10      be 18 percent annually?

      11             TOM STEBBINS:  I don't know what credit card

      12      interest rate is.

      13             I believe it's 23?  Is it 18?

      14             I don't know.  I honestly don't know.

      15             SENATOR ALCANTARA:  It depends on the

      16      company.

      17             SENATOR RANZENHOFER:  Okay.

      18             SENATOR ALCANTARA:  Some are as high as 32.

      19             SENATOR RANZENHOFER:  I try and pay off my

      20      balance I owe them.  (Indiscernible.)

      21             SENATOR ALCANTARA:  Some are as high as 32.

      22             SENATOR ORTT:  Good answer, Mike.

      23             SENATOR RANZENHOFER:  Okay.  But there are

      24      some -- so there is some other lending in the state,

      25      which, obviously, it's a different type of loan.







                                                                   23
       1             But there are some areas of the state, and

       2      other types of consumer transactions, whether it be

       3      credit card, or as Senator Alcantara just said, as

       4      high as 22 or 23 percent, up to, maybe, 32 percent.

       5             And I know this is not your, you know, area,

       6      but is there something wrong with those type of

       7      rates?

       8             TOM STEBBINS:  Well, I mean, in the case of

       9      this particular kind of financing, litigation

      10      financing, there's a non-profit out of Buffalo, the

      11      Bair Foundation, which offers rates at 8 percent.

      12             So to say that they can't do this kind of

      13      lending without rates that exceed the rate of

      14      criminal usury I think is absurd.

      15             And, frankly, again, we've seen in states

      16      where the interest rate has been capped, that these

      17      lending outfits have registered with the secretary

      18      of state to do business in those states, and we

      19      presume that they are doing business in those

      20      states.

      21             SENATOR RANZENHOFER:  Okay.  Has there

      22      been -- and I'm sure we'll hear from them.

      23             You had said they're still doing business.

      24             Obviously, there's competition among

      25      companies.







                                                                   24
       1             Has there been any reduction in the number of

       2      these businesses in these other states where there

       3      is a cap on the amount of interest?

       4             So, in other words, before the cap, you know,

       5      was there 10 companies doing business, and after the

       6      cap, that same number continued to do business?  Or,

       7      was there any dimunition (sic) in the number of

       8      companies that were involved?

       9             TOM STEBBINS:  I don't know.  We have not

      10      done a time-lapse analysis of the -- of those --

      11             SENATOR RANZENHOFER:  That would be helpful,

      12      because I know, obviously, there's the "going out of

      13      business."  And then there's the second aspect, of

      14      whether or not there's been a decrease in the number

      15      of companies and the effect of competition.

      16             TOM STEBBINS:  Well, if you can't -- if you

      17      can't make a go out of -- of it without 150 percent

      18      interest rate, I would argue you shouldn't be in

      19      business.

      20             SENATOR RANZENHOFER:  All right.  So you have

      21      mentioned 150 percent interest rate, and you

      22      mentioned an 83 percent interest rate.  And I don't

      23      think anybody would argue that those are exorbitant.

      24             Is there a number that's higher than the

      25      16 percent that would be reasonable in light of







                                                                   25
       1      other areas of consumer transactions that have

       2      higher rates?

       3             TOM STEBBINS:  Again, I would think anything

       4      over 25 percent, which is the rate of criminal loan

       5      sharking, is -- would be impossible for us to

       6      support, because, again, that is the rate of

       7      criminal loan sharking for which you would go to

       8      jail.

       9             SENATOR RANZENHOFER:  Okay.  And I know I --

      10      you know, I don't mean to put Senator Alcantara on

      11      the spot, but she had mentioned that there are some

      12      as high as 32 percent.

      13             Obviously, that would be a crime if it was

      14      lending.

      15             TOM STEBBINS:  I don't know what kind -- was

      16      that credit card lending?  Or --

      17             SENATOR ALCANTARA:  Some credit card lendings

      18      are pretty high --

      19             TOM STEBBINS:  Okay.

      20             SENATOR ALCANTARA:  -- at 32 percent.

      21             SENATOR RANZENHOFER:  So if you have credit

      22      card lending at 32 percent, and, again, I understand

      23      the difference in the type of transaction, you know,

      24      where -- you know, what is your opinion -- I know

      25      you had mentioned 25.  But what's your opinion --







                                                                   26
       1             TOM STEBBINS:  Not a big fan of 32 percent

       2      either.

       3             SENATOR RANZENHOFER:  -- I don't want to pay

       4      it either.

       5             But, in terms of the legislation that we're

       6      talking about, I mean, where is your organization

       7      in -- if there's already that type of lending in the

       8      state at that rate, and, again, I'm not asking --

       9      I'm not going to put you on the spot, I'm not asking

      10      you to endorse anything, but, you know, what would

      11      be your thought --

      12             And, again, you know, you don't have to

      13      answer this right now.

      14             -- on adopting a rate that is already being

      15      used in the state for other types of consumer

      16      transactions?

      17             TOM STEBBINS:  I mean, I think the problem

      18      with litigation in particular, is that it is going

      19      to go on a certain period of time; whereas -- and

      20      that is not the choice of the consumer as to how

      21      long that goes on.

      22             A 32 percent interest rate, credit card rate,

      23      you know, somebody can, presumably, work to pay that

      24      off; whereas, on a lawsuit loan, you can't work to

      25      pay that off.  It's not up to you as the consumer.







                                                                   27
       1             SENATOR RANZENHOFER:  Okay.

       2             You had mentioned, right now, it either

       3      should be, you can't have an interest in a law firm,

       4      and, also, a consumer-lending company.

       5             I remember there was a pretty prominent law

       6      firm in my neck of the woods, which is western

       7      New York, where one of the partners of the law firm

       8      was -- he was disbarred or sanctioned because they

       9      had an interest in a lending company.

      10             So, are there already provisions which make

      11      it, if not illegal, you could lose your license or

      12      your license could be suspended when you're doing

      13      that?

      14             TOM STEBBINS:  Well, frankly, I wish we had

      15      seen more from the bar association or the Trial

      16      Lawyers Association on this.

      17             But the sad fact is, many of their members

      18      have commercial interests with these lenders.

      19             And so, you know, while there may have been

      20      sanctions, I'm not exactly familiar with those

      21      particular instances, but, you know, we have not

      22      seen the legal community do a very good job of

      23      policing themselves on this.

      24             And there was a "New York Times" story that

      25      I referenced, just two weeks ago -- or, I believe it







                                                                   28
       1      was --

       2             ADAM MOREY:  About a month ago.

       3             TOM STEBBINS:  -- about a month ago, that

       4      showed this -- these -- this interest of the law

       5      firm in the lender, you know, sending this --

       6      sending the particular case to the lender.

       7             And, frankly, that we don't think that

       8      relationship should exist.

       9             ADAM MOREY:  Yeah, and there's an

      10      investigation in the Southern District, the U.S.

      11      Attorney's Office, into some of these -- some of the

      12      lenders and what they're -- you know, what

      13      they're -- as reported by "The Times," with this.

      14             SENATOR RANZENHOFER:  I don't want to

      15      (inaudible), but I have one more question, and I'll

      16      turn it over to -- turn it back to Senator Jacobs.

      17             Right now, if you're involved in consumer

      18      lending, and you're not successful in the lawsuit,

      19      would it be correct to say that you don't have to

      20      pay that amount back?

      21             Is that --

      22             TOM STEBBINS:  That is correct to say.

      23             But as I mentioned, in the case of the 9/11

      24      fund, and those sorts of things, you're making a

      25      claim.  You are not involved in a lawsuit.







                                                                   29
       1             SENATOR RANZENHOFER:  I'm talking about in

       2      the lawsuits.

       3             TOM STEBBINS:  Right.

       4             No, but in a lawsuit, that is -- I think that

       5      is the primary defense of the lender, is that they

       6      are not -- they don't have to get paid back if the

       7      case doesn't win.

       8             SENATOR RANZENHOFER:  Okay.  So -- and

       9      I don't know if this is feasible.

      10             So if a -- if someone is unsuccessful, and

      11      they did have to pay back a portion of it, would

      12      that be a fair exchange for a higher interest rate?

      13             Because, obviously, there's some risk on a

      14      company, you know, maybe lending, you know, $5,000,

      15      $30,000, whatever, if the claim is not successful,

      16      you know, they're out.

      17             So --

      18             TOM STEBBINS:  And then I would argue, you

      19      would just put that under existing commercial

      20      lending, or existing consumer lending.

      21             SENATOR RANZENHOFER:  Okay.

      22             Well, thank you very much.  I appreciate your

      23      taking the time to answer the questions.

      24             Thank you.

      25             TOM STEBBINS:  Thank you.







                                                                   30
       1             SENATOR ALCANTARA:  What is the percentage of

       2      people that default on their loans?

       3             TOM STEBBINS:  You would have to ask the

       4      lenders of that.

       5             But as I said, in "Crain's New York

       6      Business," one of the largest lenders said that, and

       7      I'll quote them here:  That they use strict

       8      underwriting screening rules to ensure that only

       9      about 4 percent of the cases they advance money are

      10      lost in court.

      11             End quote.

      12             SENATOR ALCANTARA:  Okay.  Thanks.

      13             SENATOR JACOBS:  If I -- Senator Ranzenhofer

      14      mentioned a case from our area, where an attorney

      15      was -- I think had his license suspended for a

      16      period of time because of having an ownership in an

      17      entity.

      18             But -- so there must be a law on the books

      19      for that.

      20             But my question is:  If I had a lending

      21      operation, I was an attorney, and I -- and --

      22      I guess this is part of the question, too, is it

      23      typical that, if I am seeking a loan, that I come to

      24      the lender first, and then get an attorney?  Or is

      25      it usually the attorney that -- they've already gone







                                                                   31
       1      to attorney, and then they are seeking a loan?

       2             TOM STEBBINS:  I think it depends.  I don't

       3      think there's any hard-and-fast rule.

       4             I mean, certainly, you know, one of the

       5      things we've seen is the proliferation of online

       6      advertising in regards to these.

       7             So, you know, obviously, personal-injury

       8      lawyers are already very, very vigorous in

       9      advertising.

      10             And we're seeing the lawsuit lenders doing

      11      the same.

      12             And I guess it just depends on which banner

      13      the consumer clicks on first.

      14             SENATOR JACOBS:  I guess my question was, if

      15      I was an attorney, but not practicing, let's say,

      16      but I had a lawsuit-lending operation, somebody

      17      comes to me for a loan, say, looks like a good case.

      18             TOM STEBBINS:  Right.

      19             SENATOR JACOBS:  I refer to Mike Ranzenhofer,

      20      and I get a referral as an attorney.

      21             TOM STEBBINS:  Right.  And that's one of the

      22      things -- that's one of those conflicts of interests

      23      that we would like to control as part -- and is

      24      controlled in Senator's Ortt's bill.

      25             SENATOR JACOBS:  Oh, it is?  Okay.







                                                                   32
       1             TOM STEBBINS:  Yes.

       2             SENATOR JACOBS:  Okay.

       3             Any other questions?

       4             Thank you very much.

       5             TOM STEBBINS:  Thank you again for having us.

       6             SENATOR JACOBS:  And the next speaker is

       7      Kelly Gilroy.

       8             Thank you for being here.

       9             KELLY GILROY:  Do I need to push anything?

      10             SENATOR JACOBS:  I think you're good.

      11             KELLY GILROY:  Thank you, Chairman Jacobs and

      12      members of the Committee.

      13             I appreciate the opportunity to be here

      14      today.

      15             My name is Kelly Gilroy.  I am the executive

      16      director of the American Legal Finance Association.

      17             ALFA is a trade association made up of

      18      companies that provide this level of funding around

      19      the country.

      20             We were formed in 2004, and we're dedicated

      21      to ensuring fair, ethical, and transparent standards

      22      in this industry.

      23             I just want to give you a little background

      24      and tell you where we stand on the issues, and then

      25      address a few points that were made in the previous







                                                                   33
       1      testimony.

       2             Let me just quickly mention, first, who legal

       3      funding helps.

       4             These are people who have already been

       5      injured through no fault of their own, have already

       6      filed a case or claim, have already hired an

       7      attorney.

       8             This all happens before they are funded by

       9      one of my members, so these are existing cases.

      10             This is not affecting the amount of

      11      litigation, and it's not affecting the amount of

      12      frivolous lawsuits.  These are completely different

      13      things.

      14             What's the money used for?

      15             The money is used for life expenses.  We're

      16      talking about rent payments, groceries, car

      17      payments, house payments, preventing foreclosure;

      18      different things like that.

      19             This money is not needed or used for legal

      20      expenses.

      21             People aren't calling up one of my members

      22      because they need help finding an attorney or

      23      because they want help filing a case.

      24             They're calling because they can't pay their

      25      rent and they can't feed their kids, and they're







                                                                   34
       1      feeling the pressure.

       2             In -- just to be clear, we have supported

       3      legislation, and we are -- we support and want

       4      legislation in New York, but it needs to be

       5      legislation that is appropriate for this product and

       6      it takes into effect its unique nature.

       7             And all the legislation that we have

       8      supported across the country, and what is in the

       9      Dilan bill as well, prohibits any funds from being

      10      used to pay for legal expenses.

      11             So that's just not part of the equation here.

      12             In the states that we've supported, and

      13      worked with regulators to come up with commonsense

      14      regulations, none of those states have subjected

      15      this product to the usury law.

      16             Arkansas is the only state that was mentioned

      17      that did.  And no one in my association does

      18      business in Arkansas because the rate there is not

      19      something that they could possibly live with.

      20             The other states that have regulation --

      21      Oklahoma, Vermont, Tennessee, Indiana, Maine,

      22      Nebraska, and Ohio -- have a special carve-out for

      23      this industry, does not subject to usury.

      24             Tennessee was mentioned a moment ago.

      25             The rate in Tennessee is not 10 percent.  The







                                                                   35
       1      rate is actually closer to 46 percent, so -- a year,

       2      is what's in the law.

       3             And we worked with those states to come up

       4      with consumer protections:  Prohibitions with the

       5      companies -- or, prohibitions for law firms,

       6      commonsense contracts, to make the industry be able

       7      to operate and still protect the consumers in those

       8      states.

       9             We are committed to protecting these

      10      consumers and the process.

      11             So when the bad actors that were mentioned in

      12      the testimony before me, some of the really

      13      egregious cases, we agree.

      14             And we've been involved in several of those,

      15      in trying to find remedies, and speak out against

      16      the practices that we have -- that we think are

      17      egregious.

      18             And, in fact, in the case that was mentioned,

      19      the RD Legal case that's happening right now, that

      20      was a joint case with the New York Attorney General

      21      and the CFPB, we were asked to submit an amicus

      22      brief for that, and we did.

      23             So the kind of regulations we support:

      24             We support strict licensure;

      25             We support an appropriate bond so you know







                                                                   36
       1      you're getting a legitimate company;

       2             Assessment of character and fitness;

       3             Transparency in contracts.

       4             A lot of times, when you've seen problems in

       5      this industry since it came into existence, it's

       6      been because people didn't understand the terms of

       7      their contract.

       8             These kind of things, by standardizing the

       9      contracts, you take care of that immediately.  You

      10      allow the consumer to be able to compare contracts

      11      from three or more companies, and find what -- the

      12      one that works best for them.

      13             We support, you know, right of recision.

      14             So, people take out this money, and then they

      15      change their mind, they can return it without having

      16      any penalty, without having to pay anything.

      17             The Dilan bill does all of these things, and

      18      it also prohibits referral fees, all of those things

      19      that were mentioned before.

      20             And I think -- based on the opening

      21      statements by Senator Ortt, I think there's so many

      22      things we agree on.

      23             We agree about the bad actors.

      24             We don't -- you know, at ALFA, we don't want

      25      those to be part of this industry either.







                                                                   37
       1             And it's not hurting -- it's hurting

       2      consumers, it's hurting the industry, it's hurting

       3      everything.

       4             I just think we disagree on the right way to

       5      do it.

       6             And, unfortunately, in the form that the bill

       7      is right now, subjecting these companies, and my

       8      members, to usury would just eliminate this from the

       9      state of New York.  There aren't companies that can

      10      operate under that.

      11             Basically, the bill treats this as a loan,

      12      and, in fact, it's very different.

      13             Loans require a lot of things that are not --

      14      that are not in existence here.

      15             There are no credit checks.

      16             There are no income or employment

      17      verification checks.

      18             There's no collateral.

      19             People aren't paying interest payments.

      20             There's no fixed maturity date.

      21             So, basically, when a person -- when a

      22      company funds someone, they don't know when, or if,

      23      they'll ever be paid back.

      24             And in the event that they don't receive any

      25      money back, they don't -- there's nothing they can







                                                                   38
       1      do, there's no recourse.

       2             They don't garnish wages.  They don't

       3      repossess cars.  They don't affect your credit.

       4      There's no debt creation here.

       5             So it's a very different product, even though

       6      I understand why people kind of want to jump to call

       7      it "a loan."

       8             It is a very unique, different product.

       9             I think you know that, in this economy, if

      10      you walked in a bank and said, I need even a loan

      11      for $1,000, and you didn't have a job, you had

      12      horrible credit, and you didn't have anything you

      13      were going to put up for it, you didn't tell --

      14      couldn't tell them when you were going to pay them

      15      back, and they couldn't do anything to you in the

      16      end, I think they would laugh you out of the -- out

      17      the door.

      18             So a couple other things that were mentioned

      19      in the previous testimony that I think merits some

      20      discussion are the risks mentioned.

      21             So, it was mentioned that a company said they

      22      have strict underwriting, and they do.  And that's a

      23      good business practice, because -- and, that,

      24      I think, points to the fact that these aren't

      25      frivolous cases.







                                                                   39
       1             People are looking at them, and trying to

       2      find cases that have merit, and make sense.

       3             But with all of that said, it's still a very

       4      risky transaction.

       5             Companies don't know when they're going to

       6      get paid back, and they don't know if they will.

       7             So even with all you can know, and how good a

       8      case can look, there are so many unknowns when

       9      you're dealing with litigation.

      10             You could fund right today, and then in

      11      discovery it turns out that the injury that the

      12      client had was actually preexisting from something

      13      that happened 10 years before, and you might not get

      14      paid back.

      15             There's a lot of unknowns, and the risk is

      16      very real.

      17             Our members have reported that, sometimes, as

      18      high as, like, 10 percent of the time they can get

      19      nothing back at all.

      20             But what happens often here, which is another

      21      thing you don't find in credit cards or loans or car

      22      payments, or anything like that, is that, when a

      23      person goes to settle, although that attorney is

      24      settling the case, they often reach out to the

      25      company and say, You know what?  This is settling







                                                                   40
       1      for a lot less than we thought.  There's not going

       2      to be enough to pay you back what was in the

       3      contract.  Can we cut that down?

       4             And that happens all the time.

       5             So that's something else that makes it

       6      unique.

       7             And something else I think is just kind of an

       8      interesting part of this discussion, especially when

       9      it seems like we agree on a lot of things about how

      10      to do it, but some of the methods are a little

      11      different, it was mentioned earlier that a lot of

      12      these cases go out for three to five years, and that

      13      that's not fault of the plaintiff.

      14             And that is -- I couldn't agree more.

      15             But what's happening here, is these

      16      plaintiffs are being sweated out by the people on

      17      the other side of the lawsuit.

      18             They know you don't have money.

      19             They know when you're going to run out.

      20             They know you need to -- you might lose your

      21      house.

      22             And they think you're gonna settle your case

      23      if you don't have something that's going to help

      24      you.

      25             And what legal funding does, and what my







                                                                   41
       1      members do every single day, is step in and take the

       2      pressure off, and help level the playing field, and

       3      help them take care of those expenses, so they can

       4      make a -- the right decision with their attorney for

       5      when the case should be settled.

       6             We are committed to regulation, as I said.

       7             We are open to talking about any part of this

       8      process.

       9             But, right now, the way it stands, the -- you

      10      know, Senator Ortt's bill would put us out.

      11             And so we're leaning more towards the Dilan

      12      bill.

      13             But we are happy to keep the discussion

      14      going, and talk to -- you know, work with any

      15      stakeholders to come up with a fair solution.

      16             SENATOR ORTT:  Thank you.

      17             Senator, any questions?

      18             SENATOR ALCANTARA:  Yes.

      19             Are you -- the members that you represent,

      20      are they non-profits?

      21             KELLY GILROY:  No.

      22             SENATOR ORTT:  Okay.

      23             So I was interested, because, you know,

      24      Miss Gilroy, you come here and, you know, you say

      25      it's not a loan.  It's just something out of -- you







                                                                   42
       1      know, like, from hearing your speech, it almost

       2      confused me with Catholic Charities, because now you

       3      guys make it sound like this is something so nice

       4      and cute you guys are doing for people.

       5             You know, when, in reality, these -- if

       6      they're not loans, what are they?

       7             KELLY GILROY:  You know, it's just a

       8      different kind of financial product.

       9             I mean, it is -- you're right, it is a

      10      financial transaction, and the companies are there

      11      to make money, they're for-profit things.

      12             But the requirements of when you get a loan,

      13      those people know they're going to get paid back.

      14             And a credit card, they're going to get their

      15      money back.

      16             Like, that doesn't happen here.

      17             If you walk away from the case, if you move,

      18      if you drop it, if you lose, they don't get any

      19      money back, not even the principal.

      20             So in the case where you lose your case, you

      21      still got to keep the couple thousand dollars, or

      22      whatever it was.

      23             SENATOR ALCANTARA:  What percentage of the

      24      clients default on this loan?

      25             KELLY GILROY:  I can give you generalities







                                                                   43
       1      based on my members.

       2             We have 43 members, and we have people, our

       3      members report, that, like, in 10 percent of the

       4      cases they don't get paid back at all.  And, you

       5      know, in, probably, about 15 to 20 percent, they

       6      take reductions or they don't get paid back the full

       7      amount that's in the contract.

       8             SENATOR ALCANTARA:  But is -- what the normal

       9      interest rate for the companies, for the

      10      organizations, you represent?

      11             KELLY GILROY:  We don't -- we don't focus on

      12      interest rates because of antitrust laws for our

      13      association.

      14             It's different for every company and every

      15      case.

      16             But I will tell you, we were involved in the

      17      legislation that passed in Tennessee and in Indiana,

      18      that both have interest rate caps in them, and

      19      they're nowhere close to the rates that they

      20      disclosed.

      21             Tennessee's is 46, and Indiana's is 42.

      22             SENATOR ALCANTARA:  I'm sorry, Miss Gilroy,

      23      but I -- you know, we need specific.

      24             You know, you come here to testify.

      25             This is my second question, and you're giving







                                                                   44
       1      me general answers.

       2             KELLY GILROY:  Well, I don't have --

       3             SENATOR ALCANTARA:  You know, if you are in

       4      the state of New York, I need to know specifically.

       5             The young man that was before you, we ask

       6      him, was the average number of companies that

       7      default?

       8             And he was able to tell me about 4 percent.

       9             I'm not in Tennessee.  I'm not in Texas.

      10             I'm in New York.

      11             So, I am sorry, I would like to know what

      12      percentage of your companies, what's the percentage

      13      of interest rate that they charge?

      14             KELLY GILROY:  Okay.  I can -- we can --

      15      I can get information from the companies

      16      I represent, and we can get back to you with more

      17      specifics.

      18             But, all due respect to the gentleman before

      19      me, he was speaking generally about things that

      20      he -- I mean, those aren't -- that's not -- that

      21      wasn't evidence.  That wasn't real -- those aren't

      22      real numbers.  Those are things that are

      23      generalities, that there's -- there's not evidence

      24      to what he's saying.

      25             SENATOR ALCANTARA:  So he made it up?







                                                                   45
       1             KELLY GILROY:  I mean, he could have read it

       2      somewhere.  But that's not -- that's not -- like,

       3      this is not evidence-based.

       4             Most of the things that that side is saying

       5      are anecdotal.

       6             Like, "I read a horrible story."

       7             And I read those horrible stories too, but

       8      that's not -- doesn't mean that that's exactly how

       9      it plays out.  That's not the way it is every day in

      10      the business.

      11             SENATOR ALCANTARA:  Oh.  And did he tell you

      12      that he picked up this information from out of the

      13      sky, or are you assuming?

      14             Sorry.

      15             You know, I just want to say, Senator Jacobs,

      16      I think we should be respectful of other people's

      17      information because, I was a union organizer for the

      18      nurses union.  And I myself saw trucks outside of my

      19      hospital, giving people business cards, asking them

      20      to take out a loan for their injuries and so.

      21             So, I would assume that, if he came here

      22      representing an organization, that he did, probably,

      23      a little bit more research than you do, because you

      24      don't even have any numbers for us, any percentage.

      25             You are talking to me about Tennessee, and







                                                                   46
       1      all these other places, that they are nice places,

       2      but I don't live there.

       3             So when you can come to me and tell me

       4      numbers, then we can argue about the information he

       5      gave us.

       6             Thanks.

       7             KELLY GILROY:  May I just say something?

       8             SENATOR ORTT:  Sure.

       9             KELLY GILROY:  Just to be -- just -- I --

      10      I think I was -- didn't -- wasn't clear in the way

      11      I said it before.

      12             The only reason I mentioned the other states

      13      are because those are some of the only states that

      14      have laws.

      15             I recognize it's very different from

      16      New York.

      17             I'd be happy to find those numbers from you.

      18             Someone standing outside and handing business

      19      cards, those are exactly the bad actors that we

      20      agree, Senator Ortt, Assemblymember Dilan, all the

      21      people agree, those are horrible business practices

      22      that my members don't do.

      23             There are bad actors.

      24             And we want to see regulation that will push

      25      those bad people out, so that the people who need it







                                                                   47
       1      have access to legitimate operating companies who

       2      are not there to take advantage of them, but are

       3      being clear and, you know, forthright in how they're

       4      handling this.

       5             So I apologize, I wasn't clear about

       6      (inaudible).

       7             SENATOR ALCANTARA:  This will be my last

       8      question.

       9             Your company, do you guys give out the loan

      10      information in any other language besides English?

      11             KELLY GILROY:  So for the trade association,

      12      our members, what they do, they -- that's the thing

      13      that we've supported in other regulation as well,

      14      that people get a contract in the language that they

      15      speak.

      16             SENATOR ALCANTARA:  Do they do that now?

      17             KELLY GILROY:  Yes.

      18             SENATOR ALCANTARA:  Okay.  So if I am in

      19      The Bronx and I speak Spanish, I would get a

      20      contract in English -- in Spanish?

      21             KELLY GILROY:  If you are dealing with one of

      22      the ALFA members.

      23             I can't speak to what some of these other

      24      companies, that are the ones who are -- are doing.

      25             SENATOR ALCANTARA:  Would you argue that







                                                                   48
       1      that's why we need some sort of regulation?

       2             KELLY GILROY:  Absolutely.

       3             SENATOR ALCANTARA:  Because we need to have a

       4      uniform --

       5             KELLY GILROY:  Absolutely.

       6             SENATOR ALCANTARA:  -- on how these companies

       7      operate.

       8             And, last -- I'm sorry, Senator Jacobs.

       9      I don't want to hijack the -- but I'm an only child,

      10      so I talk a lot.

      11                  [Laughter.]

      12             SENATOR ALCANTARA:  My other question is:

      13             You say that there might be a 10 percent

      14      default rate.

      15             But, if some companies are charging about

      16      100 percent interest rate, would they not make up

      17      the money in that?

      18             And, also, I find it hard to believe that

      19      organizations that are non-non-profit, that you are

      20      taking a risk in lending people money, because this

      21      is what they are: loans.

      22             They're not a gift.  You know, they're not a

      23      present.

      24             They're loans, because you are expected to

      25      pay them back.







                                                                   49
       1             That there has got to be a profit.  This is a

       2      business.  You know, there -- people are making

       3      money on this.

       4             So if there were so many people defaulting on

       5      this, then you would not be representing

       6      43 organizations, or companies.  Correct?

       7             KELLY GILROY:  Well, it is a business.

       8             And my point with the loss rate is that, it's

       9      one of the reasons that you -- it's hard to treat it

      10      like a loan.  The rates are higher than a

      11      traditional loan for those exact reasons.

      12             There's higher -- there's a higher risk, and

      13      all of those other things about the unknown.

      14             There's no guarantee that you'll get paid

      15      back like there is with some other things.

      16             SENATOR JACOBS:  Senator Ortt?

      17             SENATOR ORTT:  Ah, yes.

      18             Good morning -- or, afternoon.

      19             So I want to start with a comment, a general

      20      statement, and then I'll go into some questions.

      21             First of all, I agree with some of the things

      22      you said.

      23             I think everyone here, I think the focus is

      24      to bring some oversight, some guidelines, some

      25      standard practices, to this industry, which,







                                                                   50
       1      clearly, there aren't.  I mean, it's hard to argue

       2      there would be.

       3             Right now you're sort of left to the ethics

       4      or guidelines of whatever individual lender you may

       5      have.

       6             To Senator Alcantara's point, I think --

       7      look, I think it's -- to me -- I'm not a lawyer, I'm

       8      not a banker.  It's clearly a loan, because, to me,

       9      a loan is something that has to be paid back.

      10             That's sort of the criteria that I would say.

      11             If you don't have to pay it back, then you

      12      can come up with a lot of other names for it.

      13             But if it's a -- if there's an expectation of

      14      payment, to some degree, then I would say it's a

      15      loan.

      16             Now, to your point, obviously, the criteria

      17      for it are very different than if you went into a

      18      bank.  Right?

      19             And maybe it is a unique product.

      20             That might be a fair point, that there is a

      21      uniqueness to this lending, or to this type of loan,

      22      that would maybe necessitate some other rate or

      23      structure or guidelines.

      24             But I wanted to ask you:  So what is the

      25      criteria?







                                                                   51
       1             So they're not -- we know they're not

       2      financial, like if you went in for a loan.  There's

       3      no credit checks, you said, all those kinds of

       4      things.

       5             But there surely must be some criteria,

       6      because I'm certain that some people might be turned

       7      away, and some people might be loaned a certain

       8      amount.

       9             So what are the criteria that go into whether

      10      you loan to somebody or not?

      11             KELLY GILROY:  Well, as I mentioned earlier,

      12      they have to have already had a claim or case --

      13             SENATOR ORTT:  Right.

      14             KELLY GILROY:  -- they already have to have

      15      an attorney; it's already in the process.  And then

      16      they reach out to the companies.

      17             The companies want to know what the liability

      18      was.  You know, what are -- the insurance, you know,

      19      what are the limits on it.  And that kind of thing.

      20             And that's what they're looking at.

      21             They're not looking for privileged

      22      information when they -- when they do that kind of a

      23      thing.  But they're looking for, you know, is there

      24      good potential that is going to -- that is going to

      25      settle?







                                                                   52
       1             That being said, there's still a lot of

       2      unknowns that make it where you don't know if it's

       3      going to settle, or if it's going to settle for a

       4      lot less.

       5             SENATOR ORTT:  Okay.  But, I mean, from a --

       6      I guess, maybe from a legal standpoint, they're

       7      looking at, obviously, the likelihood that it will

       8      settle and there will be some ability for that

       9      person to then pay them.  Right?

      10             So there is still some criteria, I would

      11      argue, that goes into the decision to loan.

      12             KELLY GILROY:  Absolutely.

      13             SENATOR ORTT:  Obviously (indiscernible) --

      14      right.

      15             And so it might not be financial.  It might

      16      be more of a legal criteria that goes into it.

      17             And, obviously, there's still an expectation,

      18      if that settled, there will be a payback.

      19             Are there standard practices that your

      20      association puts out to its members?

      21             KELLY GILROY:  Yes, our members adhere to

      22      best practices when they join the organization.

      23             And the attorney -- the New York Attorney

      24      General agreement that was agreed to many years ago,

      25      is one of the things that was mentioned, and that







                                                                   53
       1      was with the founding members of my organization.

       2             So the people who join ALFA follow those best

       3      practices.  And we have strengthened -- based on the

       4      New York Attorney General agreement, but those have

       5      strengthened over time as we've passed other laws in

       6      other states.

       7             But it's ALFA members who are -- who are

       8      adhering to those practices.

       9             Other companies, and there are a lot of

      10      companies that I don't even -- I'm not even aware of

      11      because they're small companies, and there's other

      12      companies, that don't adhere to those.

      13             SENATOR ORTT:  Sure.

      14             KELLY GILROY:  So that's why you need some

      15      regulation to.

      16             SENATOR ORTT:  No question.

      17             And I think that goes to the concern that

      18      I have, and I think a point that was made earlier

      19      was, there -- certainly, there's always, in Albany,

      20      and in any form, I guess, any capital, any

      21      governmental body, there's always the debate,

      22      I believe, is to, how do we get there?

      23             We all like to think that we're trying to get

      24      to the same spot, but maybe we have different ways

      25      of getting there.







                                                                   54
       1             But I think, to your point, without some

       2      structure on the rate, I think you're really --

       3      you're not putting enough teeth to getting the bad

       4      actors out.

       5             So that's where I come from, and, certainly,

       6      my -- my -- my position has been, I think that a lot

       7      of the other stuff you mentioned in the other piece

       8      of legislation sponsored by Senator Dilan, a lot of

       9      good things in there, and I think a lot of things

      10      that can be part of a possible piece legislation

      11      that comes through.

      12             But I think without some -- you know, and we

      13      can argue about the rate or argue about how it's

      14      structured.  But I think some type of rate

      15      structure, where someone that goes in has some idea

      16      of what they might have to pay back.

      17             I know of companies that say, Here's the

      18      money.  And after it's settled, when you come back,

      19      then we'll talk about what you have to pay us.

      20             Now --

      21             KELLY GILROY:  Right.

      22             SENATOR ORTT:  Now, I'm not saying that's any

      23      of your members.

      24             I don't know if we know, but I know that's

      25      not your -- certainly, that's not your best







                                                                   55
       1      practices, and I get all that.

       2             But I know that's happening.

       3             When we made phone calls to some of these

       4      companies, you know, you've heard of the high rates.

       5      I'm sure there's lower rates.

       6             But the fact of the matter is, to me, if I'm

       7      going in, whether -- whatever the criteria might be,

       8      if somebody loans me an amount of money, I should

       9      have some sense of what that payment, amount,

      10      schedule, all of that, would be.  And I think,

      11      anything less than that, we're still going to be

      12      having some of these same discussions after the

      13      fact.

      14             You know what I mean?

      15             So the goal is to try to get this right, as

      16      best we can, out of the gate.

      17             Do you -- now -- and I'm going to run through

      18      just two more questions, and you may have answered

      19      them or you may discussed it with Senator Alcantara.

      20             We talked about:

      21             Factors that go into deciding a case.

      22             Percentage of cases that you finance.  I know

      23      it's hard to -- or maybe you do know that.

      24             Do -- do you -- the amount of cases that --

      25      like, as far as cases that might come in the door,







                                                                   56
       1      versus cases that actually may receive financing,

       2      even if you could provide me a rough estimate.

       3             KELLY GILROY:  There is a person who is going

       4      to testify --

       5             SENATOR ORTT:  Later?

       6             KELLY GILROY:  -- after me who I think has

       7      that.

       8             SENATOR ORTT:  Who has that?

       9             KELLY GILROY:  I just wanted to mention that.

      10             SENATOR ORTT:  Okay.  Good.  That's perfect.

      11             I will save that, then.

      12             And then, do you see -- and I'm guessing the

      13      answer is yes, but I'm going to ask it anyways:  Do

      14      you see any possible conflict, or do you understand,

      15      I guess, the concern between law firms and lenders,

      16      possible steering of clients to one particular

      17      lender over another, and, specifically for me, which

      18      I've kind of recently learned, with regard to

      19      surgical funding, and surgical-funding products, and

      20      selective surgeries?

      21             I mean, can you understand the concern there,

      22      or do you see a conflict there?

      23             KELLY GILROY:  I understand the concern.

      24             And, you know, I think that what legislation

      25      that we have supported, and that we support now, an







                                                                   57
       1      attorney -- this was kind of asked earlier -- but

       2      the attorney can't have an interest in a company

       3      that's funding their clients.

       4             SENATOR ORTT:  Okay?

       5             KELLY GILROY:  So that's not to say that they

       6      couldn't have a company.  But they couldn't have an

       7      interest in one that's funding their own clients.

       8             SENATOR ORTT:  Okay.

       9             KELLY GILROY:  And kind of -- whether --

      10      whatever the money is being used for, and whether,

      11      depending on the -- whatever kind of case it is,

      12      I mean, we want the same things.

      13             We want consumers who are coming in to know

      14      what they're getting into.

      15             We want it to be really clear.

      16             We want the terms to be crystal-clear so

      17      there's no question.

      18             And we want to know that there were no

      19      referral fees between the attorney and the funding

      20      company or any other medical providers, or anything

      21      else.

      22             And when you were asking me about the rate,

      23      and saying about people's need to understand,

      24      I think we need to point out to you, I think the

      25      Dilan bill requires a schedule.







                                                                   58
       1             And that's one of the things that we have

       2      seen, that we've done in other places, and my

       3      members do this.

       4             I mean, it would say, that you would include

       5      a schedule.  On the first page of the contract, it

       6      would say, in very clear terms:  How much money

       7      you're getting.  Any fees associated with it.  And

       8      it would say, in points of time, how much you would

       9      pay back.

      10             So it would say:  Today I took out, you know,

      11      this amount of money.  And if you pay it back

      12      between today and six months, you owe X.  If you pay

      13      it back between six months and a year, you owe Y.

      14             And so the bottom number on that schedule

      15      would be the most you would ever be expected to pay

      16      back, and it oftentimes could be, and would be,

      17      less.

      18             So it's not like a chart that shows you,

      19      like, this is how much you pay every month, because,

      20      like a traditional loan, you make monthly payments.

      21             In this you don't.

      22             So it would just say:  All right.  I'm

      23      settling my case.  It's been a year and a half.

      24             You would pull down to where that is on the

      25      chart, and that number is what you will you pay







                                                                   59
       1      back.  And the very bottom number would be for the

       2      entire life of the contract, the most it could

       3      possibly be that you would ever owe.

       4             So there would never be a point where you

       5      would go to settle your case, and you would go, I

       6      had no idea that I owed this.

       7             And that's something that happened in some of

       8      the cases that have been in the media, and mentioned

       9      before, and some of the things before the New York

      10      Attorney General agreement.

      11             So, I mean, we agree, people need to, when

      12      they take this out, know in the most basic, clear,

      13      commonsense terms, "I'm taking out this amount

      14      money, and this is the most I could pay back," so

      15      they can make that decision, because maybe this

      16      isn't the right thing for them, because it's not for

      17      everyone, and it's, certainly, not for every case.

      18             But, in the cases where people really need

      19      it, it's a very valuable tool that I think that has

      20      been a good lifeline for them.

      21             SENATOR ORTT:  Thank you.

      22             SENATOR JACOBS:  Mike, do you have --

      23             SENATOR RANZENHOFER:  Yes.

      24             First question I wanted to ask:  You had

      25      mentioned that, I think, there were 37 members of







                                                                   60
       1      your association?

       2             KELLY GILROY:  43.

       3             SENATOR RANZENHOFER:  43.  Okay.

       4             I should have written that down and I would

       5      have remembered.

       6             So of your 43 members, how many businesses

       7      are there in the state that engage in the practice,

       8      so I can figure out how many are members of your

       9      association, and what's the total number?

      10             KELLY GILROY:  I can't speak to the number of

      11      companies that are not part of my association,

      12      because there are companies that are small, that are

      13      one person, that are not people that we would be

      14      aware of.

      15             But, I mean, we make up a -- we make up a

      16      pretty sizeable portion of it, I would say, because

      17      we have some very large members that are based here.

      18             SENATOR RANZENHOFER:  I mean, would you --

      19      would you be able to give us an estimate?

      20             Are there 5 other companies? 50 other

      21      companies?

      22             I mean, do you have any inkling of how many

      23      other companies that are out there?

      24             KELLY GILROY:  I mean, I would say there's

      25      probably -- there is probably more than 20 --







                                                                   61
       1      there's more than 20 other companies.

       2             SENATOR RANZENHOFER:  Okay.

       3             So it appears, from Senator Ortt's

       4      questioning, that there is some agreement in terms

       5      of the need for regulation.

       6             And to Senator Alcantara's point, you know,

       7      making sure that a contract is in the language that

       8      the person speaks.

       9             And to Senator Ortt's point, to have a

      10      schedule so the person knows exactly what they have

      11      to pay.

      12             It appears to me, and I'm going to come back

      13      to this, because this is what I was asking the

      14      previous individual that testified, is, you know, if

      15      this company -- you know, this type of company or

      16      service is going to exist in the state of New York,

      17      really, what's the trade-off between, you know,

      18      having a fixed rate or not a fixed rate, versus a

      19      consumer being able to avail himself or herself of

      20      the products?

      21             So, you had mentioned that one of the things

      22      they don't look at, is they don't look at a

      23      consumer's assets, they don't look at a consumer's

      24      ability to pay, because, obviously, they're hoping

      25      for a settlement and be able to get paid that way.







                                                                   62
       1             So -- I mean, I see the difference in the

       2      type of product because, you know, if you default on

       3      a car loan or you default on a bank loan, you know,

       4      they can come after you and seize your assets, and

       5      you would have to file bankruptcy in order to avoid

       6      that.

       7             Here, if you don't pay, you know, the company

       8      is just out of luck.  They have no recourse against

       9      you.

      10             So it seems to be, to me, that you had

      11      mentioned, in other states -- and, again, I know

      12      this is, Tennessee and Indiana are not New York --

      13      you know, in other states they have interest rates

      14      that are in the 40s.  I think 42 percent and

      15      46 percent were mentioned.

      16             You know, to me, it seems the question is:

      17             If we want to have this service in the state

      18      of New York, and to allow consumers to avail

      19      themselves of the service, and not have the risk of

      20      having to pay, so maybe you could have a lower rate,

      21      but then, you know, you'd have to make the consumer

      22      qualify for it.  So there would have to be a

      23      financial background check.  Or, maybe, if the

      24      consumer lost his case, maybe that consumer would

      25      still have to pay back.







                                                                   63
       1             You know, I think that has to be reflected in

       2      the rate discussion.

       3             So, I do -- you know, I am very, you know,

       4      happy by the fact that everybody agrees that there

       5      are some basic ground rules that have to be in place

       6      with respect to consumer protection.

       7             And it seems to me, I mean, the issue that

       8      really is at the forefront is:  What are we doing

       9      about an interest rate versus, you know, companies

      10      being able to do business in the state?

      11             And, if we're going to -- you know, if we're

      12      going to make this service less available to

      13      consumers, to protect them, then what do you do with

      14      respect to the interest rates?

      15             So -- I didn't really have any questions.

      16             I mean, that's just the way -- that's the

      17      sense I get from this hearing.

      18             I'm sure we're going to hear from more

      19      speakers, although I have another committee meeting

      20      I got to go to.

      21             But, thank you, as I thanked Mr. Stebbin, for

      22      your testimony today.

      23             KELLY GILROY:  Thank you.

      24             SENATOR ALCANTARA:  Hi, Miss Gilroy.

      25             My -- I have two more questions.







                                                                   64
       1             When Senator Ortt asked you about the best

       2      practice, that you guys have a sheet that your

       3      members distribute out to consumers, can the

       4      Committee get a copy of the best practice?

       5             KELLY GILROY:  Oh, we can get you a copy of

       6      our best practices, yes.

       7             SENATOR ALCANTARA:  Okay.  Great.

       8             And my -- oh, the last question:  What

       9      percentage of the New York market does your

      10      43 company -- what percentage of the market in

      11      New York do you guys dominate?

      12             KELLY GILROY:  I can really only speak to the

      13      number of -- the people that I represent, because

      14      there's companies I don't know about.

      15             SENATOR ALCANTARA:  That's all right.

      16             KELLY GILROY:  I would assume it's probably

      17      the larger part of it, though, because, if there

      18      were very big companies operating here, we would

      19      know about those.

      20             And I think they're mostly, the ones who

      21      aren't members, are smaller players.

      22             So -- I mean, I would -- over half,

      23      I would -- that's my assumption.

      24             SENATOR ALCANTARA:  So your 43 companies,

      25      they all operate in the state of New York?







                                                                   65
       1             KELLY GILROY:  They don't all operate in the

       2      state of New York.

       3             They are -- some of them are big companies

       4      that operate all across the country.  Some are

       5      smaller companies that might only work in one state,

       6      here and there.

       7             SENATOR ALCANTARA:  So out of those 43, how

       8      many operate in New York?

       9             KELLY GILROY:  We have about a dozen that are

      10      based in New York, that are, like, New York

      11      companies.

      12             SENATOR ALCANTARA:  No, that do business in

      13      New York.

      14             KELLY GILROY:  Oh.  Probably 38.

      15             SENATOR ALCANTARA:  Okay.  Thank you.

      16             Thank you.

      17             SENATOR JACOBS:  Two quick things.

      18             The -- these best practices, I was just

      19      wondering, is there a standard contract that members

      20      in ALFA adhere to?

      21             KELLY GILROY:  Yes.  We actually have a -- we

      22      have a model contract that we have been working on

      23      that has -- is being implemented right now.

      24             We worked on it in conjunction with some of

      25      the work we were doing with the CFPB and others, to







                                                                   66
       1      make sure that the contracts are up to the highest

       2      standards and clearer disclosures that we can get.

       3             SENATOR JACOBS:  Okay.  And I just wanted to

       4      give you an opportunity to explain, just briefly,

       5      you answered him why you couldn't tell what the

       6      interest rate, when you say "antitrust."

       7             I just wanted you to elaborate why that --

       8             KELLY GILROY:  So, as a trade association, we

       9      don't discuss pricing.  Like, at our meetings, we

      10      don't say, How much are you guys charging?  You

      11      can't charge more than this.

      12             We talk about other business practices --

      13             SENATOR JACOBS:  Got you.

      14             KELLY GILROY:  -- and those kinds of things.

      15             SENATOR JACOBS:  I just thought that would be

      16      important to be clear.

      17             SENATOR ORTT:  Can I just ask just one last?

      18             Are there any incentives, you know, for -- to

      19      refer a client to a lender, that are out there?

      20             I mean, is there any incent -- what is the

      21      incentive, I guess, for a referral --

      22             KELLY GILROY:  I mean, I think that attorneys

      23      would refer people to specific companies because

      24      they worked with them in the past and they know

      25      them.  They like the way they do business.  They get







                                                                   67
       1      it done fast, or they -- things like that, just a

       2      general preference.

       3             SENATOR ORTT:  Okay.

       4             KELLY GILROY:  But I think, a lot of times,

       5      and very oftentimes, the consumer comes to the

       6      company, finds the company, and then tells their

       7      attorney, I want to work with this firm.

       8             SENATOR ORTT:  Okay.

       9             SENATOR JACOBS:  All right.  Thank you very

      10      much.

      11             KELLY GILROY:  Thank you.

      12             SENATOR JACOBS:  And now I'm going to -- and

      13      thank you, Senator Ranzenhofer.  I know you need to

      14      go.

      15             SENATOR RANZENHOFER:  Thank you for letting

      16      me ask questions about -- on the Committee.

      17             SENATOR JACOBS:  Absolutely, absolutely.

      18             And now, Professor Steinitz.

      19             Whenever you're ready.

      20             PROF. MAYA STEINITZ:  Thank you very much.

      21             SENATOR JACOBS:  Thank you.

      22             PROF. MAYA STEINITZ:  Good afternoon,

      23      Chairman Jacobs and members of the Committee.

      24             I thank you for giving me the opportunity to

      25      provide feedback on the pending legislation.







                                                                   68
       1             My name is Maya Steinitz, and I'm a professor

       2      of law at the University of Iowa College of Law, and

       3      a visiting professor at Harvard Law School.

       4             Third-party litigation financing is one of my

       5      main fields of expertise as an academic.

       6             I have published papers relating to

       7      third-party funding, and have recently taught a

       8      course on the subject at Harvard.

       9             Third-party litigation finance is a service

      10      with great potential if harnessed in the correct

      11      way.

      12             Litigation financing can help indigent

      13      plaintiffs access justice in their (indiscernible)

      14      mediations for harms; however, like all financing,

      15      it's open to abuse.

      16             Everyday consumers are particularly

      17      vulnerable, and an appropriate consumer protection

      18      regime needs to be put in place.

      19             The pending bills, therefore, are to be

      20      commended.

      21             My comments will focus on three main

      22      suggestions in reaction to the current bills.

      23             First, I wish to note that the Assembly bill

      24      does not, strictly speaking, regulate litigation

      25      finance; rather, it would regulate financing of a







                                                                   69
       1      consumer's costs while the litigation is pending.

       2             Specifically, the bill forbids

       3      litigation-finance companies from paying court costs

       4      or attorney's fees, and requires the borrowers to

       5      have a contingency-fee arrangement with an attorney

       6      in place.

       7             The Senate bill lacks this prohibition and

       8      would allow the financing of the actual litigation.

       9             Such financing, if allowed, can create

      10      competition for financing vis-a-vis contingency

      11      fees, and may, therefore, reduce the cost of

      12      litigation finance for consumers.

      13             It's, therefore, in my view, preferrable to

      14      permit it.  And if it is permitted, it should be

      15      covered by the protections contemplated by the

      16      bills.

      17             My second suggestion is to define the scope

      18      of protection by focusing on the characteristics of

      19      the plaintiff rather than on the amount of

      20      financing.

      21             The Senate version of the bill exempts

      22      contracts offering non-recourse financing of more

      23      than half a million dollars from its scope, while

      24      the Assembly version provides no such exemption.

      25             In my opinion, the Senate version of the bill







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       1      represents the correct direction, in the sense that

       2      the Senate bill's attempts to focus its protection

       3      on those individuals who are less-sophisticated

       4      litigants by exempting high-dollar

       5      litigation-financing contracts from its

       6      (indiscernible).

       7             Nonetheless, it would seem that a dollar

       8      amount is an imperfect way to capture the difference

       9      between the different kind of litigation-finance

      10      consumers.

      11             I, therefore, suggest protecting

      12      unsophisticated plaintiffs.

      13             In making this suggestion, I'm drawing from

      14      the field of securities litigation, where the law

      15      distinguishes between sophisticated investors and

      16      unsophisticated investors.

      17             My third suggestion is to ensure appropriate

      18      plaintiff recovery by setting a statutory minimum

      19      recovery requirement.

      20             It's critically important that third-party

      21      litigation finance does not lead to a drastic

      22      reduction in plaintiff's recovery.

      23             The concern is that the combination of the

      24      compensation of third-party funders and the

      25      attorney's contingency fees would, separately or







                                                                   71
       1      combined, leave the wronged or injured plaintiff

       2      without meaningful recovery in remediation.

       3             To achieve this goal, the bills focus on the

       4      methodology through which the funder's return is

       5      calculated.

       6             The Senate bill sets a limit on the

       7      percentage of the return, and the Assembly bill

       8      requires a flat rate.

       9             I propose that, rather than focusing on the

      10      financier's return formula, the statute directly

      11      guarantees a minimum return to the plaintiff.

      12             In order to guarantee this minimum return,

      13      the focus will need to broaden to include both the

      14      contingency fees of attorneys and the litigation

      15      finance -- funder's return, and ensure that the

      16      return of both lawyer financiers and third-party

      17      financiers, combined, do not exceed the plaintiff's

      18      minimum recovery requirement.

      19             Currently, generally speaking, in

      20      personal-injury cases, the return on lawyer's

      21      litigation finance, with contingency fee, are capped

      22      in New York at a third of the total recovery,

      23      barring extraordinary circumstances.

      24             If funders are allowed, as the bills

      25      currently envision, funding living expenses and







                                                                   72
       1      similar expenses, which lawyers are prohibited from

       2      advancing to their clients, the combined minimum

       3      return to all financiers, the lawyers and the

       4      funders, should be somewhat higher than a third.

       5             But to keep the spirit of the current

       6      limitation, on return on litigation finance should

       7      probably not exceed half of the recovery.

       8             Therefore, if my suggested approach is

       9      adopted, the statute could ensure, for example, a

      10      minimum recovery for the plaintiff of no less than

      11      50 percent, barring extraordinary circumstances.

      12             Thank you very much for offering me this

      13      opportunity, and I welcome your questions.

      14             SENATOR JACOBS:  Any questions?

      15             SENATOR ALCANTARA:  Yes, a point of

      16      clarification:  Which of the Senate bills were you

      17      speaking of: Dilan or Senator Ortt?

      18             PROF. MAYA STEINITZ:  Which of the Senate

      19      bills?

      20             SENATOR ALCANTARA:  Yes, ma'am.

      21             PROF. MAYA STEINITZ:  The ones that I have

      22      been provided.

      23             I hope I'm reading the right number, 3911-A.

      24             SENATOR ALCANTARA:  Okay.  Thank you.

      25             SENATOR JACOBS:  Well, of course,







                                                                   73
       1      I apologize.  I had to step out.

       2             The kid's got to eat.  Right?

       3             So -- but I missed part of your testimony.

       4             It sounded like, as I came in --

       5             And I thank you for being here, by the way.

       6      Especially with your credentials, I'm sure you can

       7      add a lot to this discussion.

       8             -- so were you suggesting that there be,

       9      essentially, whatever is ultimately determined, that

      10      the key is to make sure that whatever is paid out

      11      does not exceed the award?

      12             Did I hear that correctly?

      13             PROF. MAYA STEINITZ:  Actually -- well,

      14      that's -- I'm offering something more generous to

      15      the plaintiffs.

      16             SENATOR ORTT:  Of course.

      17             PROF. MAYA STEINITZ:  But, that's the way I'm

      18      thinking about it.

      19             So I'm thinking, what we're trying to do

      20      here, I think, is to ensure that, at the end of the

      21      day, the plaintiff, who has gotten injured, actually

      22      keeps a substantial amount of their recovery.

      23             SENATOR ORTT:  Yes, yes.

      24             PROF. MAYA STEINITZ:  And so the most direct

      25      way do it, is to just stay a minimum recovery







                                                                   74
       1      requirement in the statute, and say, at a minimum,

       2      the plaintiff needs to recover 50 percent.

       3             SENATOR ORTT:  Okay.

       4             PROF. MAYA STEINITZ:  And then the formula,

       5      of whether funders use a flat rate or a percentage

       6      becomes less important, once we are actually,

       7      directly, ensuring what it is, I think, the concern

       8      is about.

       9             SENATOR ORTT:  Okay.  Thank you.

      10             SENATOR ALCANTARA:  I have a couple of

      11      questions when you finish.

      12             SENATOR JACOBS:  Okay.  I just wanted to,

      13      while you were out, Senator Ortt, there were several

      14      compliments to your legislation.

      15             So, you know.

      16             SENATOR ORTT:  That's great.

      17             SENATOR JACOBS:  Yeah.

      18             But I was curious, you were saying that

      19      the -- Senator Ortt's legislation allows for funding

      20      of legal costs, and you felt that was a good thing

      21      because it could spur competition in terms of the

      22      legal costs that lawyers are pursuing clients,

      23      charging?

      24             Is that what --

      25             PROF. MAYA STEINITZ:  Yeah, I think it's a







                                                                   75
       1      good idea to allow litigation financiers to actually

       2      fund the litigation costs, to pay for lawyer's fees,

       3      as well as the court costs, testimony costs,

       4      et cetera, because, that way, they're directly

       5      competing with contingency-fee lawyers for what it

       6      is that lawyers currently fund.

       7             So, right now, or, before litigation finance

       8      sort came into the -- into existence, really,

       9      lawyers had a monopoly over financing litigation.

      10             And I can't think of a good reason why we

      11      should let lawyers sort of monopolize that form of

      12      financing.

      13             SENATOR JACOBS:  I mean, do you have any

      14      sense that lawyers in -- when -- if I had an injury

      15      and I go to a law firm, that they -- it seemed to

      16      me, from my experience, the third is so standard.

      17             Or, do they every say, Well, if you come with

      18      me, I'll only take 25 percent if you win?

      19             PROF. MAYA STEINITZ:  I don't have empirical

      20      knowledge of that, but my understanding from one,

      21      sort of, academic study that was conducted in the

      22      '90s, and I think it was in Wisconsin, so with all

      23      of those qualifications, that, actually, there's a

      24      range.  It's not actually a fixed 33 percent.  But

      25      it does range from, you know, 20 percent to







                                                                   76
       1      50 percent.

       2             And my understanding is -- again, I don't

       3      practice in this area as an attorney -- but with

       4      many personal-injury cases, there's -- there's no

       5      real question that the plaintiff is going to get

       6      paid.

       7             I mean, if they were maimed or hurt, sort of,

       8      like, we know they're getting paid.

       9             We maybe don't know exactly how much, and at

      10      what time frame.  But, lawyers sort of tend to know

      11      what that is, and so the risk may actually be less

      12      than what is sometimes portrayed.

      13             SENATOR JACOBS:  And in your suggestion that

      14      you would have a minimum of 50 percent -- that the

      15      plaintiff would get 50 percent of the suit,

      16      basically, if 50 percent, and a third, that's

      17      leaving about 16 percent for the lender.

      18             Your sense that's -- still would enable that

      19      market to exist, that the lender --

      20             PROF. MAYA STEINITZ:  Here's what I think of

      21      it:  All of the questions that have been presented

      22      to my predecessors here, I think have an underlying

      23      theme, which is:  We don't have data.  We simply

      24      don't.

      25             But funders have data.







                                                                   77
       1             And my understanding from academics who have

       2      tried to access that data is that it's private data,

       3      of course, and funders say, no, we don't want to

       4      provide it.

       5             So I think that the onus should be on the

       6      party that has data to produce it.  And if they're

       7      not producing it, then I think, I would want to see

       8      sort of leaning in favor of protection of consumers.

       9             SENATOR JACOBS:  Sure.

      10             And one other, it's really unrelated to the

      11      legislation we're talking about.

      12             I was just curious, on your testimony, that

      13      the growth in portfolio financing.

      14             PROF. MAYA STEINITZ:  Yes.

      15             SENATOR JACOBS:  And so this is a law firm

      16      basically saying, we have this group of loans -- or,

      17      group of cases, and we believe we're going to get

      18      X amount.  We'd like to loan on that.

      19             PROF. MAYA STEINITZ:  Yes.

      20             SENATOR JACOBS:  That's fair -- is it a new

      21      phenomena that that is happening?

      22             And I guess I'm wondering, is there any

      23      concern that that could start to alter the

      24      attorney's judgment on the merits of the case, and

      25      pursuing the case, on whether settling or not,







                                                                   78
       1      because they may be getting caught in a situation

       2      with a loan?

       3             PROF. MAYA STEINITZ:  Yes.

       4             Yeah, I do think that it raises its own set

       5      of concerns.

       6             And one new set of concerns it raises, is

       7      lawyers doing trade-offs between cases within the

       8      portfolio.

       9             And another concern is that the clients may

      10      not know that their cases are being funded.

      11             And so the lawyers may be receiving this

      12      funding under some arrangement in which, how much

      13      they themselves pay, depends on the duration of the

      14      litigation.  And so that might affect how long they

      15      want to -- sort of, what kind of strategy they want

      16      to pursue, whether they recommend taking a

      17      settlement early, et cetera.

      18             So it just raises its own set of

      19      considerations that are sort of worth considering.

      20             SENATOR JACOBS:  Senator, did you have any --

      21             SENATOR ALCANTARA:  Yes.

      22             Professor, thank you for being here.  I know

      23      you've come from far and away.

      24             How would you characterize these payments?

      25             Would you characterize them as loans?  Or







                                                                   79
       1      what -- would you -- how would you characterize

       2      these payments that are made?

       3             PROF. MAYA STEINITZ:  I think that there is a

       4      good argument to be made that they're not a loan.

       5             I wonder, though, whether the question about

       6      what we call them makes a difference, because the

       7      concerns are very similar to the concerns that we're

       8      seeing in relation to loans and lendings.

       9             So, that's my view.

      10             SENATOR ALCANTARA:  Okay.

      11             Number two:  Out of the states that have

      12      regulations on these lending institutions, have you

      13      seen a drop in business?

      14             PROF. MAYA STEINITZ:  I don't know either way

      15      because I have no data.

      16             SENATOR ALCANTARA:  There's no data?  Okay.

      17             And do you -- what is the average interest

      18      rate in other states for these type of loans?

      19             PROF. MAYA STEINITZ:  I -- also, I don't have

      20      that data, and that's why I made my general comment.

      21             The parties who have the data should either

      22      make it available, or, I think we should just be

      23      more protective, since the parties with the data are

      24      not releasing it.

      25             SENATOR ALCANTARA:  Okay.  And I know, you







                                                                   80
       1      know, you have said it over and over again that

       2      there's no data.

       3             But, again, have you seen a pattern in the

       4      type of folks that seek out these type of loans?

       5             PROF. MAYA STEINITZ:  Who are the plaintiffs

       6      seeking the loans?

       7             SENATOR ALCANTARA:  Yes.

       8             PROF. MAYA STEINITZ:  Patterns?

       9             I'm not aware of patterns.

      10             SENATOR ALCANTARA:  Okay.

      11             And would we argue that the reason that

      12      they're not showing us any data is because there's

      13      might be information?

      14             I know as an attorney you cannot -- you know,

      15      but I would argue that the reason why they don't

      16      provide us with the data is because there's stuff in

      17      there that maybe they don't want us to see, because,

      18      if there's nothing to hide, show me the money.

      19      I mean, like, show me the information.

      20             So, I just want to say that.

      21             SENATOR JACOBS:  Questions?

      22             I had one more.

      23             Just your -- you had suggested using the

      24      unsophisticated plaintiff/sophisticated plaintiff.

      25             And how -- what would be -- I guess you said







                                                                   81
       1      you were referring -- you were gleaning that from

       2      securities regulation.

       3             What is an "unsophisticated plaintiff"?

       4             PROF. MAYA STEINITZ:  I wish I had more time

       5      to put this written testimony together because,

       6      then, I would have looked at the jurisprudence and

       7      what kind of factors there are.

       8             So I don't have that at my fingertips.

       9             SENATOR JACOBS:  But it's something they've

      10      used for a while, and --

      11             PROF. MAYA STEINITZ:  Oh, yeah, there's a lot

      12      of jurisprudence on that, a lot of scholarship on

      13      that.

      14             And, basically, the idea is to have a

      15      multifactor test that allows regulators and judges,

      16      at the end of the day, to exercise judgment and

      17      reason to say:  This individual needs protection.

      18      This individual, not so much.

      19             So level of wealth, and access to assistance

      20      from lawyers or financial advisors, is an example of

      21      the kinds of things that are being looked at.

      22             SENATOR JACOBS:  Anymore questions?

      23             Professor, thank you very much; thank you so

      24      much for coming.

      25             PROF. MAYA STEINITZ:  Thank you for having







                                                                   82
       1      me.

       2             SENATOR ALCANTARA:  Thank you.

       3             SENATOR JACOBS:  Next, another professor,

       4      Anthony Sebok.

       5             PROF. ANTHONY SEBOK:  Good afternoon.

       6             My name is Anthony Sebok.

       7             I teach law at Cardoza Law School in

       8      New York City.  I also am a visiting law professor

       9      at Cornell.

      10             And a colleague and friend of Maya Steinitz,

      11      so I respect greatly.

      12             And, like her, I am one of the few people who

      13      have been studying this for a long time.

      14             Now, I want to make four points today.

      15             The first point is that, until now, no one

      16      really knew the true cost of consumer litigation

      17      funding.

      18             This is a question which has been asked over

      19      and over again so far.

      20             And journalists, for example, are

      21      journalists.  They just grab what they see.  They

      22      have anecdotes.

      23             And, actually, the actual contracts are,

      24      weirdly, not telling the whole story either.

      25             So with a colleague, I studied, 15 years,







                                                                   83
       1      100,000 cases that were funded.

       2             We got access to the largest litigation

       3      funding company in the United States, doing business

       4      across the country, including New York.

       5             The cases they had were typical of the whole

       6      country.

       7             New York's cases, which I can tell you we

       8      saw, but I didn't break out for this hearing, just

       9      because my article, which I published, and coming

      10      out in "The Cornell Law Review" in the fall, talks

      11      about this phenomenon nationally.

      12             But I think the results we have can be

      13      projected on to New York pretty well.

      14             We looked at 100,000 cases over 15 years.

      15             Of those 100,000 cases:

      16             We saw how much was being charged up front;

      17             We saw how much was actually being recovered

      18      by the funding company at the end;

      19             We saw what kind of cases were being funded;

      20             We saw a lot.

      21             Now, there are a lot of wrong numbers

      22      floating around, and this is, like, you hear this

      23      from academics all the time:  Well, only we know the

      24      numbers.

      25             But, I mean, I feel like we do have at least







                                                                   84
       1      better knowledge now than we did before this study.

       2             This is the first large-scale study that's

       3      ever been done.  I think it's a good study.

       4             I can't reveal who gave us access.

       5             It's a big company.

       6             I'm happy to describe our methodology, and

       7      I think it's reliable.

       8             Now, the reality, I mean, you hear numbers,

       9      like, 100 percent per annum interest.  Right?

      10             I mean, when you look at what the actual

      11      bottom-line cost to this funder was of their

      12      funding, first of all, the average length of funding

      13      was 14 months for the median case.

      14             Not every case, the median case, 14 months

      15      from date of funding to resolution.

      16             By the way, the average period of time before

      17      the applicant went to get funding, and there was an

      18      incident that they claimed they are going to get

      19      compensation for, was 10 months.

      20             So the median consumer waited 10 months

      21      before they approached the funder.

      22             We don't know what they did in those

      23      10 months.  But, I teach tort law, I teach legal

      24      ethics.  There's a good chance that they spoke to a

      25      lawyer before they spoke to a funder.







                                                                   85
       1             Now, what did we discover?

       2             We discovered that, again, the median, the

       3      median recovery, for the funder was 44 percent per

       4      year.

       5             50 percent total, because it was a 14-month

       6      period.  44 percent per annum.

       7             Not 120 percent.  Not 180 percent.

       8             Are there 108 percent deals out there?

       9      Maybe.

      10             I can tell you one thing, there are contracts

      11      out there that might say we're going to get

      12      120 percent after 14 months.

      13             But what we discovered, is that almost half

      14      of the cases, the funder came back and gave a

      15      haircut.

      16             The funder came back and said, We don't take

      17      as much as we legally could.  We recognize -- and

      18      this goes back to Professor Steinitz's point -- that

      19      maybe that would leave you too little.

      20             That's an interesting result.

      21             In almost half the cases which resulted in a

      22      positive amount that the funder could collect, the

      23      funder didn't take all they could.

      24             So in the end, if you ask somebody, What are

      25      you going to expect is going to be your cost?







                                                                   86
       1             If you look at our study and trust it,

       2      I can't promise you it's going to be 44 percent.

       3      There's a huge variability, lots of factors.

       4             But the expected cost, beforehand, is

       5      44 percent per annum.

       6             Now, the other thing we discovered, which is

       7      interesting, is that in 12 percent of the cases of

       8      those, approximately, 50,000 cases that were funded,

       9      12 percent of them were net losses for the funder:

      10      10 percent total loses.  2 percent they didn't get

      11      back what they put in.

      12             Also, of the 100,000 cases where they got

      13      applications, they rejected more than 50 percent.

      14             They took 48 percent.  They rejected

      15      52 percent.

      16             So those are the three things I want to tell

      17      you, but I have a fourth point.

      18             And my fourth point, and I say this

      19      respectfully, is that the figure "16 percent cap"

      20      equals zero.

      21             I'm going to tell you, from my experience

      22      studying this business, that if you impose a

      23      16 percent cap, you are going to have zero

      24      litigation funding in the jurisdiction.

      25             Now, I'm going to talk about Points 1







                                                                   87
       1      through 3 a little bit more, and then I'm going to

       2      talk about Point Number 4 later.  Okay?

       3             So what does this tell us, what I've learned?

       4             Well, first of all, as a lawyer, as a law

       5      professor who's done studies of stuff, I can tell

       6      you that this is a consumer product that deserves

       7      consumer protection.

       8             But, it's not a consumer credit product.

       9             It doesn't walk or talk or quack like a

      10      credit product.

      11             The price paid by the funder is highly

      12      variable and many factors.

      13             It's not a fixed interest rate that is being

      14      offered to the consumer, especially if you think

      15      about the ex post haircuts afterwards.

      16             There is no risk of increasingly

      17      indebtedness.  It's not like a payday loan.  You

      18      don't have a cycle of indebtedness, which is one of

      19      the hallmarks of why we have usury law.

      20             And just to get pedantic, if I may, because

      21      I'm a professor, there are six court opinions that

      22      say that this is not a loan, this is not debt,

      23      because there's a legal definition of "a loan" in

      24      New York State.

      25             There are four New York State opinions and







                                                                   88
       1      there two federal court opinions, they go through

       2      the law.

       3             Other states may have different definitions

       4      of "loans," but there's a definition in New York.

       5             Now, maybe we don't need to care about

       6      technical terms.

       7             We should talk about practical questions.

       8             What is it we want to do for our consumers?

       9             And this is to answer a question that was

      10      asked, and I apologize if I mispronounce the name,

      11      it's Senator Alcantara?

      12             SENATOR ALCANTARA:  Alcantara (pronouncing).

      13             ANTHONY J. SEBOK:  Alcantara (pronouncing).

      14      Sorry.

      15             There's a technical word for what this is.

      16      It's not a word that people use.  It's a word that's

      17      used in the commercial litigation funding area,

      18      where people hire lawyers to write very big

      19      contracts.

      20             But what they do in the commercial litigation

      21      area, where they do exactly the same thing for

      22      millions of dollars, the consumer's doing for

      23      thousands of dollars, and that is, they're selling a

      24      contingent right to proceeds from a lawsuit.

      25             And that is defined as a "general







                                                                   89
       1      intangible."  They are selling a general intangible.

       2             The UCC has a definition for it.

       3             Now, I realize that the average person

       4      doesn't realize that that's what they're doing, but

       5      we have a category for it, and it's not a loan.

       6             It doesn't mean, however, that a consumer who

       7      is selling a general intangible shouldn't be

       8      protected.

       9             I think a consumer should be protected, not

      10      because it's a loan, but because they're vulnerable.

      11             But when we have vulnerable consumers,

      12      according -- in the marketplace, we have different

      13      ways of protecting them.

      14             In my submitted testimony I talk about this.

      15             We don't often use price controls to protect

      16      consumers when they're selling something.

      17             I don't think we should use price controls

      18      here.

      19             I think we have other ways of protecting

      20      them.  I can talk about those later.

      21             Now, I want to talk about my fourth point,

      22      which is, perhaps, the most aggressive.

      23             Despite what you heard earlier, Arkansas does

      24      not have consumer litigation funding anymore.

      25             They're not -- I mean, there may be







                                                                   90
       1      registrants, but there are no contracts being

       2      offered.

       3             Tennessee does, but Tennessee doesn't have

       4      the rate that you were quoted.

       5             Tennessee has a much higher rate, as

       6      Miss Gilroy said: 36 plus 10.

       7             Okay?

       8             Now, I don't like the idea of picking a

       9      number.

      10             I'm here to tell you we shouldn't pick a

      11      number.  There should be other ways of protecting

      12      consumers.

      13             But I can tell you, if you go to 16, you're

      14      gonna get a zero.

      15             A further point about the bill, with all due

      16      respect, for the life of me, I cannot understand why

      17      the bill prohibits the assignment of the litigation

      18      funding asset.

      19             I mean, I just don't see it; I don't see it

      20      for two reasons:

      21             I don't see how that protects the consumer;

      22             And I also know that it is in the teeth of

      23      the UCC in New York, because New York actually

      24      favors assignment, and it specifically says, you

      25      know, under -- under our UCC, that, you know, you







                                                                   91
       1      have to specifically prohibit assignment of the

       2      contract.

       3             All right?

       4             So I don't understand why we are diverting or

       5      carving out from the Uniform Commercial Code this

       6      anti-assignment provision, other than, to put a

       7      hurdle; to put a hurdle up in front of these

       8      companies.

       9             I don't think, that putting a hurdle up in

      10      front of these companies, it doesn't help the

      11      consumer.

      12             I don't think that putting a cap, that's

      13      basically going to make it impossible for them to

      14      reach the returns which they seem to be achieving in

      15      the marketplace, is going to help the consumer.

      16             I think there are other ways of helping the

      17      consumer.

      18             I think transparency in the contract,

      19      simplicity in the contract, and more importantly,

      20      publicity about what's actually being charged for

      21      these assets, will help a marketplace grow.

      22             And that's what I would like to see.

      23             Thank you.

      24             SENATOR JACOBS:  Do you have any questions?

      25             SENATOR ALCANTARA:  Yes, I do.







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       1             Thank you, Professor, for being here and

       2      testifying.

       3             You know, I understand that there have been

       4      six court opinion saying otherwise.

       5             But, you know, English is not my first

       6      language.

       7             And when somebody gives me something and

       8      I have to pay them back, I call it "a loan," you

       9      know, regardless of what the court says.

      10             I mean, this is not Catholic Charity giving

      11      me $100 to help me with my rent for this month, or,

      12      the City -- or, HRA and the City of New York giving

      13      me a one-shot deal and I don't have to pay them

      14      back.

      15             Obviously, I have to pay this back.

      16             And, you know, what the court says, you know,

      17      at one time the court said that slavery was legal.

      18             But we all know now that it was wrong.

      19             So, that's all I have to say in regards to

      20      that.

      21             Do you have any information on what type of

      22      folks come out and seek these loans?

      23             PROF. ANTHONY SEBOK:  So, interestingly, the

      24      company doesn't take that information.

      25             I can tell you what kind of cases they're







                                                                   93
       1      using them for, if that would help you?

       2             SENATOR ALCANTARA:  Thank you.

       3             ANTHONY J. SEBOK:  Okay.

       4             So, the vast majority are for motor vehicle

       5      accidents.

       6             You wouldn't be surprised that, then, there's

       7      a big drop off from that for slip-and-falls and

       8      premises liability.

       9             And then, you know, a very vanishingly small

      10      amount is for the kind of cases that a lot of people

      11      are worried about, products liability, we're talking

      12      about a few percentage points.

      13             Medical malpractice, a few percentage points.

      14             Really, we're talking about the kind of

      15      work -- I teach torts in New York City.

      16             My students, a lot of them, I used to teach

      17      at Brooklyn Law School, my students went out and did

      18      what you do when you open up a shingle on

      19      Court Street:  Car accidents, slip-and-fall on

      20      someone else's property, and then premises liability

      21      on your own.

      22             That's the -- that's really the bulk of this.

      23             And then there's a few scaffold cases,

      24      scaffold -- you know, under the scaffold law.

      25             But, that's it.  That's -- it's the sort of







                                                                   94
       1      the stuff people have happen to them every day.

       2             If it was a medical-malpractice case, I've

       3      looked into this, why isn't there more litigation

       4      funding of medical malpractice?

       5             And I can tell you, the litigation funders

       6      tell me that they shy away from them, because they

       7      find that they are extremely difficult for them to

       8      evaluate efficiently.

       9             And you have to understand that this is, to

      10      go back to your point, a business.

      11             SENATOR ALCANTARA:  Uh-huh.

      12             ANTHONY J. SEBOK:  This is a volume business,

      13      and the companies are trying to make a profit any

      14      way they can.

      15             One way they cut corners, so to speak, is

      16      they don't want to spend a couple of days going

      17      through a case.  They want to spend a couple hours

      18      going through a case.

      19             Med-mal, it's too expensive for them to

      20      actually underwrite them.

      21             I wish they did, personally.

      22             SENATOR JACOBS:  Senator Ortt?

      23             SENATOR ORTT:  Yes.

      24             Professor Sebok, thank you for being here.

      25             I certainly appreciate the figures, because







                                                                   95
       1      I think the data is very important as we're having

       2      this discussion.

       3             I mean, our conclusions on what to do with

       4      that data may vary, but I think having some starting

       5      point or some baseline that's based on some

       6      empirical research is important.

       7             So I thank you for sharing some of those

       8      things with us.

       9             Would you agree with your -- with the

      10      predecessor, your colleague, you know, she kind of

      11      came at it from an end approach, of making sure that

      12      they keep a certain percentage or volume of the --

      13      do you agree with that notion?

      14             PROF. ANTHONY SEBOK:  So we didn't talk

      15      before we appeared here today.

      16             SENATOR ORTT:  That's good.

      17             PROF. ANTHONY SEBOK:  And I was intrigued by

      18      that proposal, which I heard for the first time

      19      today.

      20             So I immediately thought to myself, well,

      21      how's that going to work, given what I know about

      22      the data?

      23             Now, what I know about the data is that the

      24      average advance is approximately 2250 -- $2,250.

      25             Now, we don't know, because I couldn't get







                                                                   96
       1      this data, what the average, sort of, resolution was

       2      at trial, which we know never really happens, or,

       3      settlement, if it does happen.

       4             But we actually do have a sense that it's a

       5      lot more than $2,250.

       6             So if you say, well, we don't know what it

       7      is.

       8             Let's say, the valuation of these cases that

       9      they put down, the company does that, is, median,

      10      $37,000, that's a very, very soft figure.

      11             I don't know if you know much about the way

      12      personal-injury law works.

      13             SENATOR ORTT:  I don't.

      14             PROF. ANTHONY SEBOK:  But it's very hard to

      15      evaluate a case walking in the door.  Right?

      16             But let's say that number, "37,000," is

      17      right.

      18             Take a third off of 37,000, okay, what is

      19      that?

      20             You're left with approximately twenty-four,

      21      twenty-five thousand?

      22             If my numbers are right, the 2250 turns into,

      23      approximately, 3670.  You still have a big amount of

      24      money easily meeting Professor Steinitz's

      25      requirement of at least 50 percent of whatever







                                                                   97
       1      resolution there was to the case.

       2             So my initial response is, this fits with

       3      what I've been told in the field.

       4             In the field I've been told by reputable

       5      funders that they never want to advance more than

       6      10 percent of what they think is the value of the

       7      case, because they know what's going to happen.

       8             They know what's going to happen is, first of

       9      all, after resolution, the funded party is going to

      10      be very, very upset about giving up too much of what

      11      they recovered.  There's going to be a fight.

      12             Maybe you'll get a haircut.

      13             Maybe that's why we're getting the haircuts.

      14             And, also, the funded party who controls

      15      settlement --

      16             Their lawyer doesn't control settlement.  The

      17      funder doesn't control settlement.

      18             It's plaintiff who controls settlement.

      19             -- may refuse what everyone thinks is a

      20      reasonable settlement, because they're worried about

      21      giving too much over to the funder.

      22             Now, that's why funders, if they're

      23      thoughtful, and I believe that the ones who are

      24      making money are thoughtful, have rules of thumb,

      25      like, no more than 10 percent of the expected value.







                                                                   98
       1             So I think we can find a way of reconciling

       2      Professor Steinitz's recommendation with the current

       3      industry, with proper, smart regulation, without a

       4      cap.

       5             SENATOR ORTT:  You said you were funded by --

       6      or, I'm sorry.

       7             You said the -- you can't provide the company

       8      that cooperated, or the company that --

       9             PROF. ANTHONY SEBOK:  Yeah.

      10             If they gave me permission, I would.

      11             SENATOR ORTT:  -- that's fine.

      12             But can you tell us who funded the study?

      13             PROF. ANTHONY SEBOK:  Oh, yes.  It was the

      14      Israeli Science Foundation (the ISF), who my

      15      co-author teaches, in Israel; also at the University

      16      of Texas.

      17             But, they were our primary funder.

      18             SENATOR ORTT:  Is release?

      19             ANTHONY J. SEBOK:  Israeli.

      20             Like the National Science Foundation, it's

      21      the Israeli Science Foundation.

      22             SENATOR ORTT:  Israeli Science Foundation.

      23             ANTHONY J. SEBOK:  Yeah.

      24             So their version of the National Science

      25      Foundation gave us funding, gave him funding.







                                                                   99
       1             And then the rest of the funding came from my

       2      law school, Cardozo.

       3             SENATOR ORTT:  You talked -- you mentioned

       4      44 percent.

       5             ANTHONY J. SEBOK:  Yeah.

       6             SENATOR ORTT:  That was the per annum.

       7             PROF. ANTHONY SEBOK:  That's the per annum

       8      that we got on the median.

       9             SENATOR ORTT:  And that was from -- that

      10      was -- of course, that's being extrapolated from

      11      this one lender, obviously, a very large lender?

      12             ANTHONY J. SEBOK:  Yeah.

      13             SENATOR ORTT:  Okay.

      14             But I think it's fair -- and you mentioned

      15      this, fair enough to point out, obviously, one of

      16      the concerns today is that there are a number of

      17      actors --

      18             We don't even know how many.  You still don't

      19      have that amount of data.

      20             -- who are operating outside of what may be

      21      an established practice by a large and reputable

      22      lender?

      23             PROF. ANTHONY SEBOK:  Yeah.

      24             SENATOR ORTT:  And so I think that that's

      25      certainly a concern that I have, is how to bring







                                                                   100
       1      those folks to heel.

       2             I also, you know, the -- and you're right,

       3      the anecdotes that -- that the -- there's a lot of

       4      figures out there that can be pulled out of context.

       5             I see it all the time here in Albany.

       6             But, I do think that, I've also seen where

       7      you have a study.  Right?

       8             And then someone will present another study

       9      that says the exact opposite --

      10             ANTHONY J. SEBOK:  Yep.

      11             SENATOR ORTT:  -- of what, you know,

      12      sometimes, sometimes, you know, the study tells you

      13      what you want it to tell you.

      14             Sometimes.  Okay?

      15             But I do think your figures, the debt are

      16      important; the length of time I think is important,

      17      the 14 months; knowing that is critical.

      18             You know, 44 percent, I guess the question

      19      becomes, still:

      20             If 44 percent is what they're normally

      21      getting, maybe -- maybe it's a matter of a number --

      22             I know you're not a price-control guy when it

      23      comes to this.

      24             -- maybe it's what Professor Steinitz

      25      mentioned, because I think that is, certainly, a







                                                                   101
       1      focus up here, is making sure, whatever you want to

       2      call it, there's still -- in my view, there's still

       3      an aspect of predatory or predation in this area.

       4             Right away, everybody wants to talk about

       5      predatory lending, or whether you want to call it

       6      "predatory intangible," whatever, "general

       7      intangibles."

       8             I don't know what you want call it, but like

       9      in any industry, especially, you know, folks who are

      10      in need of money to pay their mortgage, you know,

      11      there can be an aspect of predation.

      12             And so I think what we're trying to do is

      13      eliminate that, get those folks out of the industry.

      14             No one wants to ban the industry.

      15             That's not what I intend to do.

      16             Every bill, I would tell you, is based on --

      17      you know, we base on the usury rates here in

      18      New York.

      19             You know, we're trying to have a discussion.

      20             We may end up in a different spot.

      21             I've already said that I think that this is a

      22      very unique area, but I do think it's important to

      23      not have some type of, sort of, end result; meaning,

      24      you're either going to keep a certain percentage of

      25      your settlement, or, it's based on a rate, or, some







                                                                   102
       1      knowledge of that person going in, I think is very

       2      important to eliminate that -- the predatory, I'll

       3      call it, "lending."  I know it's, legally, maybe

       4      it's not a lending.

       5             And I understand what you're saying, and

       6      I can appreciate that there's a legal classification

       7      for it, certainly.

       8             But I just -- I do think, still, you know,

       9      the figures are very helpful to me.

      10             You know, the 16 percent, the fact that it's

      11      zero, that it would be gone.

      12             I think there are people who may need this

      13      funding, you know.

      14             And so this is helpful to have this data,

      15      because you're the first speaker that provided any

      16      data to us, as far as real figures based on some

      17      empirical research.

      18             So I very much appreciate that.

      19             And I -- hopefully, we can take that into

      20      consideration, as we move forward, from a

      21      legislative standpoint.

      22             SENATOR JACOBS:  Professor, just again, the

      23      study you did was one lender -- one lender?

      24             PROF. ANTHONY SEBOK:  One firm.

      25             SENATOR JACOBS:  One firm.







                                                                   103
       1             ANTHONY J. SEBOK:  Yes.

       2             SENATOR JACOBS:  And you said one of the

       3      largest in the --

       4             SENATOR ORTT:  It is the largest.

       5             SENATOR JACOBS:  Okay.

       6             ANTHONY J. SEBOK:  The second largest might

       7      not like it when I say that.

       8             SENATOR ORTT:  Yeah.  And probably very

       9      reputable, I would think.

      10             ANTHONY J. SEBOK:  (Nods head.)

      11             SENATOR JACOBS:  Yeah.

      12             And I just -- one other question, and this is

      13      the legislation you mentioned, that the assignment

      14      of litigation-funding asset, why is that important

      15      to have, in your mind?

      16             ANTHONY J. SEBOK:  So I think this is an

      17      interesting issue, right, in the following sense:

      18      there's two questions.

      19             One is, why do I think the funders want it?

      20             And the other is, why would someone want to

      21      take it away?

      22             Okay?

      23             Now, burden-of-proof arguments, I learned a

      24      long time ago, are the lowest form of argument.

      25             I mean, I don't know whether I should put the







                                                                   104
       1      burden on the other side and say, why do you want to

       2      take it away, especially given what I know about

       3      commercial law in this state?

       4             But I can say this:  The reason why the

       5      funders want it, is because they themselves are

       6      borrowers.  And if they're going to enter into the

       7      credit markets, they need to point to a security

       8      interest that they can identify for a lender.

       9             Now, I want to be clear about one thing:

      10             When I saw that word "assignment," I was

      11      wondering whether or not there was an ambiguity here

      12      about whether or not the assignment was of the claim

      13      itself, or just the proceeds after the claim has

      14      been resolved.

      15             There's a big difference.

      16             I mean, in New York, for example, you cannot

      17      assign a personal-injury claim.

      18             You can assign the proceeds from a

      19      personal-injury claim.

      20             This is a very important distinction that a

      21      lot turns on.

      22             If we got rid of the second, we would do

      23      terrible damage to the ability of insurers to

      24      operate in this state.

      25             Okay?







                                                                   105
       1             So the assignment of the proceeds, right, of

       2      a claim, is something which people can pledge all

       3      the time, and the reason they do so is because it is

       4      a secured interest, which creditors like to be able

       5      to look to, if worst comes to worst, there's

       6      insolvency.

       7             SENATOR JACOBS:  Uh-huh.

       8             ANTHONY J. SEBOK:  So if you take that away

       9      from these companies, you're basically saying,

      10      you're not like any other company, first of all; and

      11      second of all, good luck trying to get commercial

      12      credit.

      13             SENATOR JACOBS:  Got you.

      14             Do you see that -- that -- if there is the

      15      assignment which they have now, I mean, do they --

      16      are these sold off --

      17             PROF. ANTHONY SEBOK:  I don't think they're

      18      being securitized right now.

      19             I think they're being pledged for credit --

      20             SENATOR JACOBS:  Got it.

      21             ANTHONY J. SEBOK:  -- I mean, for

      22      commercial-lending purposes.

      23             I don't know for sure.

      24             I mean, there may be securitization going on

      25      out there.







                                                                   106
       1             I try my best to keep up on the industry, but

       2      people don't tell me everything.

       3             SENATOR JACOBS:  Thank you.

       4             Any other questions?

       5             SENATOR ALCANTARA:  I have a question.

       6             I'm sorry, can you repeat again who funded

       7      the study?

       8             PROF. ANTHONY SEBOK:  Yes.  It was funded by

       9      the -- well, there were two authors.

      10             I'm an author.

      11             I received all my funding from my university,

      12      which is Yeshiva University, the Benjamin N. Cardozo

      13      School of Law in New York City.

      14             I have a co-author who teaches at the

      15      University of Texas, and also at Tel Aviv

      16      University.  And he applied for a grant from the

      17      Israeli government, which he received.  And as far

      18      as I know, all the funds were used for his research

      19      assistants to crunch these numbers, because, I have

      20      to admit, I'm not really a quantifiable -- I'm not

      21      "quant" person.  I'm not good with numbers.  I'm

      22      good with law.

      23             He's is a real economist, and he crunched the

      24      numbers.  And he had some research assistants.

      25             And then I also spent some time working with







                                                                   107
       1      him, so that paid for my hotel room.

       2             SENATOR ALCANTARA:  What was the criteria of

       3      the Israeli government for funding this study?

       4             Out of curiosity.

       5             PROF. ANTHONY SEBOK:  It's just general

       6      academic merit.

       7             It was a good study, that they compete -- you

       8      know, there's a competition for grant money.

       9             SENATOR ALCANTARA:  Okay.

      10             PROF. ANTHONY SEBOK:  As far as I know,

      11      I didn't -- I signed the -- I signed a letter,

      12      saying that I agreed with everything he was saying

      13      in his application.

      14             SENATOR ALCANTARA:  I was just curious, why

      15      would a foreign government be interested in funding

      16      studies about paid-loan institutions --

      17             PROF. ANTHONY SEBOK:  There are so many

      18      academics in the United States who have joint

      19      appointments with Israeli universities, that they're

      20      always doing studies outside their own country.

      21             SENATOR ALCANTARA:  No, I totally understand

      22      that.  But I would figure that they do, like, other

      23      kind of, like, scientific research, but not on

      24      paid-lending institution.

      25             I was just curious.







                                                                   108
       1             And my last questions:

       2             In the study that was conducted, did you guys

       3      speak to some of the people that have gotten these

       4      type of loans?

       5             PROF. ANTHONY SEBOK:  No.  And that was a

       6      study I wanted to do, but I haven't gotten funding

       7      for that yet.

       8             SENATOR ALCANTARA:  Okay.  Great.

       9             ANTHONY J. SEBOK:  I do have a study on tap,

      10      and I actually have a bit -- I have a model for

      11      that.

      12             SENATOR ALCANTARA:  So this -- so everything

      13      that was based on the study was on the research that

      14      you are obtained from that institution?

      15             PROF. ANTHONY SEBOK:  And most importantly,

      16      it was totally anonymized.  We know nothing about

      17      the names of any of the files we had.

      18             SENATOR ALCANTARA:  You told me.

      19             But there has been no study on the

      20      individuals that go out and seek --

      21             ANTHONY J. SEBOK:  I wanted --

      22             SENATOR ALCANTARA:  -- these type of loans?

      23             PROF. ANTHONY SEBOK:  -- I still want to do

      24      that.  I still want to do a granular, qualitative,

      25      not quantitative, study of the reasons why people







                                                                   109
       1      apply, and their experiences, because one of the

       2      hypothesis that had been floated, which I think is a

       3      worthwhile hypotheses to take seriously, is that, in

       4      addition to being necessitous, which is why we care,

       5      these people need money.

       6             And they either can go and max out their

       7      credit cards, or they can do some other form of

       8      raising funds, or they can do this.

       9             But in addition, there's an additional thing

      10      that's very different than other forms of consumer

      11      credit going on here.

      12             And for this you really have to be in the

      13      trenches of personal-injury law, like I am.

      14             Because one thing that I think is really

      15      important to understand, is these consumers can

      16      always get money for their claim.

      17             There's always someone out there willing to

      18      buy their claim, other than, say, the litigation

      19      funding company who wants to buy a tiny piece of it.

      20             The insurance company of the defendant

      21      they're suing will always put a check on the table

      22      to settle a claim.

      23             And that's buying a claim.  Right?

      24             So you have to understand, litigation funding

      25      adds a new competitor in the settlement equation.







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       1             That's what I believe.

       2             And I would love to be able to demonstrate

       3      that, in fact, there is, subjectively, in the minds

       4      of the consumer, that I'm going to hold out and see

       5      if I -- if my lawyer -- my lawyer tells me we have a

       6      good case, but they're offering this check now.

       7      Maybe I'll hold out.  Maybe that check will get

       8      bigger.

       9             You talk to PI lawyers, they'll tell you all

      10      the time, that's the dynamic.

      11             I understand, that from the defense

      12      (indiscernible) point of view, that's not a good

      13      thing, because that means the insurance company pays

      14      more.

      15             But I'm not interested here, primarily, in

      16      worrying about insurance companies.

      17             SENATOR ALCANTARA:  Okay.  Thank you.

      18             SENATOR JACOBS:  Thank you very much,

      19      Professor.

      20             PROF. ANTHONY SEBOK:  Thank you; thank you

      21      very much.

      22             SENATOR JACOBS:  Okay.  Next, Anthony Coehlo.

      23             HON. ANTHONY COEHLO:  Thank you.

      24             SENATOR JACOBS:  Congressman, thank you for

      25      being here.







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       1             HON. ANTHONY COEHLO:  Thank you,

       2      Mr. Chairman.

       3             Thank you for pronouncing my name correctly.

       4             I get so many different ways to pronounce it.

       5             It's a pleasure to be here, and thank you

       6      very much for having this hearing.

       7             My name is Tony Coehlo, and I'm pleased to

       8      present my testimony to your Committee.

       9             I would like to thank the Committee for the

      10      decision to hold this hearing, and for the

      11      opportunity to testify in support of consumer

      12      litigation funding.

      13             I served in the United States Congress,

      14      representing California's 15th District, for

      15      10 years, including 3 years as majority whip of the

      16      House.

      17             During that time, I consistently advocated

      18      for the rights of disabled Americans.

      19             Most notably, I was the author of the

      20      Americans With Disabilities Act of 1990, better

      21      known as the "ADA."

      22             Over the past 28 years, it has been

      23      extraordinarily gratifying to see this law help

      24      disabled Americans enter the workforce, access

      25      public spaces, and fight back against







                                                                   112
       1      discrimination.

       2             According to the U.S. census, one in five

       3      Americans suffer from a disability.

       4             That includes me.

       5             I had epilepsy for most of my life, a disease

       6      that causes unpredictable seizures and other health

       7      problems.

       8             I've had seizures for the last 60 years, and

       9      still have some.

      10             I'm sure many of you have friends and

      11      relatives who experienced or are currently living

      12      with some type of a disability.

      13             Imagine, if you will, that you are confined

      14      to a wheelchair, sitting in front of a door that you

      15      cannot open.

      16             Others can pass through that door freely, but

      17      you cannot.

      18             Also imagine that there is a federal law in

      19      place that says you should have the same ability to

      20      open that door as anyone else.

      21             What can you do?

      22             Your only recourse is through the court, but

      23      bringing a lawsuit can be a long and difficult

      24      process that can involve significant financial

      25      pressure for the individuals who take it upon







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       1      themselves to enforce the law through the courts.

       2             And that's why I'm here today.

       3             As all of you today I'm sure understand, the

       4      passage of legislation is only the beginning of a

       5      long process, leading to public acceptance and

       6      widespread compliance.

       7             That has certainly been the case with the

       8      ADA, which was just the first step in establishing

       9      rights for disabled Americans.

      10             Since then, disabled Americans have had to

      11      turn to the courts to enforce and find justice under

      12      the ADA.

      13             Laws are not enforcement.

      14             Enforcement is critical to make laws real.

      15             That's where legal funding comes in.

      16             Presettlement advances can provide immediate

      17      financial relief to plaintiffs who are struggling

      18      with day-to-day expenses, enabling them to stay the

      19      course in cases that are critical to enforcing

      20      compliance with the law.

      21             While most individuals with disabilities are

      22      capable of much more than people understand in the

      23      workplace, some are unable to work as a result of

      24      injuries they have sustained because of someone

      25      else's negligence or malice.







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       1             Legal funding is critical to those victims as

       2      they seek an appropriate outcome for their ordeal.

       3             Disabled or not, plaintiffs in complex

       4      litigation can be vulnerable.

       5             And some in the marketplace employ deceptive

       6      and brassive (ph.) (sic) practices.

       7             That is why New York needs strong protections

       8      for legal-funding consumers.

       9             Legal funders should be licensed by the

      10      State, and transparency for the consumer regarding

      11      the terms of the advance should be mandated by law.

      12      It must be clear exactly how much the recipient will

      13      owe.

      14             However, well-intentioned approaches that

      15      rely on interest-rate caps, instead of robust

      16      regulation, in my view, are misguided.

      17             Interest-rate caps threaten to make

      18      presettlement advances unsustainable for funders;

      19      and, therefore, reduce or eliminate the access for

      20      plaintiffs.

      21             To someone like me who cares deeply about the

      22      disabled, and the enforcement of ADA, this is highly

      23      concerning.

      24             ADA violations are serious and widespread,

      25      and the pushback that these suits continue to







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       1      receive is dangerous.

       2             Access to legal funding will help disabled

       3      Americans defend themselves and uphold the law of

       4      this great land; yet interest-rate caps are the

       5      preferred solution of insurance companies and other

       6      corporate interests driving the tort-reform

       7      movement.

       8             They would like to eliminate legal funding,

       9      for the simple reason, that it reduces their ability

      10      to extract low-ball settlements from plaintiffs who,

      11      because of the harm that they have experienced, lack

      12      the financial resources to get by in their daily

      13      lives during the long pendency of a case.

      14             Legal funding is not a panacea for the

      15      challengers who -- that disabled Americans face, but

      16      it's one tool that is available, and, it works.

      17             It ensures individuals have a chance to seek

      18      justice when they have been harmed, regardless of

      19      financial circumstances.

      20             With strong regulations mandating

      21      transparency, clear contracts for consumers, and

      22      robust oversight of funders, legal funding will be a

      23      safe alternative for victims who need financial

      24      support while they see their cases through the

      25      process.







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       1             Legal funding is important to the cause of we

       2      disabled Americans who still need the courts to

       3      enforce the equity under the law.

       4             In closing:  I want to reiterate my hope that

       5      this Senate will embrace effective regulation of the

       6      industry and preserve legal funding for your

       7      constituents.

       8             And I thank you for your time.

       9             SENATOR JACOBS:  Thank you very much,

      10      Congressman.

      11             Any questions?

      12             Senator Ortt?

      13             SENATOR ORTT:  Congressman, thank you for

      14      being here.

      15             HON. ANTHONY L. COEHLO:  Thank you.

      16             SENATOR ORTT:  As you may be aware, I'm the

      17      Chair of the Mental Health and Developmental

      18      Disability (sic) Committee in the Senate, so I have

      19      a shared interest in protecting that community, as

      20      I'm sure, and I know, you do, because of your

      21      previous service and your authorship of a landmark

      22      legislation.

      23             So I want to thank you for your work with

      24      that community.

      25             Because I care about it, and since







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       1      percentages is a big topic here today, do you have

       2      any idea what the percentage of the disability

       3      community that takes -- that, you know, tries to

       4      take advantage, I guess, of legal lending?

       5             HON. ANTHONY L. COEHLO:  I really don't know,

       6      Senator, but I can tell you that one case is too

       7      much.

       8             And it's my ministry, it's my passion.

       9             I believe very strongly, in that, that if

      10      anybody is getting -- I won't use that word -- if

      11      anybody is getting treated wrongly, that should be

      12      corrected.

      13             And so I do know the specifics of

      14      individuals, but I have no idea of numbers.

      15             SENATOR ORTT:  Okay.  And I ask because, one

      16      of the concerns I think that we've heard today is

      17      about folks who are vulnerable, meaning anybody

      18      who's, obviously coming, looking for funding, is,

      19      obviously, in a -- probably, a significantly

      20      vulnerable position.

      21             If you were to add to that, they have a, you

      22      know, developmental disability, that could be

      23      even -- I mean, now we're really talking about a

      24      vulnerable population in and of itself.

      25             Because, to your point, the ADA certainly has







                                                                   118
       1      to be enforced all the time -- you know, they have

       2      to go to court and try to enforcement that law.

       3             HON. ANTHONY COEHLO:  They have to enforce

       4      it.

       5             Let me make one point as well, is that the

       6      ADA, I always say, is an insurance policy for those

       7      of you on the podium that I don't think have

       8      disabilities.

       9             If you end up with a disability, because of

      10      an accident, or because of whatever, the ADA covers

      11      you.

      12             And so it's a question, people always talk

      13      about somebody with a severe disability, implying

      14      that they're the only individual.

      15             People are -- you know -- every day, more --

      16      and as we get older as a society, the more and more

      17      people will qualify as someone who is disabled.

      18             And so it is -- and it's an ongoing problem.

      19             And I really believe strongly -- I was

      20      intrigued with the testimony of the individual just

      21      before me, and I don't know any of these folks, so

      22      the -- the -- I was intrigued with what he was

      23      saying about what needs to be done.

      24             And I really strongly believe that regulation

      25      is the answer.







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       1             And I think that -- I know that -- and I'm

       2      not negative about insurance companies, but they

       3      have a business as well.  And they have lots of

       4      lawyers that fight those of us who have claims.

       5             And the lawyers that represent us don't have

       6      the resources that the insurance companies have.

       7             And so I think it's important to keep all

       8      this in balance, and that's what I preach about,

       9      talk about.

      10             I'm 75, and still my ministry, it's what

      11      I strongly believe in.

      12             And as I say to you, I don't know how many,

      13      but I do know it happens, and one time is too many.

      14             SENATOR ORTT:  And I was asking because, as

      15      Chair of this Committee, and as sponsor of this

      16      bill, I've never heard the nexus.

      17             No one from that community has come to me and

      18      said, This is a big issue for me, or for my family,

      19      or my loved one, or...

      20             So that was -- this is a first-time nexus for

      21      me.

      22             Not to say that (indiscernible) --

      23             HON. ANTHONY COEHLO:  But let me tell you,

      24      I was, in part of my life pursuing disabilities,

      25      I was chairman of the Epilepsy Foundation of







                                                                   120
       1      America.

       2             SENATOR ORTT:  Okay.

       3             You are still, or you were?

       4             HON. ANTHONY COEHLO:  No, I was.

       5             I'm on the board.

       6             SENATOR ORTT:  Okay.

       7             HON. ANTHONY L. COEHLO:  I'm not chair

       8      anymore.

       9             And lots of examples there of these type of

      10      cases.

      11             I was chair of the American Association of

      12      People with Disabilities.

      13             I can give you examples there.

      14             SENATOR ORTT:  Okay.

      15             HON. ANTHONY L. COEHLO:  I'm chair of

      16      Partnership to Improve Patient Care.

      17             A lot of -- this is what I strongly, I'm

      18      committed to.

      19             And I can give you examples of people who

      20      have -- as a result of their disability, have gotten

      21      some help.  And others who, basically, got

      22      mistreated as a result of what occurred.

      23             And so it's -- I can help you in that regard.

      24             I'm not sure I can give you exact numbers,

      25      but I can give you examples if you need them.







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       1             SENATOR ORTT:  Well, and I think that's

       2      important, because I think -- I want to -- I want to

       3      create -- or, I want to address something you said,

       4      but also many other speakers have said, and

       5      I certainly make no attempt to speak for my

       6      colleagues.

       7             No one is talking about trying to --

       8      certainly on the intent, to eliminate this from

       9      people who need it.

      10             We're talking about regulating it.

      11             HON. ANTHONY COEHLO:  And you're also talking

      12      about eliminating the bad actors --

      13             SENATOR ORTT:  Oh, absolutely.

      14             HON. ANTHONY L. COEHLO:  -- which I'm

      15      hopeful.

      16             SENATOR ORTT:  Yeah, yeah, if they're gone,

      17      that's a good thing.

      18             HON. ANTHONY L. COEHLO:  Yeah.

      19             SENATOR ORTT:  And so the question is:  How

      20      do we do it, and how do we do that in an effective

      21      way?

      22             And how do we make sure that people who are

      23      successful and get a claim, keep the bulk of that

      24      claim?

      25             So that's really what this attempts to do.







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       1             And I think, I would imagine, that's what all

       2      the other states have tried to do.

       3             This has nothing to do with tort reform, of

       4      which I am a supporter.  But that isn't -- that is

       5      not why we're talking about this today.

       6             And I am certainly no defender or no

       7      water-carrier of the insurance industry.

       8             HON. ANTHONY L. COEHLO:  Good.

       9             SENATOR ORTT:  You know, we all have to have

      10      insurance, and they have a business model.

      11             And -- but, you know, no one up here, this

      12      bill is not an attempt to kill.

      13             The real -- the goal is:

      14             Because you said "one is too many much."

      15             And before we heard, you know, on average,

      16      44 percent, you know.

      17             But we also know there's rates that are

      18      higher than that.

      19             And I would say, that just because the

      20      average might be "this" number, the fact that we

      21      have rates significantly higher, we shouldn't just

      22      say, eh, that's not the majority.

      23             That's -- you know, so there still is the

      24      real prospect of predation lending, predatory

      25      lending, or predatory characteristics in this







                                                                   123
       1      industry.  And there is no oversight today, as you

       2      have acknowledged.

       3             And so I think trying to get to, you know,

       4      how will we get there?

       5             Whether it's a hard rate, or what that number

       6      is, or whether we come up with, you know, additional

       7      transparencies and regulations that companies have

       8      to follow, or maybe it's something like the other --

       9      the one professor said about, you know, ensuring

      10      that plaintiffs, you know, that there's a certain

      11      amount of their award they have to -- that has to be

      12      kept for them.

      13             However you do that, I think having something

      14      hard at the end.

      15             You know, I'm kind of a bottom-line person,

      16      and I realize you can't always do that.

      17             But I'm sort of a bottom-line guy, and that's

      18      what we're trying to get to, or what I'm trying to

      19      get to, with the legislation.

      20             And, obviously, your testimony, as it relates

      21      to this, epilepsy, you know, folks who have

      22      developmental disabilities, or intellectual

      23      disability, who may become that way or are born that

      24      way, I think is important, because those are very

      25      vulnerable New Yorkers, every single day.







                                                                   124
       1             And we surely don't want to do anything

       2      that's going to increase their vulnerability.

       3             HON. ANTHONY L. COEHLO:  I know a lot of

       4      New Yorkers that fit that category --

       5             SENATOR ORTT:  I'm certain.

       6             HON. ANTHONY L. COEHLO:  -- and I work with

       7      them.

       8             But let me -- I'm going to do something

       9      I shouldn't do.  As a former legislature, I'm going

      10      to make a suggestion.

      11             It seems to me that, in this industry, the

      12      problem is, there's no regulations.  There's really

      13      no data.  There's -- and for you to try to come up

      14      with something without those basics is difficult.

      15             It would seem to me that what you should be

      16      doing is looking at, how do you regulate it, and

      17      enforce it?

      18             And you develop data as a result of that.

      19             And then it might be, that as a result of the

      20      data that you get, that then you have to do

      21      something else to prevent the bad apples from doing

      22      what they're doing.

      23             But, there's no regulation.

      24             SENATOR ORTT:  Right.

      25             HON. ANTHONY COEHLO:  And -- and -- and







                                                                   125
       1      I know a lot of these funders, because of what they

       2      do, and so forth.

       3             But it seems to me, regulation first, get

       4      facts, and then make adjustments where needed.

       5             SENATOR ORTT:  If I could add --

       6             HON. ANTHONY L. COEHLO:  And that's --

       7      that's --

       8             SENATOR ORTT:  -- no, that's a -- it's a --

       9      from a former Congressman, it's a worthy suggestion.

      10             I would just add, and you probably could

      11      appreciate this, if there wasn't a bill in, none of

      12      us are sitting here today.

      13             Let's not kid ourselves.

      14             HON. ANTHONY L. COEHLO:  Oh, I agree.

      15             SENATOR ORTT:  If there wasn't something to

      16      bring people to the table and put some fire on

      17      people, and bring them to heel, you know, because

      18      somebody is making money off of this.

      19             And if they can get whatever rates they can

      20      get, great for them.

      21             That's going to be their attitude.  Right?

      22             HON. ANTHONY L. COEHLO:  It's the American

      23      (indiscernible).

      24             SENATOR ORTT:  Right.

      25             So if you don't -- somehow, you have to start







                                                                   126
       1      somewhere to get people into the room, because we've

       2      had this discussion, at least in New York, for the

       3      past two or three years, since I've been here in the

       4      New York Senate.

       5             And this is the first time we've even moved.

       6             And a lot of that is because there's media

       7      coverage in major media outlets.  There's

       8      legislation.  There's people who are interested in

       9      this.

      10             And so, you know, such is the nature of

      11      lawmaking, but I think we can certainly try to get

      12      to a point where we have -- (indiscernible) a

      13      zero-sum game.

      14             There's no regulation in New York.

      15             So some regulation, and some consumer

      16      protection, to me, is where we're trying to get to

      17      here.

      18             So I appreciate your testimony, though,

      19      Congressman.

      20             HON. ANTHONY COEHLO:  Yeah, I would just

      21      close by saying that we've got to remember that the

      22      people that are involved here.

      23             Generally, it's poor folks.

      24             Generally, it's people who have disabilities.

      25             It is people who have no other recourse.







                                                                   127
       1             And what is taking place today is a recourse

       2      for them.

       3             Now, if we were to regulate it, and we get

       4      data, we could then control some things that are

       5      wrong.

       6             But we need to regulate it.  It needs to --

       7      we ought to get to that point, if that's the

       8      compromise that can be made, to start that process.

       9             And it shouldn't only be here in New York.

      10             It should be all over.

      11             There are abuses all over the country.

      12             And the fact that you are holding hearings,

      13      Senator, I appreciate it, because it -- it is maybe

      14      a way to get this process started, to do what needs

      15      to be done for this community.

      16             SENATOR ALCANTARA:  Thank you, Congressman,

      17      for being here.

      18             And I want to thank my colleagues,

      19      Senator Ortt, for bringing this, and Senator Jacobs

      20      for hosting this Committee.

      21             And just to echo what Senator Ortt said, you

      22      know, we are having this meeting, we are having this

      23      hearing, because, obviously, there have been a lot

      24      of publicity about it.

      25             And like you stated before, none of us want







                                                                   128
       1      to put anyone out of business, because, when

       2      business thrive in New York, we hope that that means

       3      that there are people that have those jobs, there

       4      are people that are making money, and invested in

       5      the local economy.

       6             But we also want to make sure that vulnerable

       7      New Yorkers -- the poor, victims of domestic

       8      violence, immigrants -- that they are protected from

       9      any kind of harm, because we do know that people

      10      that seek out these type of loans --

      11             I mean, you know, the court of appeal can

      12      call it whatever they want.

      13             I'm going to call it "a loan," you know.

      14             -- there are people that need this.

      15             There are people that are poor.

      16             Somebody that lives in Fifth Avenue and

      17      59th Street is not going to go and get one of

      18      these loans.

      19             Somebody that lives in Scarsdale, in

      20      Westchester County, probably has friends, or

      21      probably access to a bank.

      22             So we just want to make sure, the reason why

      23      we're having this, is because we believe in

      24      transparency, and we believe that, when you are not

      25      doing anything wrong, you should have no problems







                                                                   129
       1      with some type of regulations.

       2             And we want to make sure that people don't

       3      lose their homes.  That people are not taking

       4      advantage of.

       5             And that's why we are here, is not to try to

       6      put anyone out of business.

       7             We believe in business, that everybody, you

       8      know, is part of the American Dream, and that you

       9      become a successful business.

      10             But we also know what can happen, and who

      11      pays the price when there are no regulations and

      12      there are no transparency?

      13             You know, and we hope that, from this day,

      14      on, and the next time we meet with some of these

      15      companies, that they can provide some type of data

      16      for us.

      17             Like, for example, what is the income level

      18      of people that seek out these loans?

      19             What part of the state do they come from?

      20             And that they can provide us with real

      21      document, so we can see, and we can read, and we

      22      have time -- and we can have time to digest this.

      23             But I just wanted to say that, and I'm going

      24      to be excusing myself out.

      25             And, again, thank you for having this.







                                                                   130
       1             I think this is something very important.

       2             But, you know, New York has been the pioneer

       3      on a lot of things.

       4             And I think this is a way for New York to

       5      say:

       6             Hey, we don't care what anybody else has in

       7      another state.  We want to make sure that the people

       8      that live in our district in the state of New York

       9      are protected.

      10             Thank you.

      11             SENATOR JACOBS:  Thank you.

      12             You good?

      13             SENATOR ORTT:  Yeah, I'm good.

      14             SENATOR JACOBS:  Congressman, thank you very

      15      much for your time.

      16             HON. ANTHONY COEHLO:  Thank you, Chairman;

      17      appreciate it.

      18             SENATOR JACOBS:  And next, Lev Ginsburg.

      19             LEV GINSBURG:  Thanks, Senator.

      20             SENATOR JACOBS:  Good afternoon.

      21             LEV GINSBURG:  How are you?

      22             SENATOR JACOBS:  Thank you for being here.

      23             LEV GINSBURG:  My pleasure.

      24             So now that you've heard from the experts,

      25      you can hear from me.







                                                                   131
       1             And I studied torts, actually, at the

       2      Benjamin Cardozo School of Law.

       3             But, Professor Sebok is not to be blamed.

       4      I don't think he was a professor there at that

       5      point.

       6             I want to thank you on behalf of The Business

       7      Council, and our more than 2300 members in the state

       8      of New York who employ over a million New Yorkers,

       9      businesses, large and small, across the state.

      10             And I wish to submit these comments into the

      11      record as part of the Committee's hearing on

      12      third-party lawsuit lending in the state of

      13      New York.

      14             I will keep my comments relatively brief.

      15             As the state's largest statewide

      16      employer-advocacy organization, we often address

      17      issues impacting the state's economic

      18      competitiveness, including business costs driven by

      19      state policy actions and New York's profoundly

      20      litigious environment.

      21             By many measures, New York's business climate

      22      lags far behind that of many other states.

      23             New York has higher taxes, higher labor

      24      costs, higher energy costs, and more regulations

      25      than most states.







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       1             New York also has a vast array of laws making

       2      it advantageous to be a plaintiff and a plaintiff's

       3      attorney at the expense of defendants.

       4             Since businesses are so often the defendants

       5      in lawsuits, this paradigm leads to higher risks and

       6      higher costs of doing business in New York.

       7             One cause of the ever-growing litigation

       8      docket in New York's courts is the proliferation of

       9      third-party lawsuit lenders in the state.

      10             While many of us are familiar with banks and

      11      firms that provide bridge money to bankroll

      12      long-running, complex commercial litigation, many of

      13      us are less familiar with the cottage industry that

      14      has developed, offering non-recourse lawsuit loans,

      15      loans at exorbitant interest rates, for common tort

      16      claims.

      17             These loans, which are becoming more

      18      documented, thanks to investigations around the

      19      country, charge as much as 200 percent, and often

      20      leave a consumer-plaintiff with little or no money

      21      at the completion or settlement of their lawsuit.

      22             Lawsuit-lending outfits have been able to

      23      circumvent regulation and usury laws because the

      24      loans are contingent on the plaintiff winning or

      25      successfully settling a case.







                                                                   133
       1             It's also difficult to fully quantify the

       2      impact -- and we've heard this -- and pervasiveness

       3      of the problem, because such presettlement loans

       4      need not be filed with any court, and as a result,

       5      no public record of these loans exist.

       6             That said, these loans have a profound

       7      negative impact on our legal system and on the very

       8      plaintiffs that they purport to help.

       9             Much of the industry, founded by

      10      personal-injury lawyers, but now heavily financed by

      11      hedge funds and other investors, relies on

      12      plaintiffs' lawyers to send business.

      13             Often, the same lawyers receive a finder's

      14      fee or a referral fee for these loans.

      15             Prosecutors in New York, and beyond, have

      16      been investigating the business relationships

      17      between the lenders and the trial lawyers as to

      18      whether these financial arrangements between the

      19      parties constitute illegal kickbacks.

      20             Whether these financial arrangements are

      21      technically legal or not, they demean the legal

      22      profession and have a serious appearance of

      23      impropriety, while inserting a third-party's

      24      interest into the important attorney-client

      25      relationship.







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       1             Instead of truly helping plaintiffs in need,

       2      often, these third-party lenders prey on the most

       3      vulnerable people with aggressive advertising on

       4      television and the Internet, much like other

       5      get-rich schemes, psychic readers, and class-action

       6      lawsuits.

       7             The advertising offers quick cash with no

       8      mention of triple-digit interest rates.

       9             Many plaintiffs are left with almost nothing

      10      after their awards or settlements after paying back

      11      these usurous loans.

      12             Such a reality, once realized by a plaintiff,

      13      also has repercussions on the outcome of the

      14      lawsuits themselves.

      15             As plaintiffs become aware of the massive

      16      amounts of money owed to these lenders, the

      17      plaintiffs, in an effort to salvage any chance of

      18      substantial monetary awards reaching their pockets,

      19      are forced to reject reasonable settlement offers

      20      and, instead, swing for the fences and go to trial

      21      to reach an amount high enough to repay their loans

      22      and have little left over for themselves.

      23             This shift away from reasonable settlements

      24      greatly and needlessly increases litigation costs

      25      for businesses across New York.







                                                                   135
       1             As a direct result of this lending,

       2      settlement discussions are often upended.

       3             This push towards litigation further crowds

       4      already-stressed court dockets, and slows down the

       5      process for all cases, taking up valuable court time

       6      and judicial resources.

       7             Sadly, this reality does not help defendants,

       8      and it does not help plaintiffs.

       9             Once plaintiff attorneys are paid, and after

      10      lawsuit loans get repaid, with their high interest

      11      rates, there is often little left in the settlement

      12      or judgment for a plaintiff to make them whole.

      13             Lawyers and lenders are the only winners in

      14      this new reality.

      15             While my primary concern in this arena is the

      16      interest of my members, I'm also deeply concerned as

      17      an attorney and as a citizen of New York.

      18             As a representative for employers in the

      19      state, I'm concerned that third-party lawsuit

      20      lending leads to evermore baseless litigation

      21      against employers, and stymies reasonable

      22      settlements, one of the cornerstones of our almost

      23      system.

      24             As an attorney, I'm deeply troubled by what

      25      these loans, and the inappropriate relationships







                                                                   136
       1      between plaintiff lawyers and the lenders, do to the

       2      reputation of a good, necessary, and honorable

       3      profession.

       4             These actions diminish our collective

       5      professionalism and trustworthiness.

       6             Finally, as a New Yorker, it's abundantly

       7      clear that these lenders pray on the weakest among

       8      us.

       9             There's no consideration for fairness or

      10      decency, and just an unbridled grab at easy money,

      11      leaving the vulnerable with no money and no

      12      recourse.

      13             It isn't often that I testify in favor of

      14      more litigation and regulation.

      15             While it's rare, when there's a clear

      16      injustice that needs correction through law, the

      17      business community and The Business Council do not

      18      shy away from calling for the appropriate action.

      19             In this case, at the very least, these

      20      lawsuits must be made -- these lawsuit lendings must

      21      be made subject to usury laws to limit the

      22      outrageous rates that they -- that some of them

      23      charge.

      24             Beyond that, further transparency, licensing,

      25      and reporting are definitely in order.







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       1             I appreciate the opportunity to share my

       2      thoughts on this important issue.

       3             And on behalf of The Business Council and our

       4      members, I thank the Committee for investigating the

       5      important subject on behalf of New York's consumers.

       6             SENATOR JACOBS:  Thank you very much.

       7             Any questions?

       8             SENATOR ORTT:  Yeah, Mr. Ginsberg,

       9      I appreciate you coming in.

      10             Not everyone else did it, because they seemed

      11      to have all left before you spoke.

      12             LEV GINSBURG:  That's the way it goes.

      13             SENATOR ORTT:  That's okay.

      14             But, I appreciate your testimony.

      15             And, you know, what do you -- so I --

      16      I share -- or, at least I -- you know, I always had

      17      the feeling that, to me, one of the costs -- you

      18      hear about people talking about New York State a

      19      high cost of doing business.

      20             One of those costs, you know, it's not just

      21      taxes.  It isn't just -- it's the cost of, whether

      22      it's policies, or what have you, because of a high

      23      liti -- you know, New York State seems to be highly

      24      litigious state.

      25             LEV GINSBURG:  Sure.







                                                                   138
       1             SENATOR ORTT:  What do you say -- you know,

       2      one of the previous testifiers said, Well, this

       3      money just goes to their living costs.  It doesn't

       4      go to -- you know, in other words, it doesn't really

       5      play a part in the length of the suit or in the

       6      lawsuit being taken, or anything like that.

       7             So I guess, what would you say to that in

       8      response?

       9             LEV GINSBURG:  Well, I think a couple of

      10      things.

      11             I mean, first of all, money is fungible.

      12             So, you know, first dollar in, first dollar

      13      out -- first and last dollar out.

      14             Money is money.

      15             So whether it's going directly towards

      16      litigation or other living expenses, I think the end

      17      result is about the same.

      18             SENATOR ORTT:  Okay?

      19             LEV GINSBURG:  I also think that, you know,

      20      part of the -- I think one of the biggest problems

      21      for me, is that, if I have a client -- if I'm an

      22      attorney and I have a client, and that client is

      23      facing, you know, an enormous fee to a lender,

      24      there's no way they're going to settle for a

      25      reasonable amount.







                                                                   139
       1             So we're going to extend the length of just

       2      about every case, because, you know, a settlement

       3      might come at 18 months, or some of the times that

       4      we heard earlier.

       5             But if the case ends up going to trial,

       6      because that plaintiff is sort of desperate for a

       7      bigger payday in order to pay off the loan, and then

       8      have something left over, I think that no matter

       9      what the loan is going for, the net result is, you

      10      know, a longer process and, frankly, more money that

      11      goes into the hand of the lender.

      12             SENATOR ORTT:  Sure.

      13             Gee, I had so many more questions, but it's

      14      late in the day.

      15             Let me add this:

      16             You know, I am also not someone that normally

      17      is in favor of more regulation, because I certainly

      18      think New York State is also a very highly-regulated

      19      state.

      20             But to your earlier point, I do think it's

      21      important, you know, where there's -- we regulate so

      22      many other areas, and yet, this one, you know,

      23      there's really nothing.  Right?  I mean, it just

      24      almost seems -- it seems strangely odd, you know,

      25      that there's no regulation.







                                                                   140
       1             I guess my last question would be, or my last

       2      comment, maybe you can speak to this:

       3             Would it be your estimation, or your -- The

       4      Business Council's estimation, if I understand

       5      correctly, that this type of third-party financing,

       6      especially with these rates, really are -- you know,

       7      extend lawsuits, extend the time, because you're

       8      waiting for that bigger payday you're trying to get?

       9             You know, so there's more hands in the till,

      10      whether it's the attorneys, whether it's the

      11      lenders, whoever it might be, and that really just

      12      drives up the costs and time for everybody?

      13             LEV GINSBURG:  Sure.

      14             I mean, you know, if you go to legal

      15      ethics --

      16             And I'm not an expert on legal ethics.  I'm

      17      bound by them, but not an expert.

      18             -- I know that one of the main tests, if you

      19      will, when dealing with whether an attorney can get

      20      into a financial relationship, a business

      21      relationship, with a client, which I would argue

      22      that this is some form of business relationship,

      23      is -- is the interest of the client different than

      24      the interest of the attorney?

      25             Right?







                                                                   141
       1             So, in this particular case, if I'm an

       2      attorney, and I'm bringing my client to a lawsuit

       3      lender, who happens to pay me a finder's fee, my

       4      interest is, of course, I've gotten paid already, if

       5      you will.

       6             So my client's interests is, they need more

       7      money at the end of whatever this particular case

       8      is.

       9             And my interest as their attorney may no

      10      longer be identical.  I may no longer be married to,

      11      you know, going the distance in a trial when I have

      12      a decent settlement on the table.

      13             Right?

      14             So -- and I'm not saying -- that there's

      15      always differences of opinion.  Right?

      16             A lawyer can only give the advice.  The

      17      client can or cannot take it.

      18             But, I actually may have a different

      19      interest.  I may want the case over at settlement,

      20      and that client may very well need me to go to

      21      trial.

      22             And I really worry that we're really putting

      23      plaintiffs at a disadvantage.

      24             Now, I also worry about the defendant,

      25      obviously, because I represent several of them, in







                                                                   142
       1      many cases.

       2             So I'm worried that, once again, we're

       3      pushing, and as the gentleman who testified a moment

       4      ago indicated, you know, we're sort of, insurance

       5      companies, payers, defendants, whomever, have an

       6      interest, obviously, in mitigating their own losses,

       7      as they should.

       8             But that's where settlement comes in.

       9             And that's why everybody, you know, weighs

      10      and measures the costs, and the opportunity costs,

      11      and the BATNA, if you will (the best alternative to

      12      negotiated agreement), and all of those things.

      13             This adds another element to the table.  It

      14      puts another thumb on the scale, if you will.

      15             And I think it's, in many respects,

      16      inappropriate.

      17             I'm not saying that the entire industry is

      18      inappropriate.

      19             SENATOR ORTT:  Sure.

      20             LEV GINSBURG:  You know, if people need that

      21      bridge, I do understand it.

      22             But, to operate outside of the usury rates

      23      is -- is -- I don't want to get too dramatic, but

      24      it's almost obscene, some of the numbers that, you

      25      know, we've all read in various reports in the news,







                                                                   143
       1      and so forth.

       2             And I think that, you know, we heard

       3      testimony -- excuse me -- that if we bring it to

       4      14 percent, it might as well be zero.

       5             No one actually said bring it necessarily to

       6      14 percent, you know.

       7             Your colleagues, you all discuss these

       8      things, and there's always a magic number, right,

       9      and it's always a bit arbitrary, but there's a

      10      number that makes sense.

      11             And, certainly, if Tony Soprano would go to

      12      prison for that number, it's too high.

      13             SENATOR ORTT:  Right, right.

      14             LEV GINSBURG:  You know, it's as simple as

      15      that.

      16             SENATOR ORTT:  Do a lot of your members get a

      17      44 percent per an annum return?

      18             LEV GINSBURG:  They're not paying me a

      19      dividend.

      20             I'm going say no.

      21             SENATOR ORTT:  Okay.  I just -- I thought so.

      22             Thank you very much, Mr. Ginsburg.

      23             SENATOR JACOBS:  You had just mentioned that,

      24      hedge funds, is that -- are getting involved in

      25      this.







                                                                   144
       1             LEV GINSBURG:  I don't have intimate

       2      knowledge, but I've certainly read about it.

       3             I mean, "The New York Times" did an expose a

       4      while back, and there were a few other articles that

       5      I've read in some national newspapers, that have

       6      said that there's a lot of money being made; and,

       7      therefore, a lot of money being poured in for

       8      investment purposes.

       9             SENATOR JACOBS:  Thank you very much.

      10             LEV GINSBURG:  My pleasure.

      11             Thank you, all; appreciate it.

      12             SENATOR JACOBS:  James Copland from

      13      The Manhattan Institute.

      14             SENATOR ORTT:  Last, but certainly not least.

      15             SENATOR JACOBS:  Not at all.

      16             We're here.

      17             JAMES COPLAND:  Someone has to be last;

      18      right?

      19             SENATOR JACOBS:  Well, this is being taped,

      20      so we --

      21             JAMES R. COPLAND:  That's the good thing.

      22             I testified once in the House, and I was on

      23      the panel behind Newt Gingrich.  And once he got up

      24      and left, the entire -- it was empty.  I was

      25      speaking to the chairs.







                                                                   145
       1             SENATOR JACOBS:  That's what happens with

       2      Rob Ortt.  He said he had to leave by three, so...

       3             JAMES R. COPLAND:  So I do want to thank you,

       4      Chairman Jacobs, Ranking Member Alcantara,

       5      Senator Ortt, other members of the Committee, for

       6      your time, and the thought that's gone into Senate

       7      Bill 3911, the opportunity to speak.

       8             It's particularly nice for me to be able to

       9      speak to something.

      10             I'm accused often -- I've, for 15 years,

      11      directed The Manhattan Institute's legal-policy

      12      program, and, you know, I've been accused by the

      13      National Trial Lawyers organization as being a

      14      well-known defender of corporate negligence and

      15      malfeasance.

      16             I always say that's not totally fair.  I'm

      17      not really very well known.

      18             But -- but I do often sort of take the side

      19      of a corporate defendant.

      20             And so it's nice to sort of be attacking an

      21      unscrupulous set of corporations, and I don't mean

      22      to suggest they all are, and defending consumer

      23      rights here.

      24             Senator Ortt, you said -- but -- but as

      25      I start here, and I just want to emphasize, I've







                                                                   146
       1      given my written testimony here to the staff on the

       2      Committee, so I'm going to assume that that's

       3      incorporated here by reference --

       4             SENATOR JACOBS:  Yes.

       5             JAMES R. COPLAND:  -- and don't want to go

       6      through 2500 words with multiple footnotes here in

       7      front of you, and would, rather, just sort of

       8      summarize those points, and respond to some of the

       9      things the other panelists have talked about here

      10      today.

      11             And I do want to emphasize at the outset,

      12      just like Professor Sebok's not speaking for Cardozo

      13      Law School, I am not speaking for The Manhattan

      14      Institute in the sense that, The Manhattan Institute

      15      doesn't take institutional positions on any

      16      legislation.

      17             So I'm just here in my individual capacity.

      18             That being said, I -- I -- I want say,

      19      I mean, Senator Ortt, you said no one here is saying

      20      to get rid of all this.

      21             You know, I'm going to say, well, I am.

      22             I'm not so sure I wouldn't say that in an

      23      optimal situation.

      24             I'm not so sure I wouldn't bring back robust

      25      champerty and maintenance rules which are the old







                                                                   147
       1      common-law legal rules I talk about in some of my

       2      written testimony, that forbade sort of the

       3      sponsorship of litigation.

       4             But I do admit, that that's water under the

       5      bridge.

       6             We can all watch TV and see "1-800,

       7      J.G. Wentworth, Need Cash Now."

       8             This industry does exist.

       9             There is a lot of money, there is financing

      10      for it, as you talked about, Chairman Jacobs.

      11             And, understandably, I don't mean to suggest

      12      the hedge funds are doing anything wrong, because

      13      this is, relatively, uncorrelated with the markets,

      14      so it's an alternative asset class that they want to

      15      invest in.

      16             But it's a big business at this point.

      17             It does exist there, and I do think that

      18      there's a strong case here for regulations.

      19             So in my remarks I call this "a modest

      20      proposal."

      21             It's not outlawing the industry, and it's --

      22      it's only really this consumer part of the industry.

      23             So there is another large industry in terms

      24      of commercial litigation financing.  Outfits like

      25      Berther Capital, that pays Professor Sebok a







                                                                   148
       1      retainer to advise them, are out there and doing

       2      big-dollar claims.

       3             That's really kind of different than what

       4      we're talking about here, where we're talking about

       5      two- or three-thousand-dollar average advances to

       6      small-fry consumers paying exorbitantly high

       7      interest rates, or implicit interest rates, on those

       8      sorts of arrangements.

       9             And so the Senate bill exempts at 500,000.

      10             That's actually consistent with the Safe

      11      Harbor, under the New York Champerty law, which

      12      still exits in Section 489.

      13             So it has some logic to it.

      14             And I actually sort of like that better

      15      than -- it was an interesting idea that

      16      Professor Steinitz posited, with a

      17      qualified-investor standard, or something like that.

      18             I'm also not sure how that works here,

      19      though.

      20             I mean, the qualified-investor standard that

      21      the SEC generates, which is investing in initial

      22      public offerings and risky sorts of investors --

      23      investments, 140 -- 4A's, and what have you.

      24      I mean, that's individuals with one million in net

      25      liquid investable assets.







                                                                   149
       1             I don't think any of them are taking out

       2      lawsuit loans with implicit rates of interest of

       3      44 percent per annum.

       4             I just -- so I just don't -- I don't know how

       5      that really fits here.

       6             I understand that the "500,000" is kind of

       7      arbitrary, and that may have said, Wow, that's kind

       8      of arbitrary.

       9             Well, it is, but it's also consistent with

      10      another section of the New York law.

      11             And the same thing with the lawsuit caps that

      12      you've got in the bill, they're just a direct

      13      reference of New York usury law, at least as I read

      14      the draft that I've been circulated here.

      15             You're not just coming up with some number

      16      out of the sky, or saying, well, this is consistent

      17      with other areas of law.

      18             So I do think Professor Sebok's work with

      19      (indiscernible) Abraham, I know both of them.

      20      They're both outstanding professors.

      21             I do think it's really interesting, and

      22      I don't have any reason to question the data.  It's

      23      a dataset that I'm not privy to, so I couldn't if

      24      I wanted to.

      25             But I sort of infer different things from it







                                                                   150
       1      than Professor Sebok.

       2             I mean, he's saying that there's an average

       3      recovery -- median recovery, 50th percentile

       4      recovery, of 44 percent per year.

       5             That's a really, really, really high rate of

       6      recovery on these sorts of financial situations.

       7             And he's saying that it's a bit more than

       8      $2,000, on average, that's advanced.

       9             So these are people take -- these are pretty

      10      desperate people.

      11             I mean, let's -- let's -- let's be real here,

      12      these are pretty desperate people taking out these

      13      loans.

      14             And he says it's a volume business.

      15             As someone who studies litigation in the

      16      aggregate, and has been doing it for some time, that

      17      raises my eyebrows when I hear "this is a volume

      18      business."

      19             So, while I think these are useful

      20      situations, I mean, I don't know what it's really

      21      saying, to say, well, the median's 44 percent, not

      22      120 percent.

      23             They're both extremely high interest rates

      24      here.  And, he finds a 12 percent drop rate.

      25             That's showing that, you know, there is risk,







                                                                   151
       1      but 88 percent of the time they're getting a payout.

       2             So there's risk, but it's a fairly noble

       3      risk, and it's a noble risk when you start building

       4      a portfolio of cases, which is the whole point here.

       5             And so, sure, you're going to have risks,

       6      just like if you have a high-interest bond, you're

       7      going to have a risk.  But it's not the same as

       8      equity.

       9             So we can say it's not a loan, and,

      10      technically, it's not under New York law, but

      11      neither is it equity.

      12             The contingent fee is like equity.

      13             The lawyer is getting a third of the payout

      14      at the end, upside (indicating).  Downside, zero.

      15             Here, the downside's zero, just like with any

      16      risky sort of debt instrument.

      17             But the upside is a set payout.  It's not a

      18      percentage take.  It's a -- it's an interest rate.

      19             And the implicit interest rate that you're

      20      going to expect to get is 44 percent.

      21             So the question is:  Is that right or the

      22      wrong number?

      23             And as I sit and think about this, and

      24      started thinking about this in preparing this

      25      testimony, which, again, I go into a lot of







                                                                   152
       1      historical detail and things in here, the way to

       2      think about this for me is from two perspectives,

       3      and both of them mentioned by the other folks

       4      testifying here today.

       5             One is:  What do we think about with

       6      consumers?

       7             And that's one of the charge of this

       8      Committee:  How are we thinking about protecting

       9      these consumers?

      10             And the second is:  What does this matter for

      11      society at large?

      12             How is it going to change the way the

      13      litigation system operates?  Or how is it changing

      14      the way the litigation system operates?

      15             And they're two sort of separate questions,

      16      but I think they're both important.

      17             Now, when it comes to consumers, I'll admit,

      18      just like Mr. Ginsburg, my normal bias is to have a

      19      lot of transparency, a lot of disclosure, and let

      20      people sort of decide after that.

      21             And -- and -- I'm not a big fan, in general,

      22      of broader usury laws, which New York and other

      23      states have.

      24             I certainly wouldn't be a fan of Arkansas'

      25      usury law.  You know, it was alluded to, well,







                                                                   153
       1      Arkansas's got the wrong rate.

       2             Well, yeah.

       3             Their usury law in Arkansas is 500 basis

       4      points/5 percentage points above the federal reserve

       5      discount rate.

       6             So that's 200 basis points above the primary

       7      right now.

       8             That's an absurd usury.

       9             So, yeah, I mean, you could set the wrong

      10      usury.  Even if you wanted to say, we want to have a

      11      usury standard, you could set the wrong rate.

      12             I do think what we're talking about here,

      13      though, is something a bit different than your

      14      ordinary usury case.

      15             A paradigm case that comes in for

      16      high-interest lending, and it's one that's been in

      17      the crosshairs of the federal regulators at the CFPB

      18      recently, is -- and in Washington, otherwise, is

      19      payday lending.  Right?

      20             Now, payday lending rates can be quite high.

      21      They're very short-term interest rates set, and

      22      they're usually people who are kind of desperate to

      23      make a payment, they need to make the payment.

      24             And rather than not get health care or not

      25      default on a mortgage, et cetera, they're going to







                                                                   154
       1      take out a high-interest loan for a short basis.

       2             But, by and large, the individual taking out

       3      the loan has full understanding of the likelihood

       4      that they're going to get paid on their payday.

       5             They may get fired in the interim, but they

       6      have a pretty good idea, and almost certainly can

       7      decide, well, you know, I'm going to get paid in a

       8      week.  I need the money now.

       9             The individual who's contracting with an

      10      attorney on a lawsuit is not aware of what the odds

      11      are that they'll collect on their suit; also not

      12      aware of how much they're likely to get; and not

      13      aware of how much the attorney is going to have to

      14      do to collect it.

      15             The attorney, on the other hand, and

      16      businesses full of attorneys evaluating these

      17      claims, which is what we're talking about, is able

      18      to look at the case and say, Yep, this is a

      19      policy-limit case.

      20             That's a no-risk case.

      21             If the insurance company's going to pay out

      22      the policy limit on this case, it's no risk.

      23             Now, the attorney's still going cut it -- get

      24      a third cut in most of these cases.

      25             I mean, not always a third, but there's no







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       1      price-shopping here, because there's no way to

       2      really price-shop.

       3             There's not much price-shopping in

       4      real-estate agents -- for real-estate agents.

       5             No one's price-shopping for plaintiffs'

       6      attorneys, because nobody wants to get the cut-rate

       7      attorney to handle their case, and nobody is able to

       8      really evaluate it.

       9             So there tends to be a pretty standard rate

      10      here.  I mean, this is how this is done.

      11             And we've chronicled, and we've got Manhattan

      12      Institute papers we've published, going way back

      13      from ethicists like Richard Painter, and

      14      Lester Brickman who recently retired at Cardozo, who

      15      have gone through this, come up with reform

      16      proposals on the contingent fee itself, because

      17      there's all sorts of opportunities for the lawyer to

      18      exploit the client, because the lawyer has a lot

      19      more information than the client.

      20             And, if the lawyer's going to take a third

      21      for a case that involves no work, that's just a

      22      windfall to the lawyer.

      23             Well, you know, the lawyer at least, though,

      24      is subject to legal-ethics rules.

      25             The lawyer, at least, could be sued for legal







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       1      malpractice.

       2             The lawyer, at least, could be disbarred for

       3      unethical behavior.

       4             Right now, there's nothing protecting the

       5      consumer from these sorts of litigation-lending

       6      shops that may very well know this is a no-risk

       7      case, and still take these massive interest rates

       8      out.

       9             The consumer has no way of knowing that,

      10      which is why disclosure alone, to me, probably isn't

      11      enough in this context.

      12             The other reason why I think disclosure of

      13      loan isn't enough in this -- in these contexts, is

      14      that our legal system creates incentives for

      15      meritless litigation, abusive litigation.

      16             And this is somewhat by historical accident;

      17      right?

      18             I mean, we, unlike most of the developed

      19      world, don't have a "loser pays" rule, where, if you

      20      lose your case, you have to reimburse the other

      21      side's expenses.

      22             And that's one reason why we have contingent

      23      fees, is because it's really the only -- without --

      24      without that, I mean, that's about the only way to

      25      get people without means to be able to pay their







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       1      lawyer.

       2             But because -- but because of that, you have

       3      subsets of cases, nuisance cases, which have

       4      settlement value, because the value to litigate the

       5      case for the defendant is real, and they're going to

       6      pay you to walk away.

       7             And then you have lottery cases; cases where

       8      the probability of payout is very, very low, but the

       9      expected return across a portfolio of cases, if you

      10      are a plaintiffs' firm with a number of lawyers and

      11      a number of cases, there's -- is high.

      12             So if you take cases with 10 percent chance,

      13      and, you know, 9 out of 10 fail, but the tenth one

      14      bumps you up to 200, you made a big, big profit,

      15      even though you've lost 9 out of your 10 cases,

      16      depending on what your cost structure is to work

      17      these cases.

      18             So, why I bring this up is that, litigation

      19      finance can very well facilitate this type of

      20      abusive litigation, and, in particular, this sort of

      21      the lottery-case examples, because what they're

      22      doing is, is creating bounties for a portfolio of

      23      cases.

      24             Now -- so what this ultimately is going to

      25      do, and, again, there is a derth of evidence in







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       1      terms of how exactly this is happening, other than

       2      the fact that it's extremely high interest rates, or

       3      implicit interest rates.

       4             But -- but -- but -- but what you could do,

       5      again, is take a bunch of really weak cases with

       6      high payouts, and aggregate them together, and then

       7      get payouts at the end.

       8             Now -- now I -- Professor Sebok's evidence

       9      suggests this is not happening in the worst regard,

      10      and the reason for that is, the drop rates are

      11      actually low.

      12             So, by and large, it's more the consumer

      13      protection than a -- a -- a lottery-case model at

      14      this point.

      15             But there's nothing in an unregulated market

      16      to prevent someone from trying to aggregate, roll

      17      up, a bunch of bad claims, and -- as long as they

      18      can predict that there's a high possible payout on

      19      some of these cases.

      20             And so this would facilitate, precisely, that

      21      sort of situation.

      22             And then the individuals in question are,

      23      more likely than not, losing their case, and taking

      24      out extraordinarily high-interest loans on that

      25      case.







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       1             So -- so it's -- you know, it's -- it could

       2      happen, but it doesn't seem like it's happening that

       3      much if 88 percent of them are being upheld.

       4             So let's go, though, to the notion of the

       5      interest rate, and why we might think of this a

       6      little different than your normal sort of usury

       7      case.

       8             I mean, (a) you've got the information

       9      imbalance.

      10             So, you know, New York has usury laws.

      11             But -- but, if there's a case of usury laws

      12      in an ordinary case, there's certainly one here

      13      where there's an information imbalance.

      14             The second is the legal-ethics rules -- the

      15      second reason here, is the legal-ethics rules, and

      16      Mr. Ginsburg talked about this, you're basically

      17      severing ties.

      18             If these aren't done properly, you're

      19      severing ties and creating conflicts of interests

      20      between the lawyer and the attorney.

      21             And then the third sort of situation here is,

      22      you can create odd incentives.

      23             And one is what Mr. Ginsburg talked about,

      24      and that's really messing with settlement

      25      incentives.







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       1             And -- and -- and, you know, this is my

       2      concern, and, again, I haven't thought about it

       3      much, because I didn't know she was going to say it

       4      either, Professor Steinitz' suggestion on this, on

       5      making it sort of a recovery-based situation.

       6             My concern on that is it could really

       7      influence the motivation of parties in settlement

       8      negotiations, make it much harder to settle claims,

       9      and increase legal costs in the aggregate.

      10             I'm not sure that it's not better just to

      11      have a sort of fee cap that's a usury fee.

      12             And, again, without comment on what the right

      13      rate should be, or whether New York's got the right

      14      rate in other context, but what you know you're

      15      going to have with that is, you may or may not

      16      squeeze out some of this litigation financing.

      17             But my attitude would be is, you're squeezing

      18      out the worst of it.  Right?

      19             You're getting rid of the worst of it with

      20      those fees, and preventing lottery-type situations

      21      from, potentially, being generated by this.

      22             And I don't think the cost is that high.

      23             There are other opportunities to get for

      24      individuals who are desperate to get money at

      25      exorbitant interest rates.







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       1             And -- but I do think that, you know, we

       2      shouldn't necessarily wipe out this entire industry.

       3             But if we're going to do it, we really need

       4      to be careful about how we're regulating it, because

       5      there's a lot of perverse effects.

       6             So, lots of stuff there, and I'm happy to

       7      answer any questions.

       8             SENATOR JACOBS:  Thanks.

       9             Senator?

      10             SENATOR ORTT:  Yeah, just very quickly.

      11             So, you know, I'm hearing your comments.

      12             Would it be fair, despite the argument as

      13      always, these are high-risk loans; ergo, that's why

      14      we charge high rates?

      15             JAMES R. COPLAND:  Yeah.

      16             SENATOR ORTT:  But, yet, the evidence that

      17      was given even today, which seemed to be certainly

      18      in favor of the industry, or a study that seemed

      19      certainly to, was that they're really not nearly as

      20      high risk as they would have you believe, because

      21      88 percent have some payout.

      22             Is that -- is that your takeaway --

      23             JAMES COPLAND:  Well, 44 percent is the

      24      median payout.

      25             SENATOR ORTT:  So half of them --







                                                                   162
       1             JAMES R. COPLAND:  You could do the basic --

       2             SENATOR ORTT:  -- are higher than 44 percent?

       3             JAMES R. COPLAND:  -- right.

       4             You could do the basic math.  Right?

       5             I mean, prime rate is 4.75 percent.

       6             Add, you know, three-point -- 325 basis

       7      points to get 8 percent.  Right?

       8             You borrow at 8 percent, you know, and cover

       9      your costs with some of that surplus there, you can

      10      lose a lot more than 12 percent of your cases if

      11      your median case is bringing in 44 percent.

      12             That's an extraordinary return.

      13             One more point, if I may, just on -- because

      14      I didn't address Congressman Coehlo's comments.

      15             I do want to point out to the Committee,

      16      because this wasn't something I necessarily

      17      anticipated to put in my written comments, while

      18      I very much am sensitive to the need for legal

      19      protection for those with disabilities, you know,

      20      it's the case for a reason, that the Americans With

      21      Disabilities Act did not include a private right of

      22      action for that.

      23             Now, we do see certain private rights of

      24      action here in New York, most prominently in his

      25      native state of California, and those tend to be







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       1      abusive lawsuit-mill situations.  Right?

       2             They're not a bunch of disabled people who

       3      need $2,000 a piece.

       4             You usually have repeat litigants, who are

       5      called "vexatious litigants," eventually by the

       6      courts, who are on retainer with attorneys that file

       7      a portfolio of claims, arguing that ordinary

       8      mom-and-pop businesses don't have the signs at the

       9      right level, or the right inches between the lines,

      10      for their handicapped parking places, and things

      11      like that.

      12             And they send out letters and basically say,

      13      Give us $30,000 and we'll go away.

      14             And the defendant mom-and-pop business,

      15      because of the nature of no-loser fees -- the loser

      16      pays for fees in the United States, says, Well, it's

      17      going to cost us a hundred grand to litigate this.

      18      We'll give them the $30,000 to go away.

      19             We've documented this in a report.

      20             It's a November 2014 update of our "Trial

      21      Lawyers, Inc." series, "Wheels of Fortune," focused

      22      on disability law.  It has a number of these

      23      examples.

      24             But I certainly wouldn't hold that area of

      25      law out as an example for one to buttress this sort







                                                                   164
       1      of consumer lending.

       2             I think it cuts it exactly the opposite

       3      direction.

       4             SENATOR JACOBS:  Just, you had mentioned,

       5      I can't remember exactly, an insure -- a situation

       6      where there's an insurance claim, where you --

       7      you -- you -- was it a minimum that you need, that,

       8      essentially, it's guaranteed that that liti -- the

       9      plaintiff would get something?

      10             JAMES COPLAND:  Yeah, we -- we -- I mean, the

      11      lawyers basically know what a good claim and a bad

      12      claim is.  I mean, not with 100 percent certainty.

      13             But, I mean, this is the various situation in

      14      the fact pattern that we've done in our

      15      contingent-fee work.

      16             And Lester Brickman and Richard Painter both

      17      worked this out for us in two separate papers.

      18             But Professor Brickman's point is this:

      19             If -- if -- there doesn't have to be

      20      100 percent certainty, but if you've got a case as a

      21      plaintiff's attorney, and you know, with 95 percent

      22      certainty, the insurance company, because you know

      23      how they behave, you see these repeat cases all the

      24      time, this is a volume business again.

      25             Professor Sebok says, most of these are







                                                                   165
       1      auto-accident cases and slip-and-fall cases.

       2             These are repeat cases, they're relatively

       3      simple, you know what you're going to get.

       4             If you're the plaintiff's attorney, and you

       5      know, with 95 percent certainty, you're going to get

       6      the insurance policy limit on the case, and that's

       7      the payout, well, one-third fee to sign on for that,

       8      you have to do, virtually, no work.

       9             You send a letter, you know, you get your

      10      name on the (indicating) board, and you've got a

      11      massive return.

      12             I mean -- and this is under an ordinary

      13      contingent-fee situation.

      14             That's part of our problem with ordinary

      15      contingent-fee arrangements in the law.

      16             This sort of situation is the same thing,

      17      except, that instead of getting an equity stake,

      18      you're getting a high-interest loan on a low-risk

      19      case.

      20             And, you know, given the drop rates, a lot of

      21      these are low-risk cases they're taking.

      22             And so you're, basically, just exploiting the

      23      ignorance of the claimant in this case, the

      24      plaintiff in this case, and getting an extraordinary

      25      return from that plaintiff by virtue of this.







                                                                   166
       1             So -- so -- so it's -- it's precisely the

       2      sort of thing I think we ought to worry about, you

       3      know, as regulators, particularly, because, I mean,

       4      let's be clear on this:

       5             I mean, yes, there are some ways the

       6      contingent fees and these structures, you know, are

       7      market-based, in a sense.  But the underlying

       8      vehicle here isn't an exchange of two parties in the

       9      market.

      10             The only vehicle here is that you have a

      11      court system, which is the State, that uses the

      12      State's monopoly of the use of force, that comes in

      13      there and says, We're going to take from you and

      14      give to you.

      15             Now, we need that court system.

      16             There's a good reason for our tort system.

      17             There's a good reason for recovery from

      18      accidents, and things like this.

      19             But, we want to make sure that it's not

      20      abused.

      21             SENATOR JACOBS:  Thank you very much.

      22             Any other questions?

      23             SENATOR ORTT:  Thank you.

      24             SENATOR JACOBS:  Well, I want to thank

      25      everyone who participated today in today's hearing.







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       1             I certainly found it very beneficial.

       2             I hope my colleagues did as well.

       3             I want to thank Senator Ortt for being here,

       4      and Assemblyman Magnarelli for being here in the

       5      audience, for the entirety of this hearing.

       6             Again, thank you very much, and this

       7      concludes today's hearing.

       8                  (Whereupon, at approximately 2:47 p.m.,

       9        the public hearing held before the New York State

      10        Senate Standing Committee on Consumer Protection

      11        concluded, and adjourned.)

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