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In re Kabbage, Inc. (KServicing) — Interim Order Authorizing PPP Loan Servicing Activities

Date
2022-10-06

Summary

Doc 89-2, filed October 6, 2022 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware, is Exhibit B, an Interim Order signed by United States Bankruptcy Judge Craig T. Goldblatt and dated October 6th, 2022. The order authorizes the debtors, on an interim basis, to continue servicing and subservicing their PPPLF, Partner Bank, KS PPP and Legacy Loan portfolios and to remit borrower overpayments. It permits payment of prepetition Critical Vendor claims up to $75,000 in the aggregate and continued compliance with state licensing and regulatory obligations. It preserves the SBA's authority under the Small Business Act, including 15 U.S.C. §§ 636(a)(36), 636(a)(37) and 636m, and sets a final hearing for October 26, 2022.

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                   Case 22-10951-CTG   Doc 89-2   Filed 10/06/22   Page 1 of 8




                                         EXHIBIT B

                                        Interim Order




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                               UNITED STATES BANKRUPTCY COURT
                                    DISTRICT OF DELAWARE

------------------------------------------------------------ x
In re                                                        :         Chapter 11
                                                             :
KABBAGE, INC. D/B/A KSERVICING, et al., :                              Case No. 22-10951 (CTG)
                                                             :
                                                             :
                             1
                  Debtors.                                   :         (Jointly Administered)
                                                             :
                                                             :         Ref. Docket No. 11
------------------------------------------------------------ x
      INTERIM ORDER AUTHORIZING DEBTORS TO (I) CONTINUE SERVICING
    AND SUBSERVICING ACTIVITIES AND (II) PERFORM RELATED OBLIGATIONS

                    Upon the motion (the “Motion”)2 of Kabbage, Inc. d/b/a KServicing and its debtor

affiliates, as debtors and debtors in possession in the Chapter 11 Cases (collectively,

the “Debtors”), for entry of orders authorizing the Debtors to continue in the ordinary course of

business (a) servicing and subservicing PPP Loans; (b) servicing and subservicing Legacy Loans;

(c) engaging in activities related to the Overpayment Procedures; (d) paying and honoring

prepetition obligations to Critical Vendors; and (e) fulfilling compliance and regulatory

obligations, all as more fully set forth in the Motion; and this Court having jurisdiction to consider

the Motion and the relief requested therein pursuant to 28 U.S.C. §§ 157(a)–(b) and 1334(b), and

the Amended Standing Order of Reference from the United States District Court for the District of

Delaware, dated February 29, 2012; and consideration of the Motion and the requested relief being

a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper before this Court


1
    The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification
    number, as applicable are: Kabbage, Inc. d/b/a KServicing (3937); Kabbage Canada Holdings, LLC (N/A); Kabbage
    Asset Securitization LLC (N/A); Kabbage Asset Funding 2017-A LLC (4803); Kabbage Asset Funding 2019-A
    LLC (8973); and Kabbage Diameter, LLC (N/A). Kabbage is a trademark of American Express used under license;
    Kabbage, Inc. d/b/a KServicing is not affiliated with American Express. The Debtors’ mailing and service address
    is 925B Peachtree Street NE, Suite 383, Atlanta, GA 30309.
2
    Capitalized terms used but not otherwise defined herein shall have the respective meanings ascribed to such terms
    in the Motion.




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pursuant to 28 U.S.C. §§ 1408 and 1409; and due and proper notice of the Motion having been

provided to the Notice Parties under the circumstances, and it appearing that no other or further

notice need be provided; and this Court having held a hearing to consider the interim relief

requested in the Motion (the “Hearing”); and upon the Rieger-Paganis Declaration and the record

of the Hearing; and this Court having determined that the legal and factual bases set forth in the

Motion establish just cause for the relief granted herein; and it appearing that the relief requested

in the Motion is necessary to avoid immediate and irreparable harm to the Debtors and their estates

as contemplated by Rule 6003 of the Federal Rules of Bankruptcy Procedure, and after due

deliberation and sufficient cause appearing therefor,

                    IT IS HEREBY ORDERED THAT

                    1.    The Motion is granted on an interim basis to the extent set forth herein.

                                           PPPLF Portfolio

                    2.    The Debtors are authorized, but not directed, to continue in the ordinary

course of business, servicing and subservicing their loan portfolio.

                    3.    With regards to the PPPLF Portfolio, the Debtors are authorized, but not

directed, to continue in the ordinary course of business:

                    (a)   collecting and accounting for Pledged PPPLF Loan payments received from
                          borrowers, including payments of principal and interest;

                    (b)   maintaining a software platform for borrowers;

                    (c)   assisting borrowers in the completion of their Loan Forgiveness
                          applications;

                    (d)   submitting Guaranty Purchase applications to the SBA;

                    (e)   subject to the completion of SBA Direct Payment Processing, depositing
                          Loan Forgiveness and Guaranty Purchase amounts received from the SBA




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                           and Pledged PPPLF Loan payments received from borrowers into the
                           correspondent bank account;3 and

                    (f)    conducting loan reviews, reconciling collections and remittances,
                           responding to inquiries, and engaging in other activities in connection with
                           the foregoing.

                                           Partner Bank Portfolio

                    4.     With regards to the Partner Bank Portfolio, the Debtors are authorized, but

not directed, to continue in the ordinary course of business:

                    (a)    collecting and accounting for Partner Bank Loan payments received from
                           borrowers, including payments of principal and interest;

                    (b)    maintaining a software platform for borrowers;

                    (c)    assisting borrowers in the completion of their Loan Forgiveness
                           applications;

                    (d)    assisting the Partner Banks in their submissions for Guaranty Purchase and
                           other reports; and

                    (e)    conducting loan reviews, reconciling collections and remittances
                           responding to inquiries, and engaging in other activities in connection with
                           the foregoing.

                                              KS PPP Portfolio

                    5.     With regards to the KS PPP Portfolio, the Debtors are authorized, but not

directed, to continue in the ordinary course of business:

                    (a)    collecting and accounting for KS PPP Loan payments received from
                           borrowers, including payments of principal and interest;

                    (b)    maintaining a software platform for borrowers;

                    (c)    assisting borrowers in the completion of their Loan Forgiveness
                           applications;

                    (d)    submitting Guaranty Purchase applications to the SBA; and

3
    For the avoidance of doubt, once SBA Direct Payment Processing is established, the Company will only deposit
    borrower principal and interest payments into the correspondent bank account, and all SBA payments will be
    remitted directly to the Federal Reserve by the SBA.




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                    (e)   conducting loan reviews, reconciling collections and remittances,
                          responding to inquiries, and engaging in other activities in connection with
                          the foregoing.

                                        Legacy Loan Portfolio

                    6.    With regards to the Legacy Loan Portfolio, the Debtors are authorized, but

not directed, to continue in the ordinary course of business:

                    (a)   collecting and accounting for Legacy Loan payments received from
                          borrowers, including payments of principal and interest;

                    (b)   maintaining a software platform for borrowers; and

                    (c)   conducting loan reviews, responding to inquiries, and engaging in other
                          activities in connection with the foregoing.

                                       Borrower Overpayments

                    7.    The Debtors are authorized, but not directed, to continue in the ordinary

course of business:

                    (a)   remitting Regular Overpayments to borrowers;

                    (b)   remitting Forgiveness Overpayments to borrowers;

                    (c)   adjusting remittances to the Federal Reserve and Partner Banks pursuant to

                          Overpayment Reconciliation; and

                    (d)   remitting Guaranty Overpayments to the SBA.

                                           Critical Vendors

                    8.    The Debtors are authorized, but not directed, in the reasonable exercise of

their business judgment, to pay some or all of the prepetition claims of the Critical Vendors, upon

such terms and in the manner provided in this Interim Order and the Motion; provided, that

payments to Critical Vendors on account of prepetition claims shall not exceed $75,000 in the

aggregate, absent further order of the Court.




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                    9.    If a Critical Vendor refuses to supply services to the Debtors on Customary

Trade Terms (or such other terms as are agreed by the parties) following receipt of payment on its

prepetition claim, the Debtors’ rights to treat any payment made pursuant to this Interim Order as

an unauthorized postpetition transfer and to exercise any and all appropriate remedies are expressly

reserved.

                    10.   Notwithstanding entry of this Interim Order, the Debtors’ rights to enforce

the automatic stay provision of section 362 of the Bankruptcy Code with respect to any creditor

who demands payments of its prepetition claims as a condition to doing business with the Debtors

postpetition are preserved.

                              Compliance and Regulatory Obligations

                    11.   The Debtors are authorized, but not directed, to continue in the ordinary

course of business:

                    (a)   fulfilling state licensing requirements and to pay related obligations;

                    (b)   submitting to, and complying with, state regulatory exams and audits and to
                          pay related obligations, costs, and expenses; and

                    (c)   remediating errors and/or lack of compliance with laws or regulations.

                                              Other Relief

                    12.   Each of the Banks at which the Debtors maintain their accounts relating to

payments on account of obligations related to servicing and subservicing PPP Loans and Legacy

Loans and the Related Obligations are authorized to (a) receive, process, honor, and pay all checks

presented for payment, and to honor all fund transfer requests made by the Debtors related thereto,

to the extent that sufficient funds are on deposit in those accounts, and (b) accept and rely on all

representations made by the Debtors with respect to which checks, drafts, wires, or automated

clearing house transfers should be honored or dishonored in accordance with this or any other



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order of this Court, whether such checks, drafts, wires, or transfers are dated before, on, or after

the Petition Date, without any duty to inquire otherwise.

                    13.   The Debtors are authorized, but not directed, to issue new postpetition

checks, or effect new electronic funds transfers, on account of obligations related to servicing and

subservicing PPP Loans and Legacy Loans and the Related Obligations as set forth herein, and to

replace any prepetition checks or electronic fund transfer requests that may be lost or dishonored

or rejected as a result of the commencement of the Debtors’ Chapter 11 Cases.

                    14.   The relief granted herein is without prejudice to SBA’s authority and rights,

and responsibilities to third parties, under the Small Business Act, including 15 U.S.C. §§

636(a)(36), 636(a)(37) and 636m, and the regulations, FAQs, notices, forms, and other guidance

promulgated by SBA for the Paycheck Protection Program, including the SBA Form 3507

executed by the Debtors; and other applicable SBA Loan Program Requirements (as defined in 13

C.F.R. § 120.10); and other applicable federal law, including without limitation, the right of setoff,

if any.

                    15.   For the avoidance of doubt, nothing contained in this Order shall reduce,

limit, or release the Debtors’ statutory, regulatory, and/or contractual obligations to honor timely

and in full their payment obligations to SBA, if any.

                    16.   Nothing contained in the Motion or this Interim Order, nor any payment

made pursuant to the authority granted by this Interim Order, is intended to be or shall be construed

as an approval, assumption, adoption, or rejection of any agreement, contract, lease, program, or

policy between the Debtors and any third party under section 365 of the Bankruptcy Code.




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                    17.   Nothing contained in the Motion or this Interim Order relieves the Debtors

from any federal, state, or local regulatory requirements, including, but not limited to, any

requirements to report or disclose information.

                    18.   Notwithstanding entry of this Interim Order, nothing herein shall create, nor

is intended to create, any rights in favor of or enhance the status of any claim held by any party.

                    19.   The requirements of Bankruptcy Rule 6003(b) have been satisfied.

                    20.   Under the circumstances of these Chapter 11 Cases, notice of the Motion is

adequate under Bankruptcy Rule 6004(a).

                    21.   Notwithstanding Bankruptcy Rule 6004(h), this Interim Order shall be

immediately effective and enforceable upon its entry.

                    22.   The Debtors are authorized to take all action necessary to effectuate the

relief granted in this Interim Order.

                    23.   This Court shall retain jurisdiction to hear and determine all matters arising

from or related to the implementation, interpretation, or enforcement of this Interim Order.

                    24.   The final hearing to consider the relief requested in the Motion shall be held

on October 26, 2022 at 10:30 a.m. (Prevailing Eastern Time), and any objections or responses to

the Motion shall be in writing, filed with the Court, and served on or prior to October 19, 2022 at

4:00 p.m. (Prevailing Eastern Time).




 Dated: October 6th, 2022                    CRAIG T. GOLDBLATT
 Wilmington, Delaware                        UNITED STATES BANKRUPTCY JUDGE




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