UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 20-CV-81205-Ruiz/Reinhart

SECURITIES AND EXCHANGE

COMMISSION,

Plaintiff,

vs.

COMPLETE BUSINESS SOLUTIONS

GROUP, INC. d/b/a PAR FUNDING, et al.,

Defendants.

_________________________________/

REPORT AND RECOMMENDATION REGARDING 

RECEIVER’S FIRST APPLICATION FOR

ALLOWANCE AND PAYMENT OF PROFESSIONALS’ FEES AND 

REIMBURSEMENT OF EXPENSES (ECF No. 438) 

THIS CAUSE is before this Court upon an Order referring the motions related to the 

Receiver’s fee application to the undersigned for appropriate disposition. ECF No. 451.

Currently before the Court is the First Application (the “Application”) for Allowance and 

Payment of Professionals’ Fees and Reimbursement of Expenses for July 27, 2020 through 

September 30, 2020, submitted by Ryan K. Stumphauzer, Esq., the Court-Appointed Receiver 

(“Receiver”) of the Receivership Entities.1 ECF No. 438. The Court has reviewed the Application 

and the record and is otherwise fully advised. 

1 The “Receivership Entities” are Complete Business Solutions Group, Inc. d/b/a Par Funding (“Par Funding”); Full 

Spectrum Processing, Inc.; ABetterFinancialPlan.com LLC d/b/a A Better Financial Plan (“ABFP”); ABFP 

Management Company, LLC f/k/a Pillar Life Settlement Management Company, LLC; ABFP Income Fund, LLC; 

ABFP Income Fund 2, L.P.; United Fidelis Group Corp.; Fidelis Financial Planning LLC; Retirement Evolution 

Group, LLC;, RE Income Fund LLC; RE Income Fund 2 LLC; ABFP Income Fund 3, LLC; ABFP Income Fund 4, 

LLC; ABFP Income Fund 6, LLC; ABFP Income Fund Parallel LLC; ABFP Income Fund 2 Parallel; ABFP Income 

Fund 3 Parallel; ABFP Income Fund 4 Parallel; and ABFP Income Fund 6 Parallel; ABFP Multi-Strategy Investment 

Fund LP; ABFP Multi-Strategy Fund 2 LP; and MK Corporate Debt Investment Company LLC.

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This case involves a complex receivership. In the six months since the SEC filed this action, 

the Receiver and his professional team have expended considerable effort in managing the 

receivership entities. The professionals have provided valuable services, including obtaining 

access to and reviewing records, issuing subpoenas, responding to investor inquiries, investigating 

potential claims against third parties, overseeing the day-to-day operations of Par Funding through 

an operations consultant, conducting witness interviews, communicating with the Defendants, 

drafting status reports – all to the benefit of the investors and creditors. Considering the work 

performed and the results achieved thus far, I find that the amount requested is reasonable and 

justified by the Application and exhibits attached thereto.

REPORT AND RECOMMENATION

Accordingly, this Court RECOMMENDS that the District Court GRANT the Application 

for Fees as follows:

Professional fees $2,073,116.31

Expenses $81,902.33

TOTAL $2,155,018.64

NOTICE OF RIGHT TO OBJECT

A party shall serve and file written objections, if any, to this Report and Recommendation 

with the Honorable Rodolfo A. Ruiz, United States District Court Judge for the Southern District 

of Florida, within FOURTEEN (14) DAYS of being served with a copy of this Report and 

Recommendation. Failure to timely file objections shall constitute a waiver of a party's "right to 

challenge on appeal the district court’s order based on unobjected-to factual and legal 

conclusions." 11th Cir. R. 3-1 (2016).

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If counsel do not intend to file objections, they shall file a notice advising the District 

Court within FIVE DAYS of this Report and Recommendation.

DONE AND SUBMITTED in Chambers this __ day of February, 2021 at West Palm 

Beach in the Southern District of Florida.

BRUCE REINHART

United States Magistrate Judge

cc: Counsel of Record

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