UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-CV-81205-RAR

SECURITIES AND EXCHANGE 

COMMISSION,

Plaintiff,

v.

COMPLETE BUSINESS SOLUTIONS 

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

Defendants.

_______________________________/ 

ORDER GRANTING RECEIVER’S FIFTH APPLICATION FOR ALLOWANCE AND 

PAYMENT OF PROFESSIONALS’ FEES AND REIMBURSEMENT OF EXPENSES 

FOR JULY 1, 2021 – SEPTEMBER 30, 2021

THIS CAUSE comes before the Court upon Receiver Ryan K. Stumphauzer’s Fifth

Application for Allowance and Payment of Professionals’ Fees and Reimbursement of Expenses 

for July 1, 2021 – September 30, 2021 [ECF No. 948] (“Application”), filed on November 15, 

2021.1 The Court has reviewed the Application and is otherwise fully advised. 

This is a complex receivership involving the operation of a merchant cash advance business 

with a current receivable balance of over $400 million, and a group of investors that are seeking, 

collectively, more than $300 million dollars from the company. The Receiver and his

professional team are managing numerous operational issues involving more than 1,300 merchants 

that are parties to merchant cash advance agreements with Par Funding. The Application and 

1 The Court notes that the Receiver’s Fourth Application for Allowance and Payment of Professionals’ 

Fees [ECF No. 699] contained a scrivener’s error, whereby the time period covered by the Application was 

April 1, 2021 through July 31, 2021. The Court entered its Order Granting the Receiver’s Fourth 

Application [ECF No. 734] as such. However, as reflected in the supporting time records and other 

documentation, the Fourth Application and Order only covered the payment of fees and reimbursements 

for the period of April 1, 2021 through June 30, 2021. [ECF No. 956].

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records submitted by the Receiver reflect that the Receiver and his professional team have

reasonably and diligently discharged their duties. 

The Receiver’s tasks in this case have included negotiating with Par Funding’s merchants 

in an effort to reach settlements of MCA account balances; employing consultants to oversee and 

manage Par Funding; pursuing various claims against non-parties that may generate additional 

income to the Receivership Estate; assuming responsibilities over various residential and 

commercial properties; responding to issues and document requests related to pending litigation 

and investigations involving the Receivership Entities; communicating with the Defendants and 

responding to discovery requests; and drafting status reports for the Court.

In performing these tasks, among others, the Receiver and his professional team have 

provided a significant benefit to the Receivership Estate, investors, and creditors at rates that the 

Court finds reasonable. Accordingly, it is hereby

ORDERED AND ADJUDGED that the Application [ECF No. 948] is GRANTED as 

follows:

Professional Fees: $1,949,536.25

Expenses: $137,757.21

TOTAL: $2,087,293.46

DONE AND ORDERED in Fort Lauderdale, Florida, this 17th day of November, 2021.

 _________________________________

 RODOLFO A. RUIZ II

 UNITED STATES DISTRICT JUDGE

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