IN THE UNITED STATES DISTRICT COURT 

FOR THE 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. 

______________________________________/ 

RECEIVER RYAN K. STUMPHAUZER’S 

QUARTERLY STATUS REPORT DATED OCTOBER 31, 2022 

Ryan K. Stumphauzer, Esq., Court-Appointed Receiver (“Receiver”) of the Receivership 

Entities,1 pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

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

Spectrum Processing, Inc.; ABetterFinancialPlan.com LLC d/b/a A Better Financial Plan; 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; ABFP Income Fund 6 Parallel; ABFP Multi-Strategy Investment 

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

LLC; Capital Source 2000, Inc.; Fast Advance Funding LLC; Beta Abigail, LLC; New Field 

Ventures, LLC; Heritage Business Consulting, Inc.; Eagle Six Consultants, Inc.; 20 N. 3rd St. 

Ltd.; 118 Olive PA LLC; 135-137 N. 3rd St. LLC; 205 B Arch St Management LLC; 242 S. 21st 

St. LLC; 300 Market St. LLC; 627-629 E. Girard LLC; 715 Sansom St. LLC; 803 S. 4th St. LLC; 

861 N. 3rd St. LLC; 915-917 S. 11th LLC; 1250 N. 25th St. LLC; 1427 Melon St. LLC; 1530 

Christian St. LLC; 1635 East Passyunk LLC; 1932 Spruce St. LLC; 4633 Walnut St. LLC; 1223 

N. 25th St. LLC; Liberty Eighth Avenue LLC; The LME 2017 Family Trust; Blue Valley 

Holdings, LLC; LWP North LLC; 500 Fairmount Avenue, LLC; Recruiting and Marketing 

Resources, Inc.; Contract Financing Solutions, Inc.; Stone Harbor Processing LLC; LM Property 

Management LLC; and ALB Management, Inc., and the Receivership also includes the properties 

located at 568 Ferndale Lane, Haverford PA 19041; 105 Rebecca Court, Paupack, PA 18451; 107 

Quayside Dr., Jupiter FL 33477; and 2413 Roma Drive, Philadelphia, PA 19145. 

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hereby files this Quarterly Status Report dated October 31, 2022. By way of summary, the 

Receivership Estate consists of, among other things, approximately $55 million of real property, 

$3 million in other tangible assets the Receiver has brought into the Receivership Estate (including 

boats, cars, artwork, and luxury watches), and $116,513,918 in cash (as of September 30, 2022). 

As of October 28, 2022, the current cash balance was $118,158,801. The report attached as Exhibit 

1 includes a schedule reflecting the net tangible assets contained within the Receivership Estate. 

I. Overall Administration of Receivership Estate

A. Quarterly Report of Receivership Estate

Pursuant to the requirements of the Amended Order Appointing Receiver [ECF No. 141], 

attached as Exhibit 1 is a full report and accounting reflecting (to the best of the Receiver’s 

knowledge as of the period covered by the report) the existence, value, and location of all 

Receivership Property, and of the extent of liabilities, both those claimed to exist by others and 

those the Receiver believes to be legal obligations of the Receivership Estates (the “Quarterly 

Report”). The Quarterly Report contains the following information: (1) summary of the operations 

of the Receiver; (2) the amount of cash on hand, the amount and nature of accrued administrative 

expenses, and the amount of unencumbered funds in the estate; (3) a schedule of all the Receiver’s 

receipts and disbursements (attached as Exhibit A to the Quarterly Status Report), with one column 

for the quarterly period covered and a second column for the entire duration of the receivership; 

(4) a description of all known Receivership Property, including approximate or actual valuations, 

anticipated or proposed dispositions, and reasons for retaining assets where no disposition is 

intended; (5) a description of liquidated and unliquidated claims held by the Receivership Estate, 

including the need for forensic and/or investigatory resources; approximate valuations of claims; 

and anticipated or proposed methods of enforcing such claims (including likelihood of success in: 

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(i) reducing the claims to judgment; and, (ii) collecting such judgments); (6) a list of all known 

creditors with their addresses and the amounts of their claims; (7) the status of Creditor Claims 

Proceedings, after such proceedings have been commenced; and (8) the Receiver’s 

recommendations for a continuation or discontinuation of the receivership and the reasons for the 

recommendations, as required pursuant to Paragraphs 53 and 54 of the Amended Order Appointing 

Receiver dated August 13, 2020 [ECF No. 141]. 

II. Update on Other Assets Included within the Receivership Estate

A. Accounts Receivable and Collection Activities 

At the time of his appointment, the Receiver obtained control over $28,779,570 in cash 

held by the various original Receivership Entities. As a result of various Orders expanding the 

Receivership, the Receiver obtained an additional $14,756,649 in cash held by the additional 

Receivership Entities. The Receiver has also acquired an additional $97,679,643 in cash through

collections, settlements, and other recoveries. After accounting for expenses, the total cash balance 

was $116,513,918 as of September 30, 2022. As of October 31, 2022, the current cash balance 

was $118,158,801. 

B. Accounts Receivable – Merchant Cash Advance Accounts

The Receiver, his professionals, and the staff he rehired at Par Funding have been 

continuing to collect on the accounts receivable for the merchant cash advance (“MCA”) accounts 

that were pending with the company as of the time the Receiver took over the operations of Par 

Funding. Historically, the Receiver has reported the entire accounts receivable balances that were 

on Par Funding’s books for these MCA accounts, while explaining that these balances did not 

reflect appropriate reductions or reserves for collectability or bad debt. Beginning with the prior

reporting period (April 1, 2022 through June 30, 2022), the Receiver, through his outside 

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consultants, counsel, and internal collection staff and accountants, has analyzed the collectability 

of the balances for all MCA companies. Through this reporting period, the Receiver determined 

that certain amounts should be written off due to closed bankruptcies, circumstances where the 

merchant is out of business, and circumstances where there is neither viable guarantors nor viable 

collateral. In analyzing the MCA balances, the Receiver also determined that a reserve was 

required for accounts with ongoing bankruptcies and other circumstances where full payment is 

doubtful. See DSI’s Report, attached as Exhibit 1. At the end of the prior reporting period (April 

1, 2022, through June 30, 2022), the net result of these adjustments was a reduction of the total 

receivable balance from approximately $345 million to $224 million. At the end of the current 

reporting period, the total receivable balance was further reduced as a result of these adjustments 

to a total of $189 million. The Receiver will continue to analyze this portfolio to determine 

realistic write-offs and allowances for additional amounts that are not likely to be collected. 

Based upon an analysis of information available to CBSG management as of December 

31, 2018, and December 31, 2019, the Receiver, together with his counsel, Full Spectrum 

Processing staff, and operational consultants from DSI, determined that several merchant 

balances were uncollectible and should have been written off prior to the filing of the tax returns 

for those years. The Receiver considered many factors, including merchants that had declared or 

been discharged in bankruptcy, merchants that had not paid for several months and were, 

therefore, uncollectible according to the company’s own existing policies, and merchants that had 

ceased operations and, therefore, had no future revenues to repay MCA balances. The Receiver 

believes that CBSG and related entities will not have any taxable income for these prior years 

and, therefore, may be entitled to substantial tax refunds. 

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C. Collection Efforts Through Outside Collection Company and Litigation

Altus Receivables Management, Inc. (“Altus”) is a national collection company that the 

Receiver has engaged on a contingency fee recovery basis. Altus is seeking to collect judgments 

previously entered against select non-performing, non-bankruptcy merchants, guarantors, and 

counterparties that had outstanding balances and/or were otherwise in default at the time of the 

establishment of the receivership (collectively “merchants”). Thus, these recovery efforts are 

being pursued in the ordinary course of the administration and operation of the receivership.

The judgments against these merchants are being exemplified under Pennsylvania law 

and will be domesticated for legal action in the merchant’s home state and where assets may be 

found. The judgments referred to Altus range from low five (5)-figure balance accounts to 

accounts in excess of one million dollars ($1,000,000), based upon the Receivership Entities’ 

records. Referrals began on January 9, 2022, and 207 exemplified judgments have since been 

referred to Altus with active collection efforts are underway. The Receiver has also initiated 49 

actions against merchants in the Philadelphia Court of Common Pleas either through civil action 

complaints or confessions of judgment. The cases filed in Philadelphia typically have resulted in 

either legal challenges to the underlying agreements; offers of settlement; or default or confessed 

judgments. Thus far, merchant challenges to the underlying agreements have been unsuccessful. 

The Receivership Estate is receiving offers of settlement through the Receiver’s litigation in the 

Philadelphia Court of Common Pleas and Altus collection activities. The Receiver is considering 

and, where appropriate, approving offers when he deems the proposal to be in the best interests 

of the Receivership Estate. Finally, as additional judgments become available from the 

Philadelphia litigation, they will be assigned to Altus for further collection efforts if not resolved 

by the Receiver directly with the merchant.

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D. Collection Activity and Settlements with ESC and HBC Counterparties

To date, the Receiver has resolved, either through full payoffs of the amount owed or 

settlements, the account balances of several counterparties to agreements with Eagle Six 

Consultants, Inc. (“ESC”) and Heritage Business Consulting, Inc. (“HBC”). In addition, the Court 

has entered motions to lift the litigation injunction to allow the Receiver to pursue claims against 

several counterparties (and their guarantors) to agreements with ESC and HBC. [ECF No. 642; 

ECF No. 747; ECF No. 879]. The Receiver is in active litigation and/or settlement discussions 

with several of these counterparties for which the litigation injunction has been lifted.

E. Life Settlements

Two of the Receivership Entities—ABFP Multi-Strategy Investment Fund LP (“MSIF”) 

and ABFP Multi-Strategy Investment Fund II LP (“MSIF II”)—own portfolios of life settlement 

policies. Since the time of his appointment, the Receiver and his consultants at DSI have been 

managing these portfolios. These duties have included, among other things, the payment of 

premiums, corresponding with the insurers and servicers of these policies, and communicating 

with a potential third party regarding a valuation and potential purchase of these policies. The 

Receiver has received total death benefits payable for policies owned by MSIF in the amount of 

$3,032,479. With respect to MSIF II, the Receiver has received total death benefits totaling 

$5,450,000. These amounts only include the policy face value the Receiver has received on these 

policies, and exclude any interest or dividends the Receiver has received for these policies.

Additionally, the Receiver has explored a potential sale of the remaining life settlements. 

Based on the expected valuation of the policies, a sale of these assets would result in a payment of 

significantly less than the face value of these policies, as well as significantly less than the principal 

amounts on the books as due to the investors in these two funds. The Receiver continues to explore 

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options regarding holding and continuing to await the receipt of additional death benefits or a sale 

of the portfolio.

III. Receiver-Controlled Real Estate

A. The McElhone Properties

As previously noted, the Receiver controls 25 properties, either directly or indirectly owned 

by Lisa McElhone (collectively, the “Receiver-Controlled Properties”). Three (3) are singlefamily residential properties previously occupied by Joseph LaForte and McElhone (the “SingleFamily Homes”): 107 Quayside Drive, Jupiter Florida (the “Florida Home”); 105 Rebecca Court, 

Paupack, Pennsylvania (the “Poconos Home”); and 568 Ferndale Lane, Haverford Pennsylvania 

(the “Haverford Home”). Pursuant to an agreement with the Receiver, McElhone and LaForte 

may live in the Haverford Home, but may not occupy or otherwise use the Florida Home or 

Poconos Home. McElhone and LaForte pay the Receiver rent for the Haverford Home and are 

responsible for paying all carrying costs (taxes, insurance, and maintenance) for all 3 SingleFamily Homes.

Two other properties historically have been used for business operations, 20-22 North 3rd

Street (4 units) and 205 B Arch Street. The Receiver has consolidated all CBSG business 

operations within the 20-22 North 3rd Street office suite and directed OCF to market 205 B Arch 

Street for rent. The remaining 20 Receiver-Controlled Properties are either commercial, 

residential, or mixed-use rental properties in Philadelphia. Prior to the Receivership, these 

properties were managed by OCF Realty LLC (“OCF”) at McElhone’s direction. The Receiver 

has retained OCF to continue its management services for these properties (the “OCF-Managed 

Properties”). The 20 OCF-Managed Properties comprise 121 rental units (110 residential units 

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and 11 commercial units). The Receiver, through OCF, continues to collect rent, pay the necessary 

expenses, and market units for rent as they become available. 

The Receiver recently obtained from OCF a broker’s opinion of potential sales values for 

the OCF-Managed Properties. The estimated value of the OCF-Managed Properties is 

$44,284,000. The acquisition price for these OCF-Managed Properties, which the Receiver has 

utilized as the value of these assets in prior reports, was $41,986,900. Additionally, the acquisition 

price for the three residences is $10,845,000. The Receiver has not yet taken any steps to market 

the residences for sale and, as a result, has not undertaken to obtain a current appraisal of the 

market value for those three properties.

B. Title Clearance Efforts 

As previously noted, certain title defects encumber several Receiver-Controlled Properties

dating back to McElhone’s original acquisition. As reported in the Receiver’s prior Status Reports, 

these title defects, which primarily relate to a failure to terminate prior owner-created liens, were 

effectively “insured over” through the title insurance policies provided to McElhone at closing. 

The Receiver is continuing to attempt to resolve these liens. 

C. Abbonizio Properties

Pursuant to the Receiver’s settlement with Perry Abbonizio and PCA 159 26th St. Avalon 

LLC, the Receiver acquired two single family properties located in Cape May County, New Jersey:

159 26th Street, Avalon, NJ (the “Avalon Property”) and 164 84th Street, Stone Harbor, NJ (the 

“Stone Harbor Property”). During the current reporting period, the Receiver entered into 

agreements to sell these two properties and closed on those sales. The Stone Harbor Property, 

which appraised for $3,818,000, sold for a price of $4,150,000 and the Avalon Property, which 

appraised for $4,015,000, sold for a price of $4,025,000. After paying off mortgages that 

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encumbered these properties and other customary closing costs, the Receiver deposited the 

remaining sales proceeds and rental income into the bank account of the Receivership Estate. 

IV. Information Regarding Anticipated Claims and Distribution Process

The Receiver continues to receive numerous inquiries from investors and other creditors 

of the Receivership Entities regarding the timing of a claims and distribution process in this matter, 

as well as an estimate of the potential amounts that will be distributed to each investor/creditor. 

With respect to timing, the Receiver continues to assemble information regarding all known 

investors in and creditors of the Receivership Entities. Now that the Court has entered its final 

judgments against Lisa McElhone, Joseph LaForte, Joseph Cole Barleta, and Michael Furman, the 

Receiver is endeavoring to understand how these Defendants intend to satisfy the judgments 

entered against them, including the possibility of using funds or other assets(such as the real estate)

within the Receivership Estate to satisfy, in part, these judgments. Once there is further clarity on 

this point, the Receiver anticipates that the claims and distribution process will begin as soon as 

possible thereafter. 

There still remain a number of questions and uncertainties surrounding the accounts 

receivable of the Receivership Entities and other claims the Receiver is pursuing or otherwise 

evaluating. These additional recoveries would potentially be available to further satisfy portions 

of the judgments entered against the Defendants. The Receiver is also formulating a 

recommendation for a procedure to determine the manner in which various claims will be 

evaluated and administered. As a result, it is still too early for the Receiver to provide any 

estimates of the amounts that may be available—either on an individual level or in total—for 

distribution to investors and other creditors. 

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Additionally, given that certain claims or collection efforts from various sources of 

potential recovery are not likely to be resolved in the near future, the Receiver also anticipates the 

possibility of recommending a phased distribution process. Under this phased process, the 

Receiver would request permission to make an initial distribution from amounts already collected, 

after the Receiver has further clarity about how much is available for distribution from the cash 

and other assets currently in the Receivership Estate, as well as any other amounts the Defendants 

may pay in partial satisfaction of the judgments entered against them. Then, as the Receiver 

continues to recover additional funds on behalf of the Receivership Estate and otherwise liquidates 

assets the Receiver has collected, the Receiver would anticipate making a supplemental 

distribution (or supplemental distributions, depending on the timing of these future recoveries). 

The Receiver and his professional staff will continue to evaluate these issues and provide updates 

as they are available. Information regarding the proposed claims and distribution plan will be 

posted on the Receivership website after the Receiver has filed it with the Court.

V. Expansion of Receivership Estate 

In total, the Receiver has filed and obtained Orders from the Court granting 10 motions to 

expand the Receivership Estate. In addition, as the Receiver has previously reported, the Court’s 

Order Granting Motion to Expand Receivership Estate dated December 16, 2020 [ECF No. 436]

(“Expansion Order”), through which several entities and properties were included in the 

Receivership Estate as additional Receivership Entities, was appealed to the United States Court 

of Appeals for the Eleventh Circuit. Following oral argument before the Eleventh Circuit in Miami 

on June 7, 2022, the Eleventh Circuit issued an order dismissing the appeal for lack of jurisdiction. 

One of the entities subject to the Expansion Order was Capital Source 2000, a company 

owned by William Bromley and Defendant Joseph Cole Barleta. The Securities and Exchange 

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Commission has informed the Receiver that it does not intend to seek to collect against Defendant 

Barleta’s interest in Capital Source 2000 to satisfy the disgorgement judgment entered against him, 

and has requested the Receiver to return control of Capital Source 2000 to Mr. Bromley and 

Defendant Barleta. The Receiver has provided Mr. Bromley and Defendant Barleta with certain 

information they have requested related to this entity, and anticipates submitting an Agreed Order 

to the Court for approval of this transfer.

VI. Website / Communications with Interested Parties

The Receiver continues to receive many e-mails, telephone calls, and other inquiries from 

investors, merchants, administrators of agent funds, and other interested parties. The Receiver and 

his professionals have returned phone calls and emails from thousands of investors, merchants, 

and others. Since the Receiver established the receivership website on August 16, 2020, which is 

available at parfundingreceivership.com, there have been more than 129,979 visitors and 604,380 

pageviews to the website. The Receiver will continue to update this website with key court filings, 

news and updates, reports from the Receiver, answers to frequently asked questions, important 

dates and deadlines (including Zoom or telephone dial-in information for status conferences and 

other significant hearings before the Court), and other pertinent information. Additionally, the 

Receiver will utilize this website to provide notice to investors and other claimants regarding the 

claims and distribution process in this matter, once that information is available.

VII. Conclusion

WHEREFORE, Ryan K. Stumphauzer, as Court-Appointed Receiver, by and through his 

undersigned counsel, respectfully files this Quarterly Status Report dated October 31, 2022. 

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Dated: October 31, 2022 Respectfully Submitted, 

STUMPHAUZER FOSLID SLOMAN

ROSS & KOLAYA, PLLC

Two South Biscayne Blvd., Suite 1600 

Miami, FL 33131 

Telephone: (305) 614-1400 

By: /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

Florida Bar No. 056140 

tkolaya@sfslaw.com 

Co-Counsel for Receiver 

PIETRAGALLO GORDON ALFANO 

BOSICK & RASPANTI, LLP

1818 Market Street, Suite 3402 

Philadelphia, PA 19103 

Telephone: (215) 320-6200 

By: /s/ Gaetan J. Alfano 

GAETAN J. ALFANO 

Pennsylvania Bar No. 32971 

(Admitted Pro Hac Vice)

GJA@Pietragallo.com

DOUGLAS K. ROSENBLUM

Pennsylvania Bar No. 90989 

(Admitted Pro Hac Vice)

DKR@Pietragallo.com

Co-Counsel for Receiver 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on October 31, 2022, I electronically filed the foregoing 

document with the clerk of the Court using CM/ECF. I also certify that the foregoing document is 

being served this day on counsel of record via transmission of Notices of Electronic Filing 

generated by CM/ECF. 

 /s/ Timothy A. Kolaya 

TIMOTHY A. KOLAYA

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