EXHIBIT A 

Certification of Sean A. Gumbs

Case:17-03283-LTS Doc#:23803-1 Filed:03/15/23 Entered:03/15/23 08:21:22 Desc:

Exhibit A Page 1 of 5
IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, 

et al.

Debtors.9

PROMESA 

Title III 

No. 17 BK 3283-LTS 

(Jointly Administered) 

VERIFIED CERTIFICATION OF SEAN A. GUMBS IN SUPPORT OF 

THE SEVENTEENTH INTERIM APPLICATION OF FTI CONSULTING, 

INC. FOR ALLOWANCE OF COMPENSATION FOR SERVICES 

RENDERED AND REIMBURSEMENT OF EXPENSES INCURRED AS 

FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF RETIRED 

EMPLOYEES OF THE COMMONWEALTH OF PUERTO RICO 

FROM OCTOBER 1, 2022 THROUGH JANUARY 31, 2023 

I, Sean A. Gumbs, have the responsibility for ensuring that the Application complies with 

the UST Guidelines, and I hereby certify the following: 

1. I am a Senior Managing Director with FTI Consulting, Inc., together with its 

wholly-owned subsidiaries (“FTI”), an international consulting firm. 

9

 The Debtors in these jointly-administered PROMESA title III cases, along with each Debtor’s respective 

title III case number listed as a bankruptcy case number due to software limitations and the last four (4) 

digits of each Debtor’s federal tax identification number, as applicable, are: (i) Commonwealth of Puerto 

Rico (Bankruptcy Case No. 17 BK 3283-LTS) (Last Four Digits of Federal Tax ID: 3481); (ii) Puerto Rico 

Sales Tax Financing Corporation (Bankruptcy Case No. 17 BK 3284) (Last Four Digits of Federal Tax ID: 

8474); (iii) Puerto Rico Highways and Transportation Authority (Bankruptcy Case No. 17 BK 3567-LTS) 

(Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the Government of the 

Commonwealth of Puerto Rico (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax 

ID: 9686); (v) Puerto Rico Electric and Power Authority (Bankruptcy Case No. 17 BK 4780) (Last Four 

Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (Bankruptcy Case No. 19 

BK 5523-LTS) (Last Four Digits of Federal Tax ID: 3801). 

Case:17-03283-LTS Doc#:23803-1 Filed:03/15/23 Entered:03/15/23 08:21:22 Desc:

Exhibit A Page 2 of 5
2 

2. I, along with Steven Simms, lead professionals from FTI representing the Retiree 

Committee in connection with the above-captioned Title III Cases. I am authorized to submit this 

certification in support of the Seventeenth Application of FTI Consulting, Inc. for Allowance of 

Compensation for Services Rendered and Reimbursement of Expenses Incurred as Financial 

Advisor to The Official Committee of Retired Employees of the Commonwealth of Puerto Rico 

From October 1, 2022 through January 31, 2023 (the “Application”). Except as otherwise noted, 

I have personal knowledge of the matters set forth herein. 

3. I have read the Application. The statements contained in the Application are true 

and correct according to the best of my knowledge, information, and belief. 

4. To the best of my knowledge, information, and belief, formed after reasonable 

inquiry, the fees and disbursements sought in the Application are permissible under PROMESA, 

the Federal Rules of Bankruptcy Procedure, the Puerto Rico Oversight, Management, and 

Economic Stability Act (“PROMESA”), 48 U.S.C. §§ 2101–2241; the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”); the Bankruptcy Rules for the United States 

Bankruptcy Court for the District of Puerto Rico (the “Local Rules”); the Court’s Order 

Authorizing the Employment of FTI Consulting, Inc. as Financial Advisor for the Committee of 

Retired Employees [Dkt. No. 1413]; the Court’s First Amended Order Setting Procedures for 

Interim Compensation and Reimbursement of Expenses of Professionals [Dkt. No. 1715]; the 

Court’s Second Amended Order Setting Procedures for Interim Compensation and Reimbursement 

of Expenses of Professionals [Dkt. No. 3269]; the United States Trustee’s Guidelines for 

Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. 

§ 330 by Attorneys in Large Chapter 11 Cases Effective as of November 1, 2013; the Court’s Order 

on Fee Examiner’s Motion to Impose Presumptive Standards and Timeliness requirements for 

Case:17-03283-LTS Doc#:23803-1 Filed:03/15/23 Entered:03/15/23 08:21:22 Desc:

Exhibit A Page 3 of 5
3 

Professional Fee Applications [Dkt. No. 3932]; and the Court’s Order Imposing Additional 

Presumptive Standards: Rate Increases and the Retention of Expert Witnesses or Other Subretained Professionals [Dkt. No. 7678]. 

5. The fees and disbursements sought in the Application are billed at rates FTI 

customarily employs and FTI clients generally accept in matters of this nature. 

6. None of the professionals seeking compensation varied their hourly rate based on 

their geographic location. 

7. FTI is not seeking compensation for this Interim Period for routine billing activities 

that typically are not compensable outside of bankruptcy. 

8. FTI does not make a profit on costs or expenses for which it seeks reimbursement, 

whether the service is performed by FTI in-house or through a third party. 

9. In accordance with Rule 2016(a) of the Bankruptcy Rules and 11 U.S.C. § 504, no 

agreement or understanding exists between FTI and any other person for the sharing of 

compensation to be received in connection with the Title III Cases except as authorized by 

PROMESA, the Bankruptcy Rules, and the Local Rules. 

10. All services for which compensation is sought were professional services rendered 

to the Retiree Committee and not on behalf of any other person. 

11. The Retiree Committee was provided with a copy of the Application before it was 

filed with the Court and does not object to the relief requested therein. 

12. In accordance with the Order Imposing Additional Presumptive Standards: Rate 

Increases and the Retentions of Expert Witnesses or Other Sub-Retained Professionals, I certify 

that the Retiree Committee authorized the rate increase, both with respect to effective date and 

specific amount, on a timekeeper-by-timekeeper basis. 

Case:17-03283-LTS Doc#:23803-1 Filed:03/15/23 Entered:03/15/23 08:21:22 Desc:

Exhibit A Page 4 of 5
4 

13. FTI’s 2022 and 2023 hourly rate schedules for non-owner timekeepers are as 

follows: 

14. On an annual basis, each FTI practice evaluates the hourly rates charged by its 

billing professionals to determine whether those rates should be increased based on a timekeeper’s 

developing skill, experience, professional advancement and academic or professional level of 

certification. FTI’s hourly rate increases are consistent with changes in market hourly rates. The 

2023 rates charged by the billing professionals working on these Title III cases were set through 

this process, and are consistent, both in amount and timing, with rates for FTI timekeepers not 

working on these Title III cases. 

I certify under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge, information, and belief formed after reasonable inquiry. 

Executed on March 15, 2023 

/s/ Sean A. Gumbs 

Sean A. Gumbs

STANDARD RATE ($) STANDARD RATE ($)

2022 2023

TITLE

Corporate Finance/

Restructuring

Corporate Finance/

Restructuring

Managing Director $910 - 960 $985 - 1,055

Senior Director 875 - 900 925 - 975

Director 780 - 865 835 - 925

Senior Consultant 595 - 695 635 - 750

Consultant 440 - 530 475 - 570

Project Manager / Assistant 300 305 - 325

Case:17-03283-LTS Doc#:23803-1 Filed:03/15/23 Entered:03/15/23 08:21:22 Desc:

Exhibit A Page 5 of 5