4886-7781-6750 

Jason S. Brookner (TX Bar No. 24033684) 

Aaron M. Kaufman (TX Bar No. 24060067) 

Lydia R. Webb (TX Bar No. 24083758) 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, TX 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: jbrookner@grayreed.com 

akaufman@grayreed.com 

lwebb@grayreed.com 

Proposed Counsel to the Debtors 

and Debtors in Possession 

 

 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

 

 § 

In re: § Chapter 11 

 § 

COTTONWOOD FINANCIAL LTD., et al.,

1

 § Case No. 24-80035 (SWE) 

 § 

 Debtors. § (Jointly Administered) 

 § 

GLOBAL NOTES AND STATEMENT OF LIMITATIONS, METHODOLOGIES, 

AND DISCLAIMERS REGARDING THE DEBTORS’ SCHEDULES 

OF ASSETS AND LIABILITIES AND STATEMENTS OF FINANCIAL AFFAIRS 

The above-captioned debtors and debtors in possession (collectively, the “Debtors”) hereby 

file their Schedules of Assets and Liabilities (collectively with attachments, the “Schedules”) and 

Statements of Financial Affairs (collectively with attachments, the “Statements,” and together with 

the Schedules, the “Schedules and Statements”). The Schedules and Statements were prepared 

pursuant to section 521 of title 11 of the United States Code (the “Bankruptcy Code”), rule 1007 

of the Federal Rules of Bankruptcy Procedure, and rule 1007-1 of the Local Bankruptcy Rules of 

the United States Bankruptcy Court for the Northern District of Texas by the Debtors with the 

assistance of their advisors and are unaudited. 

These Global Notes and Statement of Limitations, Methodologies, and Disclaimers 

Regarding the Debtors’ Schedules of Assets and Liabilities and Statements of Financial Affairs

1

 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ federal tax identification number are 

as follows: Cottonwood Financial Ltd. (1001); Cottonwood Financial Administrative Services, LLC (7228); 

Cottonwood Financial Texas, LLC (9059); Cottonwood Financial Idaho, LLC (“Cottonwood Idaho”) (5651); 

Cottonwood Financial Wisconsin, LLC (“Cottonwood Wisconsin”) (7075). The Debtors’ principal offices are located 

at 2100 W Walnut Hill Lane, Suite 300, Irving, TX 75038. 

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4886-7781-6750 

(the “Global Notes”) pertain to, are incorporated by reference in, and constitute an integral part of 

the Schedules and Statements. These Global Notes should be referred to, considered, and reviewed 

in connection with any review of the Schedules and Statements. To the extent that the Schedules 

and Statements conflict with these Global Notes, these Global Notes shall control. 

The Debtors and their professionals do not and cannot guarantee or warrant the accuracy 

or completeness of the data that is provided herein and shall not be liable for any loss or injury 

arising out of, or caused in whole or in part by, the acts, errors, or omissions in procuring, 

compiling, collecting, interpreting, reporting, communicating, or delivering the information 

contained herein. While diligent and reasonable efforts have been made to provide accurate and 

complete information in the Schedules and Statements, inadvertent errors or omissions may exist. 

In no event shall the Debtors or their professionals be liable to any third party for any direct, 

indirect, incidental, consequential, or special damages (including, but not limited to, damages 

arising from the disallowance of a potential claim against the Debtors or damages to business 

reputation, lost business, or lost profits), whether foreseeable or not and however caused, even if 

the Debtors or their professionals are advised of the possibility of such damages. 

These Global Notes are in addition to any specific notes contained in each Debtor’s 

respective Schedules or Statements. Disclosure of information in one or more Schedules or 

Statements, or one or more exhibits or attachments to the Schedules or Statements, even if 

incorrectly placed, shall be deemed to be disclosed in the correct Schedules, Statements, exhibits, 

or attachments. 

Global Notes and Overview of Methodology 

1. “As Of” Information Date. On February 25, 2024 (the “Petition Date”), each Debtor filed 

a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtors are 

operating as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy 

Code. 

To the best of the Debtors’ knowledge, the information provided herein represents the asset 

and liability data of the Debtors as of the Petition Date, except as otherwise noted. 

Amounts ultimately realized may vary from net book value (or the applicable value 

ascribed herein) and such variance may be material. Accordingly, the Debtors reserve all 

rights to amend or adjust the value of each asset set forth herein. In addition, the amounts 

shown for total liabilities exclude items identified as “unknown,” “disputed,” “contingent,” 

“unliquidated,” or “undetermined,” and thus, ultimate liabilities may differ materially from 

those stated in the Schedules and Statements. 

2. Reservations and Limitations. Diligent and reasonable efforts have been made to prepare 

and file complete and accurate Schedules and Statements; however, as noted above, 

inadvertent errors or omissions may exist. The Debtors reserve all rights to: (a) amend 

and/or supplement the Schedules and Statements from time to time, in all respects, as may 

be necessary or appropriate, including, without limitation, amending the Schedules and 

Statements with respect to the description or designation of any claim (each, a “Claim”); 

(b) dispute or otherwise assert offsets or defenses to any Claim reflected in the Schedules 

and Statements as to amount, liability, priority, status, or classification; (c) subsequently 

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4886-7781-6750 

designate any Claim as “disputed,” “contingent,” or “unliquidated;” or (d) object to the 

extent, validity, enforceability, or priority of any Claim (regardless of whether such Claim 

is designated in the Schedules and Statement as “disputed,” “contingent,” or 

“unliquidated”). 

Notwithstanding the Debtors’ diligent and reasonable efforts to properly characterize, 

classify, categorize, or designate certain Claims, assets, executory contracts, unexpired 

leases, and other items reported in the Schedules and Statements, the Debtors may 

nevertheless have inadvertently improperly characterized, classified, categorized, 

designated, or omitted certain items. Accordingly, the Debtors reserve their rights to 

recharacterize, reclassify, recategorize, redesignate, add, or delete items reported in the 

Schedules and Statements at a later time as is necessary or appropriate as additional 

information becomes available, including, without limitation, whether contracts or leases 

listed herein were deemed executory or unexpired as of the Petition Date and remain 

executory and unexpired postpetition. 

Furthermore, nothing contained in the Schedules and Statements constitutes a waiver of 

any of the Debtors’ rights or an admission of any kind with respect to these chapter 11 

cases, including any rights or Claims of the Debtors against any third party or issues 

involving Claims, substantive consolidation, equitable subordination, recharacterization, 

or defenses and/or causes of action arising under the provisions of chapter 5 of the 

Bankruptcy Code and any other relevant applicable bankruptcy or non-bankruptcy laws to 

recover assets or avoid transfers. 

Any specific reservation of rights contained elsewhere in the Global Notes does not limit 

in any respect the general reservation of rights contained in the above paragraphs, nor shall 

it otherwise infringe upon the Debtors’ rights to amend their Schedules and Statements at 

any time before these chapter 11 cases are closed, pursuant to Bankruptcy Rule 1009. 

3. Claims Description. Schedules D and E/F permit the Debtors to designate a Claim as 

“disputed,” “contingent,” and/or “unliquidated.” 

A claim that is dependent on the realization of some uncertain future event is a 

“contingent” claim. 

A claim, or portion of a claim, for which a specific value could not be readily 

quantified by the Debtor using currently available information is scheduled as 

“unliquidated.” 

A claim with respect to which the applicable Debtor and the claimant disagree as 

to the amount owed, whether any amount is owed, or the claim classification, is 

“disputed.” 

Any failure to designate a Claim in the Schedules and Statements as “disputed,” 

“contingent,” or “unliquidated” does not constitute an admission by the Debtors that such 

Claim or amount is not “disputed,” “contingent,” or “unliquidated,” or that such Claim is 

not subject to objection. The Debtors reserve all rights to dispute, or assert offsets or 

defenses to, any Claim reflected on their Schedules and Statements on any grounds, 

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4886-7781-6750 

including, but not limited to, amount, liability, priority, status, or classification. 

Additionally, the Debtors expressly reserve all rights to designate such Claims as 

“disputed,” “contingent,” or “unliquidated” at a later date. Moreover, listing a Claim does 

not constitute an admission of liability by the Debtors. The Debtors reserve all rights to 

amend the Schedules and Statement as necessary and appropriate, including, but not 

limited to, with respect to Claim description and designation. 

4. Basis of Presentation. Information contained in the Schedules and Statements has been 

derived from the information provided by the Debtors’ management. The Schedules and 

Statements have not been subject to procedures that would typically be applied to financial 

statements prepared in accordance with Generally Accepted Accounting Principles 

(“GAAP”) and are not intended to reconcile fully with any financial statements prepared 

under GAAP. Therefore, combining the assets and liabilities set forth in the Schedules and 

Statements would result in amounts that are substantially different from financial 

information that would otherwise be prepared under GAAP. To the extent that a Debtor 

shows more assets than liabilities, this is not an admission that the Debtor was solvent as 

of the Petition Date or at any time before the Petition Date. Likewise, to the extent a Debtor 

shows more liabilities than assets, this is not an admission that the Debtor was insolvent at 

the Petition Date or any time before the Petition Date. For the avoidance of doubt, nothing 

contained in the Schedules and Statement is indicative of the Debtors’ enterprise value. 

5. Causes of Action. Despite making diligent and reasonable efforts to identify all known 

assets, the Debtors may not have identified or set forth all of their causes of action (filed 

or potential) against third parties as assets in their Schedules and Statements, including, 

without limitation, causes of action arising under the provisions of chapter 5 of the 

Bankruptcy Code and actions under other relevant bankruptcy and non-bankruptcy laws to 

recover assets or avoid transfers. The Debtors reserve all rights with respect to any causes 

of action (including avoidance actions), controversy, right of setoff, cross claim, 

counterclaim, or recoupment and any claim on contracts or for breaches of duties imposed 

by law or in equity, demand, right, action, lien, indemnity, guaranty, suit, obligation, 

liability, damage, judgment, account, defense, power, privilege, license, and franchise of 

any kind or character whatsoever, known, unknown, fixed or contingent, matured or 

unmatured, suspected or unsuspected, liquidated or unliquidated, disputed or undisputed, 

secured or unsecured, assertable directly or derivatively, whether arising before, on, or after 

the Petition Date, in contract or in tort, at law or in equity, or pursuant to any other theory 

(collectively, “Causes of Action”) they may have, and neither these Global Notes nor the 

Schedules and Statements shall be deemed a waiver of any claims or Causes of Action or 

in any way prejudice or impair the assertion of such claims or Causes of Action by the 

Debtors. 

6. Book Value. Except as otherwise indicated, the Debtors, have made a good faith effort to 

list assets and liabilities based on book values as of the latest close of books and records 

or, where possible, through the Petition Date. The book values of certain assets may 

materially differ from their fair market values. Certain assets that have been fully 

depreciated or that were expensed for accounting purposes either may not appear in the 

Schedules and Statements or are listed with a zero-dollar value, as such assets have no net 

book value. The omission of an asset from the Schedules and Statements does not 

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4886-7781-6750 

constitute a representation regarding the ownership of such asset, and any such omission 

does not constitute a waiver of any of the Debtors’ rights with respect to such asset. 

7. Classifications. Listing (a) a claim on Schedule D as “secured,” (b) a claim on Schedule 

E/F as “priority,” or (c) a claim on Schedule E/F as “unsecured,” or (d) a contract or lease 

on Schedule G as “executory” or “unexpired,” does not constitute an admission by the 

Debtors of the legal rights of the claimant or a waiver of the Debtors’ rights to recharacterize or reclassify such Claims, contracts, or leases or to setoff such Claims. 

8. Court Orders. Pursuant to certain orders of the Bankruptcy Court entered in these 

chapter 11 cases (the “First Day Orders”), the Debtors were authorized (but not directed) 

to pay, among other things, certain of the Debtors’ ordinary course operational costs and 

employee compensation. Accordingly, certain liabilities may have been or may be satisfied 

in accordance with such First Day Orders and therefore, generally are not listed in the 

Schedules and Statements. 

9. Liabilities. The Debtors have sought to allocate liabilities between the prepetition and 

postpetition periods based on the information and research that was conducted in 

connection with the preparation of the Schedules and Statements. As additional 

information becomes available and further research is conducted, the allocation of 

liabilities between prepetition and postpetition periods may change. 

10. Excluded Assets and Liabilities. The Debtors may have excluded immaterial or de minimis

assets and liabilities. 

11. Property Rights. Exclusion of certain property from the Schedules and Statements shall 

not be construed as an admission that such property rights have been abandoned, 

terminated, assigned, expired by terms, or otherwise transferred pursuant to a sale, 

acquisition, or other transaction. Conversely, inclusion of certain property shall not be 

construed to be an admission that such property rights have not been abandoned, have not 

been terminated, or otherwise expired by terms, or have not been assigned or otherwise 

transferred pursuant to a sale, acquisition, or other transaction. 

12. Insiders. In instances where the Schedules and Statements require information regarding 

“insiders,” the Debtors have included information with respect to the individuals or entities 

who the Debtors believe may be included in the definition of “insider” set forth in section 

101(31) of the Bankruptcy Code during the relevant time periods. 

The listing or omitting a party as an insider for purposes of the Schedules and Statements 

is for informational purposes only and is not intended to be, nor should it be, construed as 

an admission of the legal characterization of such party as an insider for purpose of section 

101(31) of the Bankruptcy Code. Moreover, the Debtors do not take any position with 

respect to: (a) any insider’s influence over the control of the Debtors; (b) the management 

responsibilities or functions of any such insider; (c) the decision making or corporate 

authority of any such insider; or (d) whether the Debtors or any such insider could 

successfully argue that they are not an “insider” or “affiliate” under applicable law or with 

respect to any theories of liability or for any other purpose 

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13. Estimates. To prepare and file the Schedules and Statements in accordance with the 

deadline established in these chapter 11 cases, the Debtors were required to make 

reasonable estimates and assumptions with respect to the reported amounts of assets and 

liabilities, the amount of contingent assets and contingent liabilities on the date of the 

Schedules and Statement, and the reported amounts of revenues and expenses during the 

applicable reporting periods. The Debtors reserve all rights to amend, supplement, or 

otherwise modify the reported amounts of assets and liabilities to reflect changes in those 

estimates or assumptions. 

14. Fiscal Year. Each Debtor’s fiscal year ends on December 31.

15. Currency. Unless otherwise indicated, all amounts are reflected in U.S. dollars. 

16. Executory Contracts and Unexpired Leases. Although the Debtors have made diligent 

attempts to properly identify executory contracts and unexpired leases, the inclusion of a 

contract or lease on Schedule G does not constitute an admission as to the executory or 

unexpired nature (or non-executory or expired nature) of any contract or lease, or an 

admission as to the existence or validity of any Claims held by any counterparty to any 

contract or lease. Furthermore, while the Debtors have made diligent attempts to properly 

identify all executory contracts and unexpired leases, inadvertent errors, omissions, or over 

inclusion may have occurred. 

Moreover, nothing in the Schedules and Statements is, or shall be construed to be, an 

admission as to the determination of the legal status of any lease or financing arrangement 

(including whether any lease or financing arrangement is a true lease, a financing 

arrangement, or a real property interest), and the Debtors reserve all rights with respect to 

such issues. 

17. Totals. All totals that are included in the Schedules and Statements represent totals of all 

known amounts. To the extent there are unknown, disputed, contingent, unliquidated, or 

otherwise Undetermined Amounts, the actual total may be different from the listed total. 

18. Unliquidated Claim Amounts. Claim amounts that could not be quantified by the Debtors 

are scheduled as “unliquidated.” 

19. Undetermined Amounts. The description of an amount as “unknown,” “disputed,” 

“contingent,” “unliquidated,” or “undetermined” is not intended to reflect upon the 

materiality of such amount. 

20. Liens. Property and equipment listed in the Schedules and Statements are presented 

without consideration of any liens that may attach (or have attached) to such property and 

equipment. 

21. Confidential Information. Pursuant to that certain Order (I) Authorizing the Debtors to 

Serve a Consolidated List of Creditors and a Consolidated List of the 30 Largest 

Unsecured Creditors, (II) Authorizing the Debtors to Redact Certain Personal 

Identification Information, (III) Approving the Form and Manner of Notifying Creditors of 

the Commencement of the Debtors’ Chapter 11 Cases, and (IV) Granting Related Relief 

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4886-7781-6750 

[Docket No. 70] (the “Creditor Matrix Order”), the Bankruptcy Court has authorized the 

Debtors to redact certain personally identifiable information, such as home addresses of 

individuals and the names and addresses of the Debtors’ customers. To the extent the 

Debtors believe a claim, name, address, or amount falls under the purview of the Creditor 

Matrix Order, such information is not included in the Schedules and Statements. The 

alterations or redactions, if any, are limited only to what the Debtors believe is warranted 

to comply with the Creditor Matrix Order. 

22. Setoffs. The Debtors may have incurred setoffs and net payments in the ordinary course 

of business. Such setoffs and nettings may have occurred due to a variety of transactions 

or disputes including, but not limited to, intercompany transactions, counterparty 

settlements, pricing discrepancies, rebates, returns, warranties, refunds, and negotiations 

and/or disputes between Debtors and their customers and/or vendors. Therefore, although 

such setoffs and other similar rights may have been accounted for when scheduling certain 

amounts, these ordinary course setoffs are not independently accounted for, and as such, 

are or may be excluded from the Schedules and Statements. In addition, some amounts 

listed in the Schedules and Statements may have been affected by setoffs or nettings by 

third parties of which the Debtors are not yet aware. The Debtors reserve all rights to 

challenge any setoff and/or recoupment rights that may be asserted. 

23. Cottonwood Financial Administrative Services, LLC. The Debtor Cottonwood Financial 

Administrative Services, LLC (“Cottonwood Financial”) is the contracting entity for the 

majority, if not all, of the contracts with the Debtors. To the extent a contract states that 

the party is “Cottonwood Financial,” the Debtors believe this refer to Cottonwood 

Financial Administrative Services, LLC. Additionally, although the Debtors’ employees 

are employees of a specific Debtor entity, the employee wages and benefits, including 401k 

plans are paid by and are administered through Cottonwood Financial. Cottonwood 

Financial also pays all or the majority of all of the Debtors’ respective business expenses. 

Specific Disclosures with Respect to the Debtors’ Schedules 

1. Schedule A/B, Question 2: For purposes of these Schedules, the Debtors have listed cash 

at the Debtors’ stores on a consolidated basis for security purposes. 

2. Schedule A/B, Question 7: The Debtors believe that all posted utility deposits have either 

been refunded or applied to the Debtors’ outstanding balances, and no deposits remain. 

The Debtors reserve all rights to amend the Schedules to the extent that any deposits are 

identified that have not been refunded or applied to balances. 

3. Schedule A/B, Question 8: Prepayments represent entries from the Debtors’ prepayment 

schedules and may not necessarily represent cash paid out as of the Petition Date. 

4. Schedule A/B, Questions 64 & 77: The Debtors have certain contractual rights under the 

Brokering and Servicing Agreement with TreeMac. Funding Group, LLC (“TreeMac”). 

The Debtor Cottonwood Financial Texas, LLC (“Cottonwood Texas”) operates as a Credit 

Services Organization (“CSO”) and a licensed Credit Access Business (“CAB”) under 

Texas law. Pursuant to a Brokering and Servicing Agreement with Cottonwood Texas, 

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4886-7781-6750 

TreeMac is the exclusive third-party lender for loans brokered by Cottonwood Texas to 

customers. Cottonwood Texas earns fees at the time a loan is originated, paid from a 

portion of the loan proceeds, and which are remitted to Cottonwood Texas pursuant to the 

settlement process with TreeMac in the ordinary course of business. Subsequent fees, 

including fees Cottonwood Texas earns for maintaining the letter of credit during the term 

of the loan, are paid to Cottonwood Texas directly by the customer. Cottonwood Texas’s 

revenue from fees for performing its services under the Brokering and Servicing 

Agreement is scheduled at Schedule A/B question 64. 

Further, if a customer defaults on its loan agreement with TreeMac, TreeMac demands 

payment from Cottonwood Texas under the terms of its individual letter of credit. Once 

the letter of credit is called, Cottonwood Texas pays TreeMac in full on the loan. 

Cottonwood Texas is then subrogated to the rights of TreeMac in the loan, and Cottonwood 

Texas seeks reimbursement from the borrower pursuant to the credit services agreement 

by and between Cottonwood Texas and the customer. Cottonwood Texas has scheduled 

this right of collection/reimbursement from the customer at Schedule A/B question 77. 

5. Schedule D: The Debtors made reasonable, good faith efforts to include all liens on 

Schedule D, but may have inadvertently omitted an existing lien because of, among other 

things, the possibility that a lien may have been imposed after Uniform Commercial Code 

searches were performed or a vendor may not have filed the requisite perfection 

documentation. Moreover, the Debtors have not included on Schedule D parties that may 

believe their claims are secured through setoff rights or inchoate statutory lien rights. 

6. Schedule E/F, Part 1: Creditors Holding Priority Unsecured Claims. The listing of any 

claim on Schedule E/F does not constitute an admission by the Debtors that such claim is 

entitled to priority treatment under section 507 of the Bankruptcy Code. The Debtors 

reserve all rights to dispute the amount and the priority status of any claim on any basis at 

any time. All claims listed on the Debtors’ Schedule E/F are claims arising from tax 

obligations for which the Debtors may potentially be liable, and which may be subject to 

ongoing audits or other proceedings. 

7. Schedule E/F, Part 2: Creditors Holding Non-Priority Unsecured Claims. The claims 

listed in Schedule E/F arose or were incurred on various dates. In certain instances, the 

date on which a claim arose is an open issue of fact. Determining the date upon which 

each claim in Schedule E/F was incurred or arose would be unduly burdensome and cost 

prohibitive and, therefore, the Debtors do not list a date for each claim listed on 

Schedule E/F. Vendors may have invoiced the Debtors prior to the filing for postpetition 

services (i.e., annual contracts). Liabilities related to such invoices have been prorated on 

Schedule E/F to solely reflect the asserted prepetition Claim.

8. Schedule G. Customer contracts included on Schedule G, if any, are redacted pursuant to 

the Creditor Matrix Order, which authorizes the Debtors to redact both customer names 

and addresses. 

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4886-7781-6750 

Specific Disclosures with Respect to the Debtors’ Statements 

1. Statement 3. Payments to the Debtors’ bankruptcy professionals for work related to the 

bankruptcy are not included in the payments to creditors and are instead included in 

Statement 11. 

2. Statements 4 & 30. Business Payments by the Debtors to or on behalf of their respective 

insiders for expense reimbursements, including credit card vendor payments, travel, meals 

and entertainment, are included in the amounts listed in Statement 4. 

Due to the nature of the Debtors’ business operations, and the sheer number of transfers 

between and among the Debtors on a daily basis, Statement 4 does not include 

intercompany transfers between or among Debtors. 

3. Statement 7: Information is listed, to the best of the Debtors’ knowledge and information, 

regarding current, threatened, or pending litigation involving a Debtor. The Debtors pursue 

collections against customers in the ordinary course of the Debtors’ business. Such 

collection matters have not been included in these Statements. 

4. Statement 13. In the ordinary course of business, the Debtors sell defaulted customer loans 

and/or the right to collect on such loans to third-party buyers. Statement 13 lists such 

transfers to the extent applicable to each Debtor entity. 

5. Statement 17. The Debtors’ 401k plan is administered under the Debtor Cottonwood 

Financial Administrative Services, LLC. 

6. Statement 21: Pursuant to the Brokering and Servicing Agreement by and between 

Cottonwood Texas and TreeMac Cottonwood Texas brokers and assists customers in 

obtaining loans from TreeMac. Cottonwood Texas also collects payments from such 

customers on behalf of TreeMac. Cottonwood Texas and TreeMac have established a 

settlement process whereby funds collected from customers by Cottonwood Texas on 

behalf of TreeMac are remitted to TreeMac several business days after receipt. Statement 

21 shows the amount collected and held by Cottonwood Texas as of the Petition Date from 

customers between February 22 and February 25, 2024. 

7. Statement 26d: In the ordinary course of business, the Debtors regularly provide financial 

information to regulators, state and federal agencies, and brokers to assist in obtaining and 

maintaining bonds to meet certain of the Debtors’ regulatory requirements. 

8. Statement 28. Cottonwood Financial Ltd. is the sole member of Cottonwood Financial, 

Cottonwood Texas, Cottonwood Wisconsin and Cottonwood Idaho. Cottonwood 

Financial Management, Inc. is the sole general partner of Cottonwood Financial Ltd. 

Trevor Ahlberg is President and CEO of Cottonwood Financial Management, Inc. 

9. Statement 31. The Debtors’ income and expenses are consolidated and tax returns for all 

Debtor entities are filed under Cottonwood Financial Ltd. 

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Official Form 207

Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy 04/22

The debtor must answer every question. If more space is needed, attach a separate sheet to this form. On the top of any additional pages, 

write the debtor’s name and case number (if known).

Check if this is an 

amended filing

 Fill in this information to identify the case:

Debtor

United States Bankruptcy Court for the:

Case number

 (if known)

24-80035

NORTHERN DISTRICT OF TEXAS

COTTONWOOD FINANCIAL LTD.

 ̈

 Part 1: Income

1. Gross revenue from business

þ None

2. Non-business revenue

Include revenue regardless of whether that revenue is taxable. Non-business income may include interest, dividends, money collected 

from lawsuits, and royalties. List each source and the gross revenue for each separately. Do not include revenue listed in line 1. 

þ None

 Part 2: List Certain Transfers Made Before Filing for Bankruptcy

3. Certain payments or transfers to creditors within 90 days before filing this case

List payments or transfers3⁄4including expense reimbursements3⁄4to any creditor, other than regular employee compensation, within 90 days 

before filing this case unless the aggregate value of all property transferred to that creditor is less than $7,575. (This amount may be adjusted 

on 4/1/25 and every 3 years after that with respect to cases filed on or after the date of adjustment.)

 ̈ None

Reasons for payment or transfer

Check all that apply

Creditor’s name and address Dates Total amount or value

BANK OF TEXAS

ATTN: CHRISTOPHER HOUSTON

600 PENN ST

FORT WORTH, TX 76102

12/14/2023 $5,511.53 FEES

01/16/2024 $5,911.84 FEES

02/14/2024 $4,599.05 FEES

TOTAL FOR BANK OF TEXAS $16,022.42

GRAND TOTAL: $16,022.42

4. Payments or other transfers of property made within 1 year before filing this case that benefited any insider 

List payments or transfers, including expense reimbursements, made within 1 year before filing this case on debts owed to an insider or 

guaranteed or cosigned by an insider unless the aggregate value of all property transferred to or for the benefit of the insider is less than 

$7,575. (This amount may be adjusted on 4/1/25 and every 3 years after that with respect to cases filed on or after the date of adjustment.) Do 

not include any payments listed in line 3. Insiders include officers, directors, and anyone in control of a corporate debtor and their relatives; 

general partners of a partnership debtor and their relatives; affiliates of the debtor and insiders of such affiliates ; and any managing agent of 

the debtor. 11 U.S.C. § 101(31).

þ None

5. Repossessions, foreclosures, and returns 

List all property of the debtor that was obtained by a creditor within 1 year before filing this case, including property repossessed by a creditor, 

sold at a foreclosure sale, transferred by a deed in lieu of foreclosure, or returned to the seller. Do not include property listed in line 6. 

þ None

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 1 of 8

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Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

6. Setoffs

List any creditor, including a bank or financial institution, that within 90 days before filing this case set off or otherwise took anything from an 

account of the debtor without permission or refused to make a payment at the debtor’s direction from an account of the debtor because the 

debtor owed a debt.

þ None

 Part 3: Legal Actions or Assignments

7. Legal actions, administrative proceedings, court actions, executions, attachments, or governmental audits

List the legal actions, proceedings, investigations, arbitrations, mediations, and audits by federal or state agencies in which the debtor was 

involved in any capacity-within 1 year before filing this case.

 ̈ None

Case title Nature of case Court or agency’s name and address Status of case

LATASHA WILSON V. CONSUMER

COTTONWOOD FINANCIAL LTD.

Case number

19-SC-49193

 ̈ Pending

 ̈ On appeal

þ Concluded

WISCONSIN MILWAUKEE COUNTY 

CIRCUIT COURT

THOMAS ALSTON V. CONSUMER

COTTONWOOD FINANCIAL LTD.

Case number

1:23-CV-00571

 ̈ Pending

 ̈ On appeal

þ Concluded

US DISTRICT COURT OF COLUMBIA

WENDY MASON V. CONSUMER

COTTONWOOD FINANCIAL LTD.

Case number

2022CV000278

 ̈ Pending

 ̈ On appeal

þ Concluded

WISCONSIN WAUPACA COUNTY 

CIRCUIT COURT

8. Assignments and receivership

List any property in the hands of an assignee for the benefit of creditors during the 120 days before filing this case and any property in the 

hands of a receiver, custodian, or other court-appointed officer within 1 year before filing this case. 

þ None

 Part 4: Certain Gifts and Charitable Contributions

9. List all gifts or charitable contributions the debtor gave to a recipient within 2 years before filing this case unless the aggregate 

value of the gifts to that recipient is less than $1,000

þ None

 Part 5: Certain Losses

10. All losses from fire, theft, or other casualty within 1 year before filing this case. 

þ None

 Part 6: Certain Payments or Transfers

11. Payments related to bankruptcy

List any payments of money or other transfers of property made by the debtor or person acting on behalf of the debtor within 1 year before the 

filing of this case to another person or entity, including attorneys, that the debtor consulted about debt consolidation or restructuring, seeking 

bankruptcy relief, or filing a bankruptcy case.

þ None

12. Self-settled trusts of which the debtor is a beneficiary 

List any payments or transfers of property made by the debtor or a person acting on behalf of the debtor within 10 years before the filing of this 

case to a self-settled trust or similar device. 

Do not include transfers already listed on this statement.

þ None

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 2 of 8

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Main Document Page 11 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

13. Transfers not already listed on this statement

List any transfers of money or other property3⁄4by sale, trade, or any other means3⁄4made by the debtor or a person acting on behalf of the 

debtor within 2 years before the filing of this case to another person, other than property transferred in the ordinary course of business or 

financial affairs.

Include both outright transfers and transfers made as security. Do not include gifts or transfers previously listed on this statement.

þ None

 Part 7: Previous Locations

14. Previous addresses

List all previous addresses used by the debtor within 3 years before filing this case and the dates the addresses were used. 

 ̈ Does not apply

Address Dates of occupancy

1901 GATEWAY DRIVE, SUITE 200

IRVING, TX 75038

From 8/1/2018 To 11/30/2021

 Part 8: Health Care Bankruptcies

15. Health Care bankruptcies

Is the debtor primarily engaged in offering services and facilities for :

3⁄4 diagnosing or treating injury, deformity, or disease, or 

3⁄4 providing any surgical, psychiatric, drug treatment, or obstetric care?

þ No. Go to Part 9.

 Part 9: Personal Identifiable Information

16. Does the debtor collect and retain personally identifiable information of customers?

 ̈ No.

þ Yes. State the nature of the information collected and retained. NAME, ADDRESS, INCOME, FINANCIAL HISTORY, SSN, AND 

OTHER INFORMATION TYPICALLY COLLECTED FOR CREDIT 

CHECK.

Does the debtor have a privacy policy about that information? 

 ̈ No

þ Yes

17. Within 6 years before filing this case, have any employees of the debtor been participants in any ERISA, 401(k), 403(b), or other 

pension or profit-sharing plan made available by the debtor as an employee benefit?

þ No. Go to Part 10.

 ̈ Yes. Does the debtor serve as plan administrator?

 Part 10: Certain Financial Accounts, Safe Deposit Boxes, and Storage Units

18. Closed financial accounts

Within 1 year before filing this case, were any financial accounts or instruments held in the debtor’s name , or for the debtor’s benefit, closed, 

sold, moved, or transferred? 

Include checking, savings, money market, or other financial accounts; certificates of deposit; and shares in banks, credit unions, brokerage 

houses, cooperatives, associations, and other financial institutions.

þ None

19. Safe deposit boxes

List any safe deposit box or other depository for securities, cash, or other valuables the debtor now has or did have within 1 year before filing 

this case.

þ None

20. Off-premises storage

List any property kept in storage units or warehouses within 1 year before filing this case. Do not include facilities that are in a part of a building 

in which the debtor does business.

þ None

 Part 11: Property the Debtor Holds or Controls That the Debtor Does Not Own

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 3 of 8

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Main Document Page 12 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

21. Property held for another

List any property that the debtor holds or controls that another entity owns. Include any property borrowed from, being stored for, or held in 

trust. Do not list leased or rented property.

þ None

 Part 12: Details About Environmental Information

For the purpose of Part 12, the following definitions apply:

n Environmental law means any statute or governmental regulation that concerns pollution, contamination, or hazardous material, 

regardless of the medium affected (air, land, water, or any other medium).

n Site means any location, facility, or property, including disposal sites, that the debtor now owns, operates, or utilizes or that the 

debtor formerly owned, operated, or utilized. 

n Hazardous material means anything that an environmental law defines as hazardous or toxic, or describes as a pollutant, 

contaminant, or a similarly harmful substance.

Report all notices, releases, and proceedings known, regardless of when they occurred.

22. Has the debtor been a party in any judicial or administrative proceeding under any environmental law? Include settlements and orders.

þ No

 ̈ Yes. Provide details below.

23. Has any governmental unit otherwise notified the debtor that the debtor may be liable or potentially liable under or in violation of an 

environmental law?

þ No

 ̈ Yes. Provide details below.

24. Has the debtor notified any governmental unit of any release of hazardous material?

þ No

 ̈ Yes. Provide details below.

 Part 13: Details About the Debtor’s Business or Connections to Any Business

25. Other businesses in which the debtor has or has had an interest

List any business for which the debtor was an owner, partner, member, or otherwise a person in control within 6 years before filing this case.

Include this information even if already listed in the Schedules.

 ̈ None

Employer Identification number 

Do not include Social Security number or ITIN.

Business name and address Describe the nature of the business

COTTONWOOD FINANCIAL 

ADMINSTRATIVE SERVICES, LTD.

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 75-3069055

From: 5/15/2002 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

ARIZONA, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3252357

From: 8/8/2005 To: 07/20/2023

Date business existed

COTTONWOOD FINANCIAL 

AUSTIN CSO

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 84-3184008

From: 9/23/2019 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

COLORADO, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3252478

From: 8/8/2005 To: 08/02/2023

Date business existed

COTTONWOOD FINANCIAL 

EXECUTIVE, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 85-2474847

From: 11/20/2012 To: PRESENT

Date business existed

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 4 of 8

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Main Document Page 13 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

Employer Identification number 

Do not include Social Security number or ITIN.

Business name and address Describe the nature of the business

COTTONWOOD FINANCIAL 

IDAHO, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 33-1045651

From: 2/14/2003 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

ILLINOIS, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3545375

From: 9/28/2005 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

INVESTMENTS, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 26-1696654

From: 12/27/2007 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

KANSAS, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3252556

From: 8/8/2005 To: 08/02/2023

Date business existed

COTTONWOOD FINANCIAL 

MICHIGAN, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 27-0057219

From: 4/30/2003 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

MISSOURI, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3536474

From: 9/22/2005 To: 07/20/2023

Date business existed

COTTONWOOD FINANCIAL NEW 

MEXICO, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 27-0057220

From: 4/30/2003 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL OHIO, 

LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3200095

From: 7/20/2005 To: 07/20/2023

Date business existed

COTTONWOOD FINANCIAL 

TEXAS, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 75-3069059

From: 5/14/2002 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL UTAH, 

LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 26-1366280

From: 11/2/2007 To: PRESENT

Date business existed

COTTONWOOD FINANCIAL 

VIRGINIA, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 20-3200349

From: 7/20/2005 To: 08/02/2023

Date business existed

COTTONWOOD FINANCIAL 

WASHINGTON, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 26-1366803

From: 11/2/2007 To: 05/02/2011

Date business existed

COTTONWOOD FINANCIAL 

WISCONSIN, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 26-1367075

From: 11/2/2007 To: PRESENT

Date business existed

WINDSOR CAPITAL TEXAS, LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 47-2268566

From: 11/5/2014 To: 11/22/2022

Date business existed

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 5 of 8

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Main Document Page 14 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

Employer Identification number 

Do not include Social Security number or ITIN.

Business name and address Describe the nature of the business

WINDSOR CAPITAL WISCONSIN, 

LLC

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

CONSUMER FINANCE 45-1074461

From: 7/19/2011 To: 11/22/2022

Date business existed

26. Books, records, and financial statements

26a. List all accountants and bookkeepers who maintained the debtor’s books and records within 2 years before filing this case. 

 ̈ None

Name and address Dates of service

ADAM ACKERMANN

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

From JANUARY 2023 To PRESENT

JEREMY JAMES

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

From 4/7/2021 To 6/24/2022

List all firms or individuals who have audited, compiled, or reviewed debtor’s books of account and records or prepared a financial 

statement within 2 years before filing this case. 

 ̈ None

26b.

Name and address Dates of service

ARMANINO LLP

15950 N DALLAS PKWY #600

DALLAS, TX 75248

From JANUARY 2013 To PRESENT

List all firms or individuals who were in possession of the debtor’s books of account and records when this case is filed .

 ̈ None

26c.

If any books of account and records are 

unavailable, explain why

Name and address

ADAM ACKERMANN

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

List all financial institutions, creditors, and other parties, including mercantile and trade agencies, to whom the debtor issued a financial 

statement within 2 years before filing this case. 

 ̈ None

26d.

Name and address

SEE GLOBAL NOTE

27. Inventories

Have any inventories of the debtor’s property been taken within 2 years before filing this case?

þ None

28. List the debtor’s officers, directors, managing members, general partners, members in control, controlling shareholders, or other 

people in control of the debtor at the time of the filing of this case.

 ̈ None

Position and nature of any % of interest, if any

interest

Name Address

2100 W. WALNUT HILL LN

SUITE 300

IRVING, TX 75038

COTTONWOOD FINANCIAL 

MANAGEMENT INC.

GENERAL PARTNER 1.0%

29. Within 1 year before the filing of this case, did the debtor have officers, directors, managing members, general partners, members in 

control of the debtor, or shareholders in control of the debtor who no longer hold these positions?

þ None

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 6 of 8

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Main Document Page 15 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

30. Payments, distributions, or withdrawals credited or given to insiders 

Within 1 year before filing this case, did the debtor provide an insider with value in any form, including salary, other compensation, draws, 

bonuses, loans, credits on loans, stock redemptions, and options exercised? 

þ None

31. Within 6 years before filing this case, has the debtor been a member of any consolidated group for tax purposes? 

 ̈ None

Employer identification number of the parent 

corporation. 

Name of the parent corporation

COTTONWOOD FINANCIAL LTD 75-2671001

32. Within 6 years before filing this case, has the debtor as an employer been responsible for contributing to a pension fund?

þ None

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 7 of 8

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Main Document Page 16 of 17
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

 Part 14: Signature and Declaration

WARNING -- Bankruptcy fraud is a serious crime. Making a false statement, concealing property, or obtaining money or property 

by fraud in connection with a bankruptcy case can result in fines up to $500,000 or imprisonment for up to 20 years, or both. 

18 U.S.C. §§ 152, 1341, 1519, and 3571.

I have examined the information in this Statement of Financial Affairs and any attachments and have a reasonable belief that the 

information is true and correct.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 03/29/2024.

û /s/ KAREN G. NICOLAOU KAREN G. NICOLAOU

Signature of individual signing on behalf of the debtor Printed Name

 CHIEF RESTRUCTURING OFFICER

Position or relationship to debtor 

Are additional pages to Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy (Official Form 207) attached?

þ No

 ̈ Yes

Official Form 207 Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy Page 8 of 8

Case 24-80035-swe11 Doc 184 Filed 03/29/24 Entered 03/29/24 15:53:25 Desc

Main Document Page 17 of 17