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. 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 1 of 24
 2 

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 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 2 of 24
 3 

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, 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 3 of 24
 4 

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 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 4 of 24
 5 

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 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 5 of 24
 6 

4886-7781-6750 

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 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 6 of 24
 7 

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, 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 7 of 24
 8 

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. 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 8 of 24
 9 

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. 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 9 of 24
Official Form 206Sum

Summary of Assets and Liabilities for Non-Individuals 12/15

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: Summary of Assets

1.

1a.

Total personal property:

Total of all property:

Copy line 88 from Schedule A/B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Real property:

Schedule A/B: Assets-Real and Personal Property (Official Form 206A/B)

1b.

1c.

Copy line 91A from Schedule A/B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Copy line 92 from Schedule A/B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

NOT APPLICABLE

$24,495.88

$24,495.88

 Part 2: Summary of Liabilities

2. Schedule D: Creditors Who Have Claims Secured by Property (Official Form 206D)

Copy the total dollar amount listed in Column A, Amount of claim, from line 3 of Schedule D . . . . . . . . .

3.

3a.

Total amount of claims of nonpriority amount of unsecured claims:

Copy the total claims from Part 1 from line 5a of Schedule E/F . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Total claim amounts of priority unsecured claims:

Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 206EF)

3b.

Copy the total of the amount of claims from Part 2 from line 5b of Schedule E/F . . . . . . . . . . . . . .

4. Total liabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

Lines 2 + 3a + 3b

+

$26,743,881.44

NOT APPLICABLE

$38,162,528.33

$64,906,409.77

Official Form 206Sum Page 1 of 1

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 10 of 24
Official Form 206A/B

Schedule A/B: Assets - Real and Personal Property 12/15

Disclose all property, real and personal, which the debtor owns or in which the debtor has any other legal, equitable, or future interest. Include 

all property in which the debtor holds rights and powers exercisable for the debtor's own benefit. Also include assets and properties which 

have no book value, such as fully depreciated assets or assets that were not capitalized. In Schedule A/B, list any executory contracts or 

unexpired leases. Also list them on Schedule G: Executory Contracts and Unexpired Leases (Official Form 206G).

Be as complete and accurate as possible. If more space is needed, attach a separate sheet to this form. At the top of any pages added, write the 

debtor’s name and case number (if known). Also identify the form and line number to which the additional information applies. If an additional 

sheet is attached, include the amounts from the attachment in the total for the pertinent part.

Check if this is an 

amended filing

 ̈

For Part 1 through Part 11, list each asset under the appropriate category or attach separate supporting schedules, such as a fixed asset 

schedule or depreciation schedule, that gives the details for each asset in a particular category. List each asset only once. In valuing the 

debtor’s interest, do not deduct the value of secured claims. See the instructions to understand the terms used in this form.

 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: CASH AND CASH EQUIVALENTS

DOES THE DEBTOR HAVE ANY CASH OR CASH EQUIVALENTS?

 ̈ No. Go to Part 2.

þ Yes. Fill in the information below.

1.

All cash or cash equivalents owned or controlled by the debtor Current value of 

debtor’s interest

2. CASH ON HAND 

NONE

CHECKING, SAVINGS, MONEY MARKET, OR FINANCIAL BROKERAGE ACCOUNTS 

(IDENTIFY ALL) 

3.

Name of institution (bank or brokerage firm) Type of account Last 4 digits of account number

3.1. BANK OF TEXAS CHECKING (OPERATING) 8712 $6,671.18

3.2. PLAINSCAPITAL BANK CHECKING 6124 $17,774.70

3.3. THIRD COAST BANK CHECKING 3938 $50.00

4. OTHER CASH EQUIVALENTS 

NONE

Total of Part 1.

ADD LINES 2 THROUGH 4 (INCLUDING AMOUNTS ON ANY ADDITIONAL SHEETS). COPY THE 

TOTAL TO LINE 80.

5

$24,495.88

 Part 2: DEPOSITS AND PREPAYMENTS

DOES THE DEBTOR HAVE ANY DEPOSITS OR PREPAYMENTS?

þ No. Go to Part 3.

 ̈ Yes. Fill in the information below.

6.

Current value of 

debtor’s interest

7. DEPOSITS, INCLUDING SECURITY DEPOSITS AND UTILITY DEPOSITS 

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 1 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 11 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

Current value of 

debtor’s interest

7. DEPOSITS, INCLUDING SECURITY DEPOSITS AND UTILITY DEPOSITS 

DESCRIPTION, INCLUDING NAME OF HOLDER OF DEPOSIT

PREPAYMENTS, INCLUDING PREPAYMENTS ON EXECUTORY CONTRACTS, LEASES, 

INSURANCE, TAXES, AND RENT 

8.

DESCRIPTION, INCLUDING NAME OF HOLDER OF PREPAYMENT

Total of Part 2.

ADD LINES 7 THROUGH 8. COPY THE TOTAL TO LINE 81.

9

NOT APPLICABLE

 Part 3: ACCOUNTS RECEIVABLE

DOES THE DEBTOR HAVE ANY ACCOUNTS RECEIVABLE?

þ No. Go to Part 4.

 ̈ Yes. Fill in the information below.

10.

Current value of 

debtor’s interest

11. ACCOUNTS RECEIVABLE 

Total of Part 3.

CURRENT VALUE ON LINES 11A + 11B = LINE 12. COPY THE TOTAL TO LINE 82.

12

NOT APPLICABLE

 Part 4: INVESTMENTS

DOES THE DEBTOR OWN ANY INVESTMENTS?

 ̈ No. Go to Part 5.

þ Yes. Fill in the information below.

13.

Current value of 

debtor’s interest

Valuation method used 

for current value

14. MUTUAL FUNDS OR PUBLICLY TRADED STOCKS NOT INCLUDED IN PART 1 

NAME OF FUND OR STOCK:

NON-PUBLICLY TRADED STOCK AND INTERESTS IN INCORPORATED AND 

UNINCORPORATED BUSINESSES, INCLUDING ANY INTEREST IN AN LLC, PARTNERSHIP, 

OR JOINT VENTURE 

15.

Name of entity % of ownership

15.1. COTTONWOOD FINANCIAL ADMINSTRATIVE SERVICES, LTD. 100% UNKNOWN

15.2. COTTONWOOD FINANCIAL AUSTIN CSO 100% UNKNOWN

15.3. COTTONWOOD FINANCIAL EXECUTIVE, LLC 100% UNKNOWN

15.4. COTTONWOOD FINANCIAL IDAHO, LLC 100% UNKNOWN

15.5. COTTONWOOD FINANCIAL ILLINOIS, LLC 100% UNKNOWN

15.6. COTTONWOOD FINANCIAL INVESTMENTS, LLC 100% UNKNOWN

15.7. COTTONWOOD FINANCIAL MICHIGAN, LLC 100% UNKNOWN

15.8. COTTONWOOD FINANCIAL NEW MEXICO, LLC 100% UNKNOWN

15.9. COTTONWOOD FINANCIAL TEXAS, LLC 100% UNKNOWN

15.10. COTTONWOOD FINANCIAL UTAH, LLC 100% UNKNOWN

15.11. COTTONWOOD FINANCIAL WISCONSIN, LLC 100% UNKNOWN

GOVERNMENT BONDS, CORPORATE BONDS, AND OTHER NEGOTIABLE AND 

NON-NEGOTIABLE INSTRUMENTS NOT INCLUDED IN PART 1 

16.

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 2 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 12 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

Current value of 

debtor’s interest

Valuation method used 

for current value

GOVERNMENT BONDS, CORPORATE BONDS, AND OTHER NEGOTIABLE AND 

NON-NEGOTIABLE INSTRUMENTS NOT INCLUDED IN PART 1 

16.

DESCRIBE:

Total of Part 4.

ADD LINES 14 THROUGH 16. COPY THE TOTAL TO LINE 83.

17

UNDETERMINED

 Part 5: INVENTORY, EXCLUDING AGRICULTURE ASSETS

DOES THE DEBTOR OWN ANY INVENTORY (EXCLUDING AGRICULTURE ASSETS)?

þ No. Go to Part 6.

 ̈ Yes. Fill in the information below.

18.

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

Date of the last 

physical inventory

19. RAW MATERIALS 

20. WORK IN PROGRESS 

21. FINISHED GOODS, INCLUDING GOODS HELD FOR RESALE 

22. OTHER INVENTORY OR SUPPLIES 

Total of Part 5.

ADD LINES 19 THROUGH 22. COPY THE TOTAL TO LINE 84.

23

NOT APPLICABLE

Is any of the property listed in Part 5 perishable?

þ No

 ̈ Yes

24.

Has any of the property listed in Part 5 been purchased within 20 days before the bankruptcy was filed?

þ No

 ̈ Yes

25.

Book value Valuation method Current value

Has any of the property listed in Part 5 been appraised by a professional within the last year?

þ No

 ̈ Yes

26.

 Part 6: FARMING AND FISHING-RELATED ASSETS (OTHER THAN TITLED MOTOR VEHICLES AND LAND)

DOES THE DEBTOR OWN OR LEASE ANY FARMING AND FISHING-RELATED ASSETS (OTHER THAN TITLED MOTOR VEHICLES AND 

LAND)?

þ No. Go to Part 7.

 ̈ Yes. Fill in the information below.

27.

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

28. CROPS—EITHER PLANTED OR HARVESTED 

FARM ANIMALS EXAMPLES: LIVESTOCK, POULTRY, FARM-RAISED FISH EXAMPLES: 

LIVESTOCK, POULTRY, FARM-RAISED FISH

29.

FARM MACHINERY AND EQUIPMENT (OTHER THAN TITLED MOTOR VEHICLES) (OTHER 

THAN TITLED MOTOR VEHICLES)

30.

31. FARM AND FISHING SUPPLIES, CHEMICALS, AND FEED 

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 3 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 13 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

32. OTHER FARMING AND FISHING-RELATED PROPERTY NOT ALREADY LISTED IN PART 6 

Total of Part 6.

ADD LINES 28 THROUGH 32. COPY THE TOTAL TO LINE 85.

33

NOT APPLICABLE

Is the debtor a member of an agricultural cooperative?

þ No

 ̈ Yes. Is any of the debtor’s property stored at the cooperative ?

 ̈ No

 ̈ Yes

34.

Has any of the property listed in Part 6 been purchased within 20 days before the bankruptcy was filed?

þ No

 ̈ Yes

35.

Is a depreciation schedule available for any of the property listed in Part 6?

þ No

 ̈ Yes

36.

Has any of the property listed in Part 6 been appraised by a professional within the last year? 

þ No

 ̈ Yes

37.

 Part 7: OFFICE FURNITURE, FIXTURES, AND EQUIPMENT; AND COLLECTIBLES

DOES THE DEBTOR OWN OR LEASE ANY OFFICE FURNITURE, FIXTURES, EQUIPMENT, OR COLLECTIBLES?

þ No. Go to Part 8.

 ̈ Yes. Fill in the information below.

38.

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

39. OFFICE FURNITURE 

40. OFFICE FIXTURES 

OFFICE EQUIPMENT, INCLUDING ALL COMPUTER EQUIPMENT AND COMMUNICATION 

SYSTEMS EQUIPMENT AND SOFTWARE 

41.

COLLECTIBLES EXAMPLES: ANTIQUES AND FIGURINES; PAINTINGS, PRINTS, OR OTHER 

ARTWORK; BOOKS, PICTURES, OR OTHER ART OBJECTS; CHINA AND CRYSTAL; STAMP, 

COIN, OR BASEBALL CARD COLLECTIONS; OTHER COLLECTIONS, MEMORABILIA, OR 

COLLECTIBLES

42.

Total of Part 7.

ADD LINES 39 THROUGH 42. COPY THE TOTAL TO LINE 86.

43

NOT APPLICABLE

Is a depreciation schedule available for any of the property listed in Part 7? 

þ No

 ̈ Yes

44.

Has any of the property listed in Part 7 been appraised by a professional within the last year? 

þ No

 ̈ Yes

45.

 Part 8: MACHINERY, EQUIPMENT, AND VEHICLES

DOES THE DEBTOR OWN OR LEASE ANY MACHINERY, EQUIPMENT, OR VEHICLES?

þ No. Go to Part 9.

 ̈ Yes. Fill in the information below.

46.

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 4 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 14 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

General description

Include year, make, model, and identification numbers (i.e., VIN, 

HIN, or N-number)

Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

AUTOMOBILES, VANS, TRUCKS, MOTORCYCLES, TRAILERS, AND TITLED FARM 

VEHICLES 

47.

WATERCRAFT, TRAILERS, MOTORS, AND RELATED ACCESSORIES EXAMPLES: BOATS, 

TRAILERS, MOTORS, FLOATING HOMES, PERSONAL WATERCRAFT, AND FISHING 

VESSELS

48.

49. AIRCRAFT AND ACCESSORIES 

OTHER MACHINERY, FIXTURES, AND EQUIPMENT (EXCLUDING FARM MACHINERY AND 

EQUIPMENT) 

50.

Total of Part 8.

ADD LINES 47 THROUGH 50. COPY THE TOTAL TO LINE 87.

51

NOT APPLICABLE

Is a depreciation schedule available for any of the property listed in Part 8? 

þ No

 ̈ Yes

52.

53. Has any of the property listed in Part 8 been appraised by a professional within the last year? 

þ No

 ̈ Yes

 Part 9: REAL PROPERTY

DOES THE DEBTOR OWN OR LEASE ANY REAL PROPERTY?

þ No. Go to Part 10.

 ̈ Yes. Fill in the information below.

54.

55. ANY BUILDING, OTHER IMPROVED REAL ESTATE, OR LAND WHICH THE DEBTOR OWNS OR IN WHICH THE DEBTOR HAS AN INTEREST 

Description and location of property

Include street address or other description 

such as Assessor Parcel Number (APN), and 

type of property (for example, acreage, 

factory, warehouse, apartment or office 

building), if available

Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

Nature and extent 

of debtor’s 

interest in 

property

Total of Part 9.

ADD THE CURRENT VALUE ON LINES 55.1 THROUGH 55.6 AND ENTRIES FROM ANY 

ADDITIONAL SHEETS. COPY THE TOTAL TO LINE 88.

56

NOT APPLICABLE

57. Is a depreciation schedule available for any of the property listed in Part 9? 

þ No

 ̈ Yes

58. Has any of the property listed in Part 9 been appraised by a professional within the last year? 

þ No

 ̈ Yes

 Part 10: INTANGIBLES AND INTELLECTUAL PROPERTY

DOES THE DEBTOR HAVE ANY INTERESTS IN INTANGIBLES OR INTELLECTUAL PROPERTY?

 ̈ No. Go to Part 11.

þ Yes. Fill in the information below.

59.

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

60. PATENTS, COPYRIGHTS, TRADEMARKS, AND TRADE SECRETS 

60.1. TRADEMARK FOR $!; REGISTRATION NO. 2461638 UNDETERMINED UNDETERMINED

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 5 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 15 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

General description Current value of 

debtor’s interest

Valuation method used 

for current value

Net book value of 

debtor's interest

(Where available)

60. PATENTS, COPYRIGHTS, TRADEMARKS, AND TRADE SECRETS 

60.2. TRADEMARK FOR CASH ASAP; REGISTRATION NO. 

2889456

UNDETERMINED UNDETERMINED

60.3. TRADEMARK FOR CASH STORE CASH & TITLE LOANS; 

REGISTRATION NO. 4461158

UNDETERMINED UNDETERMINED

60.4. TRADEMARK FOR CASH STORE TITLE LOANS & CASH 

ADVANCES; REGISTRATION NO. 4461159

UNDETERMINED UNDETERMINED

60.5. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

2969462

UNDETERMINED UNDETERMINED

60.6. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

3542978

UNDETERMINED UNDETERMINED

60.7. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

3546856

UNDETERMINED UNDETERMINED

60.8. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

3546857

UNDETERMINED UNDETERMINED

60.9. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

3546858

UNDETERMINED UNDETERMINED

60.10. TRADEMARK FOR CASH STORE; REGISTRATION NO. 

3637952

UNDETERMINED UNDETERMINED

60.11. TRADEMARK FOR CASHSTORE.COM; REGISTRATION 

NO. 3896180

UNDETERMINED UNDETERMINED

60.12. TRADEMARK FOR THE CASH STORE; REGISTRATION 

NO. 2270955

UNDETERMINED UNDETERMINED

60.13. TRADEMARK FOR THE CASH STORE; REGISTRATION 

NO. 2461639

UNDETERMINED UNDETERMINED

60.14. TRADEMARK FOR YOU'RE CASHWORTHY AT THE CASH 

STORE; REGISTRATION NO. 2576147

UNDETERMINED UNDETERMINED

60.15. TRADEMARK FOR YOU'RE CASHWORTHY WITH US; 

REGISTRATION NO. 2576104

UNDETERMINED UNDETERMINED

61. INTERNET DOMAIN NAMES AND WEBSITES 

62. LICENSES, FRANCHISES, AND ROYALTIES 

63. CUSTOMER LISTS, MAILING LISTS, OR OTHER COMPILATIONS 

64. OTHER INTANGIBLES, OR INTELLECTUAL PROPERTY 

65. GOODWILL 

Total of Part 10.

ADD LINES 60 THROUGH 65. COPY THE TOTAL TO LINE 89.

66

UNDETERMINED

67. Do your lists or records include personally identifiable information of customers (as defined in 11 U.S.C. §§ 101(41A) and 107)? 

þ No

 ̈ Yes

68. Is there an amortization or other similar schedule available for any of the property listed in Part 10? 

þ No

 ̈ Yes

69. Has any of the property listed in Part 10 been appraised by a professional within the last year? 

þ No

 ̈ Yes

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 6 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 16 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

 Part 11: ALL OTHER ASSETS

DOES THE DEBTOR OWN ANY OTHER ASSETS THAT HAVE NOT YET BEEN REPORTED ON THIS FORM?

INCLUDE ALL INTERESTS IN EXECUTORY CONTRACTS AND UNEXPIRED LEASES NOT PREVIOUSLY REPORTED ON THIS FORM.

 ̈ No. Go to Part 12.

þ Yes. Fill in the information below.

70.

Current value of 

debtor’s interest

71. NOTES RECEIVABLE 

DESCRIPTION (INCLUDE NAME OF OBLIGOR)

72. TAX REFUNDS AND UNUSED NET OPERATING LOSSES (NOLS) 

DESCRIPTION (FOR EXAMPLE, FEDERAL, STATE, LOCAL)

73. INTERESTS IN INSURANCE POLICIES OR ANNUITIES 

73.1. AUTOMOBILE - MSIG SPECIALTY INSURANCE COMPANY USA INC. - POLICY NO. HNO1000257-01 UNDETERMINED

73.2. GENERAL LIABILITY - THE BURLINGTON INSURANCE COMPANY - POLICY NO. 820BG08548 UNDETERMINED

73.3. PROPERTY - THE NORTH RIVER INSURANCE COMPANY - POLICY NO. 3231034839 UNDETERMINED

73.4. UMBRELLA LIABILITY - FEDERAL INSURANCE COMPANY - POLICY NO. 78198991 UNDETERMINED

73.5. WORKERS COMPENSATION - ARGONAUT INSURANCE COMPANY - POLICY NO. 92-904-838268-4 UNDETERMINED

WORKERS COMPENSATION - TEXAS MUTUAL WORKERS' COMPENSATION INSURANCE - POLICY NO. 

12306660

73.6. UNDETERMINED

CAUSES OF ACTION AGAINST THIRD PARTIES (WHETHER OR NOT A LAWSUIT HAS 

BEEN FILED) 

74.

OTHER CONTINGENT AND UNLIQUIDATED CLAIMS OR CAUSES OF ACTION OF EVERY 

NATURE, INCLUDING COUNTERCLAIMS OF THE DEBTOR AND RIGHTS TO SET OFF 

CLAIMS 

75.

76. TRUSTS, EQUITABLE OR FUTURE INTERESTS IN PROPERTY 

OTHER PROPERTY OF ANY KIND NOT ALREADY LISTED EXAMPLES: SEASON TICKETS, 

COUNTRY CLUB MEMBERSHIP EXAMPLES: SEASON TICKETS, COUNTRY CLUB 

MEMBERSHIP

77.

Total of Part 11.

ADD LINES 71 THROUGH 77. COPY THE TOTAL TO LINE 90.

78

UNDETERMINED

79. Has any of the property listed in Part 11 been appraised by a professional within the last year? 

þ No

 ̈ Yes

 Part 12: Summary

Cash, cash equivalents, and financial assets. Copy line 5, Part 1.

In Part 12 copy all of the totals from the earlier parts of the form. 

Type of property Current value of 

personal property

Current value of real 

property

80. $24,495.88

81. Deposits and prepayments. Copy line 9, Part 2.

82. Accounts receivable. Copy line 12, Part 3.

83. Investments. Copy line 17, Part 4. UNDETERMINED

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 7 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 17 of 24
Debtor Case number (if known)

(Name)

COTTONWOOD FINANCIAL LTD. 24-80035

84. Inventory. Copy line 23, Part 5.

85. Farming and fishing-related assets. Copy line 33, Part 6.

Office furniture, fixtures, and equipment; and collectibles.

Copy line 43, Part 7.

86.

87. Machinery, equipment, and vehicles. Copy line 51, Part 8. 

88. Real property. Copy line 56, Part 9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .è N/A

89. Intangibles and intellectual property. Copy line 66, Part 10. UNDETERMINED

90. All other assets. Copy line 78, Part 11. UNDETERMINED +

91. Total. Add lines 80 through 90 for each column. . . . . . . . . 91a. $24,495.88 + 91b. N/A

92. Total of all property on Schedule A/B. Lines 91a + 91b = 92. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $24,495.88

Official Form 206A/B Schedule A/B: Assets - Real and Personal Property Page 8 of 8

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 18 of 24
 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.

Official Form 206D

Schedule D: Creditors Who Have Claims Secured by Property 12/15

Be as complete and accurate as possible.

Check if this is an 

amended filing

 ̈

1. 1. Do any creditors have claims secured by debtor’s property?

No. Check this box and submit page 1 of this form to the court with debtor’s other schedules . Debtor has nothing else to report on this form.

þ Yes. Fill in all of the information below.

 ̈

List in alphabetical order all creditors who have secured claims. If a creditor has more than 

one secured claim, list the creditor separately for each claim. 

2. Column A

Amount of claim

Do not deduct the value of 

collateral.

Column B

Value of collateral that 

supports this claim

 Part 1: List All Creditors with Secured Claims

2.1 Creditor’s name

THIRD COAST BANK

Creditor's mailing address

20202 HIGHWAY 59 N

SUITE 190

HUMBLE, TEXAS 77338

USA

Creditor's email address

DDIENES@THIRDCOASTSSB.COM

Date or dates debt was incurred

12/9/2020

Last 4 digits of account number: 5303

Do multiple creditors have an interest in the 

same property?

þ No

 ̈ Yes

Describe debtor’s property that is 

subject to a lien

ALL ASSETS

Describe the lien

FIRST LIEN LOAN FACILITY

Is the creditor an insider or related 

party?

þ No

 ̈ Yes

Is anyone else liable on this claim?

 ̈ No

þ Yes

As of the petition filing date, the claim is:

Check all that apply.

 ̈ Contingent

 ̈ Unliquidated

 ̈ Disputed

$26,743,881.44 UNKNOWN

Total of the dollar amounts from Part 1, Column A, including the amounts from the 

Additional Page, if any.

3. $26,743,881.44 

Official Form 206D Schedule D: Creditors Who Have Claims Secured by Property Page 1 of 1

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 19 of 24
Official Form 206E/F

Schedule E/F: Creditors Who Have Unsecured Claims 12/15

Be as complete and accurate as possible. Use Part 1 for creditors with PRIORITY unsecured claims and Part 2 for creditors with NONPRIORITY 

unsecured claims. List the other party to any executory contracts or unexpired leases that could result in a claim. Also list executory contracts 

on Schedule A/B: Assets - Real and Personal Property (Official Form 206A/B) and on Schedule G: Executory Contracts and Unexpired Leases

(Official Form 206G). Number the entries in Parts 1 and 2 in the boxes on the left. If more space is needed for Part 1 or Part 2, fill out and attach 

the Additional Page of that Part included in this form.

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: List All Creditors with PRIORITY Unsecured Claims

1. Do any creditors have priority unsecured claims? (See 11 U.S.C. § 507).

No. Go to Part 2.

 ̈ Yes. Go to line 2.

þ

 Part 2: List All Creditors with NONPRIORITY Unsecured Claims

Do any creditors have nonpriority unsecured claims? (See 11 U.S.C. § 507).

No.

þ Yes.

 ̈

List in alphabetical order all of the creditors with nonpriority unsecured claims. If the debtor has more than 6 creditors with nonpriority 

unsecured claims, fill out and attach the Additional Page of Part 2.

3.

Amount of claim

Nonpriority creditor’s name and mailing address

BOMANI BUSINESS LENDING, LLC

C/O WICK PHILLIPS

ATTN: JASON RUDD & CATHERINE CURTIS

3131 MCKINNEY AVENUE, SUITE 500

DALLAS, TX 75204

Date or dates debt was incurred

Last 4 digits of account number: 

As of the petition filing date, the claim is:

Check all that apply.

 ̈ Contingent

 ̈ Unliquidated

 ̈ Disputed

Basis for the claim:

SUBORDINATED NOTE

Is the claim subject to offset?

þ No

 ̈ Yes

3.1 $38,162,528.33

Nonpriority creditor’s name and mailing address

NAME AND ADDRESS REDACTED

Date or dates debt was incurred

Last 4 digits of account number: 

As of the petition filing date, the claim is:

Check all that apply.

þ Contingent

þ Unliquidated

þ Disputed

Basis for the claim:

CONSUMER CLAIM, US DISTRICT COURT OF 

COLUMBIA - CASE NO. 1:23-CV-00571

Is the claim subject to offset?

þ No

 ̈ Yes

3.2 UNKNOWN

Official Form 206E/F Schedule E/F: Creditors Who Have Unsecured Claims Page 1 of 2

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 20 of 24
Debtor COTTONWOOD FINANCIAL LTD. Case number (if known) 24-80035

(Name)

 Part 2: Additional Page

Amount of claim

Nonpriority creditor’s name and mailing address

NAME AND ADDRESS REDACTED

Date or dates debt was incurred

Last 4 digits of account number: 

As of the petition filing date, the claim is:

Check all that apply.

þ Contingent

þ Unliquidated

þ Disputed

Basis for the claim:

CONSUMER CLAIM, WISCONSIN WAUPACA 

COUNTY CIRCUIT COURT - CASE NO. 

2022CV000278

Is the claim subject to offset?

þ No

 ̈ Yes

3.3 UNKNOWN

Nonpriority creditor’s name and mailing address

NAME AND ADDRESS REDACTED

Date or dates debt was incurred

Last 4 digits of account number: 

As of the petition filing date, the claim is:

Check all that apply.

þ Contingent

þ Unliquidated

þ Disputed

Basis for the claim:

CONSUMER CLAIM, WISCONSIN MILWAUKEE 

COUNTY CIRCUIT COURT - CASE NO. 

19-SC-49193

Is the claim subject to offset?

þ No

 ̈ Yes

3.4 UNKNOWN

 Part 4: Total Amounts of the Priority and Nonpriority Unsecured Claims

5. Add the amounts of priority and nonpriority unsecured claims. 

5a.

 Total of claim amounts

Total claims from Part 1 5a.

5b. Total claims from Part 2 5b. +

5c. Total of Parts 1 and 2

Lines 5a + 5b = 5c.

5c.

$38,162,528.33

NOT APPLICABLE

$38,162,528.33

Official Form 206E/F Schedule E/F: Creditors Who Have Unsecured Claims Page 2 of 2

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 21 of 24
Official Form 206G

Schedule G: Executory Contracts and Unexpired Leases 12/15

Be as complete and accurate as possible. If more space is needed, copy and attach the additional page, numbering the entries consecutively.

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.

1. Does the debtor have any executory contracts or unexpired leases?

No. Check this box and file this form with the court with the debtor’s other schedules . There is nothing else to report on this form.

Yes. Fill in all of the information below even if the contracts or leases are listed on Schedule A/B: Assets - Real and Personal Property (Official 

Form 206A/B).

þ

 ̈

2. List all contracts and unexpired leases State the name and mailing address for all other parties with 

whom the debtor has an executory contract or unexpired lease

2.1 ACCELERATED DATA SYSTEMS INC

5750 DTC PARKWAY

STE 145

GREENWOOD VILLAGE, CO 80111

State what the contract 

or lease is for and the 

nature of the debtor’s 

interest

MULTI-USER SOFTWARE LICENSE AND 

SUPPORT AGREEMENT

State the term remaining 3/17/2024

List the contract number 

of any government 

contract

2.2 COMMERCIAL FIRE LLC

2465 ST JOHNS BLUFF RD S

JACKSONVILLE, FL 32246

State what the contract 

or lease is for and the 

nature of the debtor’s 

interest

FIRE-LIFE SAFETY SERVICES 

AGREEMENT 12-01-2020

State the term remaining 12/1/2024

List the contract number 

of any government 

contract

2.3 EAN SERVICES LLC

600 CORPORATE PARK DR

SAINT LOUIS, MO 63105-4204

State what the contract 

or lease is for and the 

nature of the debtor’s 

interest

CORPORATE PARTNER PROGRAM 

AGREEMENT

State the term remaining CURRENT

List the contract number 

of any government 

contract

2.4 SWIFTREACH NETWORKS INC

492 OLD CONNECTICUT PATH

2ND FLOOR

FRAMINGHAM, MA 01701

State what the contract 

or lease is for and the 

nature of the debtor’s 

interest

SERVICE ORDER AND AGREEMENT

State the term remaining CURRENT

List the contract number 

of any government 

contract

Official Form 206G Schedule G: Executory Contracts and Unexpired Leases Page 1 of 1

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 22 of 24
Official Form 206H

Schedule H: Codebtors 12/15

Be as complete and accurate as possible. If more space is needed, copy the Additional Page, numbering the entries consecutively. Attach the 

Additional Page to this page. 

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.

1. Does the debtor have any codebtors?

No. Check this box and submit this form to the court with the debtor's other schedules. Nothing else needs to be reported on this form.

þ Yes.

 ̈

In Column 1, list as codebtors all of the people or entities who are also liable for any debts listed by the debtor in the schedules of 

creditors, Schedules D-G. Include all guarantors and co-obligors. In Column 2, identify the creditor to whom the debt is owed and each 

schedule on which the creditor is listed. If the codebtor is liable on a debt to more than one creditor, list each creditor separately in Column 2.

2.

Column 1: Codebtor Column 2: Creditor

Name Mailing Address Name Check all schedules 

that apply

2.1 2100 W. WALNUT HILL LANE

SUITE 300

IRVING, TX 75038

COTTONWOOD FINANCIAL 

ADMINISTRATIVE SERVICE 

LLC

THIRD COAST BANK þ D

 ̈ E/F

 ̈ G

2.2 2100 W. WALNUT HILL LANE

SUITE 300

IRVING, TX 75038

COTTONWOOD FINANCIAL 

TEXAS LLC

THIRD COAST BANK þ D

 ̈ E/F

 ̈ G

Official Form 206H Schedule H: Codebtors Page 1 of 1

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 23 of 24
Official Form 202

Declaration Under Penalty of Perjury for Non-Individual Debtors 12/15

An individual who is authorized to act on behalf of a non-individual debtor, such as a corporation or partnership, must sign and submit this 

form for the schedules of assets and liabilities, any other document that requires a declaration that is not included in the document, and any 

amendments of those documents. This form must state the individual’s position or relationship to the debtor, the identity of the document, and 

the date. Bankruptcy Rules 1008 and 9011.

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. 

 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.

Delcaration and signature

I am the president, another officer, or an authorized agent of the corporation; a member or an authorized agent of the partnership; or

another individual serving as a representative of the debtor in this case.

I have examined the information in the documents checked below and I have a reasonable belief that the information is true and correct: 

þ Schedule A/B: Assets-Real and Personal Property (Official Form 206A/B)

þ Schedule D: Creditors Who Have Claims Secured by Property (Official Form 206D)

þ Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 206E/F)

þ Schedule G: Executory Contracts and Unexpired Leases (Official Form 206G)

þ Schedule H: Codebtors (Official Form 206H)

þ Summary of Assets and Liabilities for Non-Individuals (Official Form 206Sum)

 ̈ Amended Schedule

 ̈ Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured Claims and Are Not Insiders (Official Form 204)

 ̈ Other document that requires a declaration

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

Executed on 03/29/2024 /s/ KAREN G. NICOLAOU

MM / DD / YYYY Signature of individual signing on behalf of debtor

KAREN G. NICOLAOU

Printed name

CHIEF RESTRUCTURING OFFICER

Position or relationship to debtor 

û

Official Form 202 Declaration Under Penalty of Perjury for Non-Individual Debtors 

Case 24-80035-swe11 Doc 185 Filed 03/29/24 Entered 03/29/24 16:26:11 Desc

Main Document Page 24 of 24