The CFPB sued Top Notch Funding II, LLC “for lying in loan offerings to consumers who were awaiting payment from settlements” or “victim-compensation funds.” The “consumers included former National Football League (NFL) players suffering from neurological disorders, victims of the Deepwater Horizon oil-rig disaster, and 9/11 first responders.” In January 2018, a federal district judge ordered Top Notch Funding (and two individuals associated with the company) to pay a total of $75,000, even recognizing the “Defendants’ limited financial resources.”

• On September 19, 2017, the CFPB sued Top Notch Funding II, LLC [CFPB v. Top Notch Funding II, LLC et. al., Case no. 1:17-cv-07114]

• “The Consumer Financial Protection Bureau (CFPB) took action today against Top Notch Funding and two individuals associated with the company for lying in loan offerings to consumers who were awaiting payment from settlements in legal cases or from victim-compensation funds. These consumers included former National Football League (NFL) players suffering from neurological disorders, victims of the Deepwater Horizon oil-rig disaster, and 9/11 first responders. In a complaint and proposed consent order filed in federal court, the CFPB is seeking to prevent Top Notch, its owner Rory Donadio, and his business associate John ‘Gene’ Cavalli from offering or providing such products in the future, and to require them to pay $70,000 in civil money penalties to the CFPB’s Civil Penalty Fund. The proposed penalties take into account the defendants’ inability to pay more.” [Press Release, Consumer Financial Protection Bureau, 09/19/17]

• In January 2018, a federal district judge ordered the defendants to pay a total of $75,000, taking  “into account Defendants’ limited financial resources.” [CFPB v. Top Notch Funding II, LLC et. al., Case no. 1:17-cv-07114]