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Litigation finance

Disclosure and champerty

status: draft

Disclosure and champerty

Two legal considerations dominate litigation finance structuring: disclosure requirements (when must you reveal the funding?) and champerty (is the funding arrangement even valid?). Both are jurisdiction-specific and evolving rapidly.

Third-party funding disclosure

Disclosure obligations are expanding. Assume your funding will eventually become known—structure accordingly.

Federal court rules

The federal landscape is fragmented but trending toward mandatory disclosure.

Court/DistrictRequirementScope
N.D. California (Local Rule 3-15)Disclose non-party with financial interestCovers most funders; disclosed to court
D. New Jersey (Local Civil Rule 7.1.1)Disclose funder identityStandalone litigation funding rule (2021)
E.D. & W.D. WisconsinStanding orders requiring disclosureIdentity and general terms
D. DelawareDisclose funding in patent casesAffects significant portion of funded IP
MDL PanelIncreasingly requires disclosureCase management; varies by proceeding

Coming changes: The Judicial Conference has studied uniform federal disclosure rules. While no rule exists yet, expect broader requirements within 2-3 years. Draft rules have proposed disclosure of:

  • Funder identity
  • Whether funder has approval rights over settlement
  • General economic terms (not specific percentages)

State court rules

StateStatusNotes
WisconsinDisclosure requiredFirst state; must produce agreement upon request
West VirginiaDisclosure requiredIdentity and basic terms
MontanaEnacted requirementsPrimarily targeting consumer funding
IndianaEnacted requirementsConsumer focus with spillover
LouisianaProposed requirementsPending legislation
New YorkNo general requirementCourts may order production in discovery
CaliforniaNo commercial requirementConsumer funding regulated separately

Most states have no explicit requirements, but courts can order disclosure in discovery if relevant. The trend is clearly toward more disclosure, not less.

International arbitration

Disclosure is more established in international arbitration:

InstitutionRequirement
ICSIDTribunals routinely order disclosure; affects costs allocation
ICC2021 Rules require disclosure of funder existence and identity
SIACDisclosure requirements adopted
HKIACDisclosure guidance issued
LCIADisclosure requirements in place

Why arbitration moved first: Arbitrators have broad discretion over procedure, funders often have interests in cost allocation, and arbitral institutions compete globally on governance standards.

Practical implications

Structure for disclosure:

Assume your funding arrangement will become known. Structure so that disclosure doesn’t harm competitive position or case strategy:

  • Separate economic terms from strategy discussions in documentation
  • Use standard market terms that don’t reveal unusual positions
  • Maintain privilege protections through proper structuring

Privilege protection:

The funding agreement itself may be discoverable even if communications remain privileged. Best practices:

  • Separate funding negotiation from case strategy communications
  • Involve counsel in privilege-protected discussions
  • Mark privileged communications clearly
  • Consider common-interest agreements with funder

Disclosure timing:

Early disclosure (at case inception) is less disruptive than mid-litigation disclosure. If you know disclosure is coming, get ahead of it rather than having it forced during settlement negotiations.

Competitive intelligence:

Your competitors will learn about your funded positions. Factor this into:

  • Deal terms (if terms are disclosed, are they market?)
  • Relationship management (counterparty may know your capital constraints)
  • Settlement strategy (defendant knows you have funding support)

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Champerty law by jurisdiction

Champerty (third-party financing of litigation for a share of proceeds) was historically prohibited. Most US jurisdictions have abolished or limited these restrictions, but the landscape remains uneven.

States where funding is clearly permitted

These jurisdictions have explicitly authorized litigation funding by statute, court decision, or abolished champerty entirely:

StateStatusKey Authority
CaliforniaPermittedChamperty doctrine abolished
New YorkPermittedJudiciary Law §489 narrowly construed
TexasPermittedNo champerty prohibition
FloridaPermittedChamperty abolished
IllinoisPermittedConsumer regulated; commercial permitted
MassachusettsPermittedCourts have upheld funding
WashingtonPermittedChamperty not recognized
NevadaPermittedExplicitly authorized
ArizonaPermittedNo champerty bar
New JerseyPermittedCourts enforce commercial funding
ColoradoPermittedNo restrictions for commercial

In these jurisdictions, properly structured funding agreements are enforceable according to their terms.

States with restrictions or uncertainty

Delaware: The primary cautionary jurisdiction.

Delaware has not abolished champerty. The Court of Chancery has expressed skepticism about funding arrangements with strong funder control. Key cases:

  • Charge Injection Technologies v. DuPont (Del. Ch. 2016): Court expressed concern about funder control; noted funder was “real party in interest”
  • Hamilton Capital VII (Del. 2023): Continued scrutiny of aggressive control provisions

Practice tips for Delaware:

  • Minimize funder control rights in agreement
  • Ensure plaintiff retains all litigation decisions
  • Consider New York governing law for the funding agreement itself
  • Obtain Delaware counsel opinion on enforceability

Other uncertain jurisdictions:

StateStatus
MinnesotaRetains doctrine; not applied to modern funding
AlabamaChamperty statute on books; rare enforcement
South CarolinaTraditional restrictions; untested recently
GeorgiaTechnically prohibited; not applied to modern structures
PennsylvaniaMixed precedent; older cases not overruled
OhioMixed precedent; case-by-case review

Structuring around champerty risk

For cases touching uncertain jurisdictions:

1. Ensure plaintiff controls litigation:

  • No funder veto over strategy, witnesses, or litigation decisions
  • Settlement approval rights framed as economic protection only (minimum return), not case control
  • Document plaintiff’s independent decision-making

2. Document independence:

  • Investment committee memos should reflect plaintiff sought funding, not that it was imposed
  • Show plaintiff evaluated multiple funders
  • Demonstrate arm’s-length negotiation

3. Choose governing law carefully:

  • Many funding agreements use New York or California law regardless of case jurisdiction
  • Check that choice-of-law clause will be respected in relevant courts
  • Consider whether the case itself involves Delaware law (separate analysis)

4. Consider assignment vs. funding:

  • Purchasing a claim outright may face different treatment than funding
  • Assignment may be more clearly permitted but changes accounting treatment
  • Hybrid structures (partial assignment) may offer benefits

5. Get specific legal opinions:

  • For Delaware-touching matters, obtain Delaware counsel opinion
  • For matters in uncertain jurisdictions, confirm enforceability before funding

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Regulatory developments

Beyond disclosure and champerty, broader regulatory trends affect litigation finance:

Consumer litigation funding

Consumer legal funding (small advances to personal injury plaintiffs) faces increasing regulation:

StateRegulation
Multiple statesRate caps, disclosure requirements
CFPBHas expressed interest in oversight
State AGsEnforcement actions against abusive practices

Commercial litigation funding is generally not subject to these consumer protections, but regulatory spillover is possible.

Securities law

  • Fund structures must comply with securities registration or exemption requirements
  • Most litigation finance funds rely on Rule 506 (accredited investors)
  • Public funder vehicles (Burford, Omni Bridgeway) have securities law obligations

Professional responsibility

  • Bar rules on fee-splitting may affect how funding arrangements are structured
  • Lawyers cannot share fees with non-lawyers (varies by jurisdiction)
  • Funding must be structured as client capital, not lawyer fee-sharing

Trend direction

FactorDirectionImpact
Disclosure requirementsExpandingMore transparency; less asymmetry
Champerty restrictionsContractingMore jurisdictions permitting funding
Consumer regulationExpandingMay spill into commercial space
Institutional acceptanceGrowingMore capital; more standardized structures

The overall trend supports litigation finance growth, but compliance complexity is increasing. Structures that were fine 5 years ago may need updating.


status: draft

Related: Single-Case Funding · Diligence Guide

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