Reliable Fast Cash lawsuit: what TLC Homes and Raycom held

Reliable Fast Cash lawsuit coverage of TLC Homes: usury and fraud claims dismissed with prejudice, unjust enrichment survived. Plus the Raycom COJ Slip Op.

Updated 2026-10-30

Home · News · Reliable Fast Cash lawsuit

By Anonymous MCA industry contributor Research, writing and editorial review · MCA sales background

A Reliable Fast Cash lawsuit search usually lands on private New York litigation involving Reliable Fast Cash, LLC, not a statewide Attorney General enforcement caption. The clearest published trial-court signal is Richmond County’s June 22, 2022 decision in Tender Loving Care Homes Inc. v. Reliable Fast Cash, LLC, reported as 2022 NY Slip Op 22196 and 76 Misc 3d 314. That opinion dismissed fraud and declaratory-judgment theories (including the usury-as-loan attack) with prejudice, while letting an unjust-enrichment claim about the confession-judgment balance proceed to discovery. A related Kings County confession-of-judgment fight, Raycom Program Ventures, Inc. v. Reliable Fast Cash, LLC, 2018 NY Slip Op 31946(U), shows a different procedural posture: most of the merchant-side vacatur theories survived dismissal, but the usury count did not. This page sticks to those Slip Opinions. It is not a prediction about your file.

Editorial update: 2026-10-27 · Desk research of the published Richmond County Misc 3d opinion and the Kings County Raycom Slip Opinion. Not legal advice.

Quick answer

Item	Public record
Lead published case	Tender Loving Care Homes Inc. v. Reliable Fast Cash, LLC, 2022 NY Slip Op 22196, 76 Misc 3d 314 (Sup Ct, Richmond County June 22, 2022) (DiDomenico, J.)
Related Kings County case	Raycom Program Ventures, Inc. v. Reliable Fast Cash, LLC, 2018 NY Slip Op 31946(U) (Sup Ct, Kings County July 30, 2018) (Ruchelsman, J.), Index No. 501246/18
TLC Homes outcome	Fraud and declaratory-judgment causes dismissed with prejudice; unjust enrichment proceeds to discovery
Raycom outcome (July 2018)	Motion to dismiss denied except the usury count, which was dismissed
Core dispute pattern	Merchant-side plenary attacks on receivables-purchase agreements and confessions of judgment, decided under the familiar LG Funding loan-versus-sale factors

Soft next step if papers name Reliable Fast Cash, LLC, or a related confession filing: read the caption, county, and any return date before treating a summary as your deadline. You can request a free consultation from Coastal Debt Resolve (Get a free review). Comparing providers? See our Business Debt Insider review.

What TLC Homes says happened

According to the published opinion, Frederick Baker’s company, Tender Loving Care Homes Inc., entered a September 13, 2018 contract with Reliable Fast Cash. Reliable purchased rights to Tender’s future receivables with a face value of $356,762 for a purchase price of $238,000. Tender authorized daily debits of $2,744, described as an estimate of 42% of daily revenue, based on estimated average monthly sales of about $153,000. Baker also signed a personal guaranty and an affidavit of confession of judgment held in escrow.

Around October 2018, Tender blocked payments from the designated account. Reliable then filed a confession judgment for $73,318.48, described as the contractual balance of $54,833.82 plus attorney’s fees and costs. Reliable waived prejudgment interest.

Plaintiffs’ amended complaint pressed four theories:

Declaratory judgment that the agreement and guaranty were criminally usurious loans disguised as receivables purchases.
Declaratory judgment that the confession of judgment was invalid as a product of that allegedly illegal contract.
Declaratory judgment that the forum-selection clause was invalid (and thus that the court lacked jurisdiction).
Unjust enrichment, alleging the confession-judgment amount omitted payments Tender had made.

What Richmond County held in TLC Homes

Loan-versus-sale analysis cut against the usury theory

Reliable moved to dismiss, arguing the contract was a true purchase of future receipts, not a loan. The court applied the familiar three-factor test from LG Funding, LLC v. United Senior Props. of Olathe, LLC, 181 AD3d 664 (2d Dept 2020): reconciliation, finite term, and recourse if the merchant declares bankruptcy. Language saying “THIS IS NOT A LOAN” was not conclusive; the court looked at the whole deal.

On the factors as described in the opinion, the agreement did not set a finite repayment term. Withdrawals were framed as a percentage of receivables until the purchase amount was recovered, and the contract addressed what happens if the full purchase amount is never remitted because the seller’s business fails. Those features, together with the reconciliation structure discussed in the decision, led the court to treat the arrangement as a purchase rather than an absolute-repayment loan. The usury / disguised-loan declaratory theory therefore failed at the pleading stage on that record.

Important limit: TLC Homes is one Richmond County decision on one contract record. It is not a statewide holding that every Reliable Fast Cash agreement is insulated from loan analysis. Compare our Argus Capital lawsuit page, where the Fourth Department kept a usury-as-loan theory alive because reconciliation looked illusory and the term looked finite on the pleaded facts.

Fraud and the other declaratory claims dismissed with prejudice

The court granted Reliable’s dismissal motion in part. Causes of action sounding in fraud and for declaratory judgment (including the confession-judgment and forum-selection attacks tied to the illegality theory) were dismissed with prejudice.

Unjust enrichment survived to discovery

The unjust-enrichment claim alleged that payments made under the agreement were omitted when Reliable calculated the confession-judgment amount. Reliable offered an unsworn “statement of account.” The court held that document was not enough to conclusively disprove unrecorded payments at the CPLR 3211 stage. Because Reliable did not argue that a valid contract barred quasi-contract recovery in its moving papers, and because plaintiffs had not pleaded breach of contract while contesting the contract’s validity, the court let unjust enrichment proceed to discovery (unless plaintiffs later amended to plead breach).

Bottom line of the reported decision: no surviving usury or fraud declaratory track on that complaint, but a live dollar-accounting dispute about the judgment balance.

Related Kings County signal: Raycom

Raycom Program Ventures, Inc. v. Reliable Fast Cash, LLC, 2018 NY Slip Op 31946(U) (Sup Ct, Kings County July 30, 2018), Index No. 501246/18, is a different kind of merchant-side fight. According to that decision and order, Mary McDonnell entered merchant agreements with Reliable Fast Cash in summer 2017 and executed confessions of judgment that Reliable later entered in Kings County against multiple individuals and entities, including Bellum Entertainment LLC. Raycom, a fifty-percent owner of BR Holding Company LLC (with Bellum as the other half), sued to vacate, alleging McDonnell lacked authority to bind related California production entities (Fix It and Finish LLC and Flip My Food LLC) and pleading fraud, CPLR 3218 defects, usury, and vacatur.

Reliable moved to dismiss. Justice Ruchelsman denied the motion except as to the fourth (usury) count, which was dismissed. Authority, fraud, CPLR 3218, and vacatur theories were allowed to proceed at that early stage. A follow-up Slip Opinion in the same index, 2018 NY Slip Op 32945(U) (Nov. 20, 2018), appears in the reporter series; treat it as later motion practice in the same case rather than a second, free-standing “Reliable Fast Cash lawsuit” storyline.

Together, TLC Homes and Raycom show why a single Google result for “Reliable Fast Cash lawsuit” is not enough: one published Misc 3d opinion can shut down a usury/fraud declaratory package while keeping an accounting claim alive, while a related COJ-authority case can keep most vacatur theories open after dismissing usury.

How this differs from Argus / Richmond / Yellowstone pages on this site

Page	Typical public record
Argus Capital lawsuit	Fourth Department pleading-stage affirmance where usury-as-loan and fraud theories survived dismissal
Richmond Capital lawsuit	NY AG Executive Law § 63(12) case plus related First Department opinions
Yellowstone Capital lawsuit / FTC refunds note	FTC enforcement and refund administration materials
This Reliable Fast Cash page	Richmond County Misc 3d dismissal of usury/fraud DJ claims with unjust enrichment surviving, plus a Kings County COJ-authority Slip Op

If your papers show Reliable Fast Cash as the plaintiff collecting under an RPA, do not assume TLC Homes’s dismissal posture is your posture. Read your index number and relief requested.

What to do if Reliable Fast Cash appears on your papers

Confirm the exact entity (Reliable Fast Cash, LLC or another caption name) and the county / index number.
If you see a confession of judgment, judgment by confession, or “ex parte” language, calendar counsel review immediately. Settlement-company sales scripts are not a substitute for vacatur deadlines or bankruptcy strategy.
Preserve the agreement, remittance history, any reconciliation request you sent, and the confession papers. TLC Homes turns heavily on payment history versus the judgment calculation; Raycom turns on who had authority to bind which entity.
Do not treat a Richmond County dismissal of someone else’s usury claim as proof your agreement is ironclad, and do not treat Raycom’s surviving vacatur counts as a template win rate.
If you are still pre-suit and exploring negotiated business-debt options, evaluate providers in writing. If a judgment, levy, freeze, or bankruptcy filing is already in play, start with licensed counsel in the relevant jurisdiction.

Soft dual options after that literacy check (negotiation path only; neither is a law firm):

Coastal Debt Resolve · Get a free review (Settlement CTA path used on this site, including the Coastal MCA Settlement Reviews landing page when that campaign is active)
Business Debt Insider review

FAQ

Did TLC Homes rule that every Reliable Fast Cash deal is a true sale?

No. It held that on that contract record, applying the LG Funding factors, the usury / disguised-loan declaratory theory failed and related fraud/DJ claims were dismissed with prejudice. Other agreements can look different on reconciliation, term, and bankruptcy recourse.

Does unjust enrichment mean the confession judgment was vacated?

No. The court only held the claim was adequately pleaded for discovery. Whether any balance is wrong, and what remedy follows, depends on the later record, not on this news summary.

Why does this page also mention Raycom?

Raycom is a published Kings County Slip Opinion involving the same funder name and confession-of-judgment mechanics, but focused on alleged lack of authority to bind co-owned entities. It is useful contrast, not a duplicate of TLC Homes.

Is this the same as the Richmond Capital AG case?

No. Richmond coverage on this site centers on People v. Richmond Capital Group and related First Department opinions. TLC Homes was decided in Richmond County Supreme Court as a private plenary action against Reliable Fast Cash, LLC.

Should I ignore a Reliable Fast Cash collection letter because of these opinions?

No. A dismissal in someone else’s case, or surviving claims in someone else’s case, does not pause ACH pulls, lawsuits, or judgment enforcement on your account.

Related funder lawsuit pages

Reliable Fast Cash's Kings County filings sit alongside other funders' cases in our MCA lawsuit tracker.

Sources checked October 27, 2026

Desk research only. We did not contact Reliable Fast Cash for this update, and we did not review any merchant’s private claim file. This is not a complete litigation search or a prediction about your case.

NY Courts reporter: Tender Loving Care Homes Inc. v. Reliable Fast Cash, LLC, 2022 NY Slip Op 22196
NY Courts reporter PDF: Raycom Program Ventures, Inc. v. Reliable Fast Cash, LLC, 2018 NY Slip Op 31946(U)
Internal contrast: Argus Capital lawsuit (usury survived dismissal on different reconciliation facts); Richmond Capital lawsuit (AG vs private county mix-up)

Takeaway

Treat “Reliable Fast Cash lawsuit” search intent primarily through TLC Homes: a published Misc 3d plenary decision that dismissed usury/fraud declaratory claims with prejudice after a purchase-versus-loan analysis, while keeping an unjust-enrichment fight over the confession-judgment balance alive for discovery. Pair that with Raycom only when your papers look like a COJ-authority / multi-entity vacatur dispute. Neither opinion is a statewide ban, an FTC refund story, or a substitute for reading your own caption.

Talk to our featured first provider

Request a free consultation from Coastal Debt Resolve. Confirm fees, service scope, and any legal representation in writing.

Get a free review

Also comparing providers? Read our Business Debt Insider review, and confirm any engagement terms directly with BDI.