By now, most lenders and their counsel have heard about the February 16, 2021 decision of the U. S. District Court for the Southern District of New York in Citibank N.A. v. Brigade Capital Management, L.P, which held that certain lenders to Revlon who received payments by mistake from Citibank were in fact entitled to keep those payments. 

The magnitude of the funds transferred is just one of the eye-catching elements of the case.  On August 11, 2020, Citibank, which had been the agent for a syndicate of term lenders to Revlon, mistakenly transferred approximately $900 million to a group of the lenders.  According to Citibank, it had intended to send a much smaller amount, around $7 million, solely to cover an interest payment then due on the loans, but a problem with its loan processing system resulted in the overpayment.  Typically, you would expect lenders receiving the money by mistake just to return it—after all, you never know when you might be the one mistakenly sending the money.  And, in fact, a number of the lenders did just that—but one group, did not.