Contrarian Corpus
short seller research note follow up
2019-08-13 · 13 pages

Burford Capital BUR

Burford's rebuttal confirms it: aggressive mark-to-model fair-value gains, manipulated ROIC/IRR, and a CEO-CFO marriage make BUR an Enron-style stock promotion the FCA should investigate.

N 4 Narrative
V 2 Visual
C 1 Craft
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Thesis

Muddy Waters' follow-up rebuts Burford Capital's response to its August 7 short report, arguing the response was distraction not refutation. Carson Block reiterates that BUR aggressively marks litigation assets up under IFRS 9, then engineers non-IFRS ROIC and IRR metrics to justify those fair-value gains and raise hundreds of millions in retail bonds and equity. He cites the Napo/Jaguar case where BUR booked a 113% ROIC in 2013 only to deliver a final 18% ROIC and 3% IRR after an Invesco-led bailout, and argues 52% of core litigation assets are now Fair Value Gains, including a likely fully-marked Petersen. With the CFO married to the CEO and a board no longer deemed independent, BUR has no guardrails, evoking Enron and Noble Group's mark-to-model collapses.

SCQA

Situation

Burford Capital is a UK-listed litigation finance pioneer that grew rapidly by funding lawsuits and reporting non-IFRS ROIC and IRR metrics, raising hundreds of millions of pounds in retail bonds and equity.

Complication

BUR's growth is fueled by aggressive IFRS 9 fair-value markups, self-defined return metrics, and a governance vacuum (CFO married to CEO, no independent directors), echoing Enron and Noble Group's mark-to-model collapses.

Resolution

The UK FCA should investigate BUR's Napo conduct, ROIC/IRR presentation, and Petersen marks; BUR should disclose Gross Fair Value Gains since 2012, reconcile cash flows, and release compensation history.

Reward

Forced disclosure and an FCA inquiry would expose the gap between accounting profits and cash, validate the short, and re-rate BUR sharply lower as the mark-to-model premium collapses.

The three reasons

  1. 1

    BUR aggressively marks cases up to generate non-cash fair-value profits, Enron-style

  2. 2

    Non-IFRS ROIC and IRR metrics are self-defined and manipulated to justify capital raises

  3. 3

    Fragile balance sheet with no guardrails: CFO is married to the CEO and board is ossified

Primary demands

  • FCA should investigate BUR's conduct in Napo and its presentation of return metrics
  • BUR should disclose where Petersen is marked as of H1 2019
  • BUR should disclose all Gross Fair Value Gains by period since 2012 and going forward
  • BUR should reconcile cash flows to its investment performance table for historical and future periods
  • BUR should release its compensation history for Bogart and Molot
  • BUR should install real governance guardrails (independent CFO and directors)

KPIs cited

Expense ratio on invested capital
~9% currently vs. 2% management fee under original closed-end-fund structure
Napo (2011 vintage) reported ROIC
Booked at 113% in 2013 annual report; raised to 195% by end-2017; final outcome ~18% ROIC and 3% IRR
Napo reported IRR
104% IRR booked in 2013 vs. eventual 3% IRR after Invesco-led bailout
Retail bond raises
£90m (2013), £100m (2016), £175m (June 2017), £310m equity (2018), all referencing 2011 vintage performance
Fair Value Gains share of core litigation assets
Management confirmed 52% of core litigation assets are Fair Value Gains (~108% ROIC already recognized)
Cash flow vs. investment performance discrepancy
2018 cash proceeds $596m vs. $254m of recoveries implied by performance table
Non-Level 3 share of investment additions
31% in 2018 vs. 12% in 2017; non-Level 3 realizations 14% in 2018 vs. 0% in 2017
Average employee comp (LTM)
Approximately $570,000 per employee, with Bogart/Molot pay undisclosed

Pattern membership

Where this document fits across the library's 12 rhetorical / structural patterns.

Precedents cited

  • Enron (mark-to-model gains financed by debt)
  • Noble Group (Level 2 valuation abuse, collapse)
  • Orient Paper (Muddy Waters first short, 2010)
  • Sino-Forest (Muddy Waters short, fraud, de-listed 2011)
  • Noble Group response (Muddy Waters short, 2015, bankrupt)
  • IQE (Muddy Waters short, 2018, -48%)

Notable slides (4)

Notes

Follow-up rebuttal note (Aug 13, 2019) to Muddy Waters' initial Burford short of Aug 7, 2019, responding to BUR's two-hour conference call defense led by Chris Bogart and director John Lazar. Pure prose memo in Word/Times Roman style with extensive footnotes (35 cites) and embedded screenshots of competitor (IMF Bentham, LCM) accounting policies as evidentiary contrast. Memorable rhetorical devices: 'sprinting on a treadmill' metaphor for fair-value-driven growth, 'cockroaches in plain sight' line on metric manipulation, and a closing comparison table of denial-then-collapse responses from prior MW targets (Orient Paper, Sino-Forest, Noble Group, IQE). Heavy governance attack: notes BUR's CFO is Chris Bogart's wife. No price target or quantified upside disclosed; thesis is qualitative + regulatory. Stake size not disclosed in this document.