Revlon Erroneous Payment Decision Reversed On Appeal

On September 8, 2022, the United States Court of Appeals for the Second Circuit reversed and remanded a ruling by the Southern District of New York that had allowed lenders to reap the benefits of Citibank's $1 billion mistake.

What you need to know

In August 2020, acting as agent under the $2 billion Revlon credit facility, Citibank intended to transfer Revlon's $8 million payment of accrued interest to the Revlon lenders when it accidentally included $900 million of its own money in payment of the outstanding principal amount. Citibank alerted the lenders of the mistake and sued those that refused to return the funds, arguing that equitable principles required the recipients of erroneous payments to return them.