The 79th Group: 79th Commercial Three Ltd (CM3) & 79th Luxury Living Five Ltd (LL5)

No Assets, Purpose, or Answers.

Loan Note Holders in 79th Commercial Three Ltd (CM3) and 79th Luxury Living Five Ltd (LL5) have now received the Joint Administrators’ Proposals. Buried beneath the legal formalities and dense terminology is a stark message: there’s nothing left. No assets or recoveries. No return for investors.

The reports, published by Kroll Advisory Ltd / Kroll (Gibraltar) Ltd and Quantuma Advisory Ltd, outline a bleak and unambiguous position:

• 79th Commercial Three Ltd (CM3): No business activity. No trading history. No assets. Its sole function appears to have been the issuance of loan notes.
• 79th Luxury Living Five Ltd (LL5) : Never traded. Established as a bare trust structure. No assets were acquired. No value ever materialised.

In both cases, the Administrators confirm that unsecured creditors will receive nothing. The Administration process has reached its end before it ever truly began.

Yet the absence of recoverable funds may not be the most troubling aspect of this story. Far more disturbing are the unanswered questions about how these appointments were made, and who stood to benefit from steering these companies into Administration.

Administration Without a Mandate?

Under the Insolvency Act 1986, Administration must serve one of three statutory objectives:

1. Rescue the company as a going concern
2. Achieve a better result for creditors than a liquidation
3. Realise property to benefit secured or preferential creditors

In the cases of 79th Commercial Three Ltd (CM3) and 79th Luxury Living Five Ltd (LL5) , none of these apply. There was no business to rescue. No operational model, or secured creditor structure. No value to unlock.

Which raises a pressing question:
Why weren’t these companies placed into compulsory liquidation, where investigatory powers are stronger, creditor oversight is greater, and outcomes are tested against the public interest?

That’s the route Insolvency & Law Ltd previously petitioned for, until the process was overtaken by administration applications made under the leadership of Crowell & Moring LLP, representing certain creditors.

“Creditor-Led” or Strategically Engineered?

The appointments of Robert Goodhew and Andrew Stoneman of Kroll Advisory have been described as “creditor-led.” But many Loan Note Holders say they were never consulted. Instead, unsolicited messages began arriving, from anonymous websites with unclear origins and opaque motives.

Several loan note holders report being contacted by Bond Review and Safe or Scam, which promoted the appointment of Kroll and the involvement of Paul Muscutt, a restructuring partner at Crowell & Moring LLP. These sites are not regulated in the UK, have no public directors, and offer no transparency around ownership, funding, or its management.

Yet somehow, they appeared to obtain and circulate the personal contact details of UK-based investors to influence a court-supervised process.

The Questions That Still Need Answers

If loan note holder contact data was used without proper authority, and if regulated firms and their practitioners relied on that data, directly or indirectly, it raises serious questions:

• How was the data sourced, and by whom?
• Was any of it shared with Crowell & Moring or Kroll, or used in support of their applications?
• Were proper consents in place at the time investors were contacted?

These are not technicalities. If client data was processed or distributed unlawfully, the implications would extend across multiple regulatory regimes, including:

• The Solicitors Regulation Authority (SRA) Code of Conduct
• UK GDPR (data protection and privacy)
• SRA transparency rules on referral arrangements and financial interests

Would the Court Have Approved the Appointments If It Knew?

That question now casts a shadow over the entire process. If loan note holder support for administration was influenced by data that was improperly obtained, or by entities with undeclared relationships, would the court still have signed off on these appointments?

Thus far, no findings of wrongdoing have been made against Crowell & Moring LLP, Kroll, or any individuals involved. But without clear answers, these events risk undermining confidence in both the legitimacy and independence of the administration process.

If those involved are confident in their conduct, they should refer the matter to their own regulators:

• Crowell & Moring LLP to the Solicitors Regulation Authority (SRA)
• Kroll Advisory to the Insolvency Practitioners Association (IPA)
• And both firms to the Information Commissioner’s Office (ICO)

Until then, the silence will only grow louder.

A Familiar Pattern: History Repeating Itself?

For many Loan Note Holders, the collapse of 79th Commercial Three Ltd (CM3) and LL5 feels like déjà vu.

Back in the case of High Street Group Ltd, Insolvency & Law Ltd pushed for compulsory liquidation, believing it offered a more transparent route to uncover misconduct. But that option was bypassed. The company entered administration instead.

Nearly three years later, more than £1 million in fees had been charged against the estate, the promised recoveries never materialised, and the Administration eventually collapsed, ending with Compulsory Liquidation under the Official Receiver.

Three years of delays. Millions in fees. And not a single pound returned to the Loan Note Holders who paid for the whole thing.

Now, with The 79th Group, the same playbook appears to be in motion. This time, anonymous operators such as Safe or Scam were active from the outset, pushing creditor support toward administration, rather than liquidation.

Who Benefits?

It’s difficult to argue that the current process is serving Loan Note Holders.

The only guaranteed winners so far are the professionals billing from the pot meant for creditors. The Loan Note Holders made this Administration possible. But what they’ve received in return is little more than silence, and a growing stack of invoices they’re unknowingly funding.

Administrative Dysfunction

Even among the Joint Administrators, the facade is breaking down.

In its latest update, Grant Thornton, appointed to 79th Luxury Living Six Ltd, openly distanced itself from Kroll Advisory and Quantuma. It described 79th Group’s business model as bearing the hallmarks of a Ponzi scheme, and expressed frustration at a lack of cooperation from the other Administrators and their legal representatives, Crowell & Moring LLP.

Grant Thornton also alleges that a survey was circulated intended to undermine its role, without consultation, stirring division and confusion among Loan Note Holders.

This isn’t just professional disagreement. It’s systemic dysfunction, happening on Loan Note Holders’ time, and on Loan Note Holders’ dime.

Why Is Insolvency & Law Being Shut Out?

Insolvency & Law Ltd holds creditor status by legal assignment, meaning Loan Note Holders have transferred their claims for the purpose of lawful enforcement. Yet Kroll Advisory continues to reject these claims outright, based on its interpretation of restrictive “no transfer” clauses in the loan note documents.

That stance has the effect, deliberate or not, of excluding one of the only parties willing to question the process, challenge assumptions, and press for accountability.

This exclusion shields the process from scrutiny. And it leaves Loan Note Holders with fewer avenues for meaningful representation.

The Questions That Won’t Go Away

• What statutory purpose is this Administration truly serving?
• What value, if any, is being delivered to Loan Note Holders?
• How much more will be spent before the process collapses under its own weight?

There’s no business to rescue. No assets to distribute. And no progress toward recovery. Whatever this Administration is doing, it is not protecting the people who funded it.

Where We Stand

Insolvency & Law Ltd is:

• Continuing to pursue transparency
• Investigating the conduct of all parties involved
• Exploring potential action against regulated professionals and their indemnity insurers

We operate through lawful assignments, in our own name. We bear the cost and risk ourselves, because someone has to stand up to this.

If You’re Still Waiting for Answers

If your data was used without consent, or if your questions about this process remain unanswered, this is the time to speak.

 investigations@insolvencyandlaw.co.uk
020 7504 1300

Disclaimer:
Logos used in this post are for identification and commentary purposes only. Insolvency & Law Ltd is not affiliated with, endorsed by, or acting on behalf of any company named. Use is permitted under fair dealing provisions for reporting, criticism, and matters of public interest.

Disclaimer: Insolvency & Law Ltd is not a firm of solicitors or licensed insolvency practitioners and does not provide legal advice, investment advice, or any regulated services under the Legal Services Act 2007 or the Financial Services and Markets Act 2000. All content published by I&L relating to The 79^th Group, including blogs and podcasts, is provided free of charge for general information and educational purposes only and must not be relied upon as professional advice.
Where appropriate, I&L may take legal assignment of loan notes issued by The 79^th Group companies in its own name, for the purpose of enforcement and recovery. In such cases, I&L bears all associated costs and risks, and the original Loan Note Holder is fully insulated from legal expense and liability.