Earlier today, the Securities and Exchange Commission charged Patriarch Partners and its founder, Lynn Tilton, with defrauding investors to the tune of $200 million. According to the regulator, Patriarch lied about the value of underlying loans of three collateralized loan obligations: Zohar I, II and III. Obviously, we're a long way off from a punishment, if there is any, for Tilton and the firm, which has vowed to "vigorously defend [itself] against the SEC’s allegations." But, just as an exercise, let's look down the road. Say a punishment is deemed right and necessary-- Tilton is a billionaire, so a financial penalty would make but a dent in her net worth. As for prison time, it seems unlikely in a case like this.1 So what, then, would be a potentially appropriate sentence? Let's look to Tilton herself for some ideas.
* She could be banned from doing Jello shots and covering herself in whipped cream for a period of 3-5 years: Tilton offered her male employees a choice: They could take a Jell-O shot off her stomach or lick whipped cream off her breasts. “The crazy part was, she saw it as morale building,” says one person present. “People were hiding in the bathroom.”
* ...or given strict instructions that any men she encounters are to stay upright and clothed at all times: "You must be mistaken," she shot back. "It's only men that I strip and flip. My companies I hold long and close to my heart."
* The government could seize her whip, handcuff, and dagger collection, as well as come up with a rule that states she's not allowed to pose for photos on the hood of any luxury vehicles (jalopies are okay): The walls are filled with whips and handcuffs sent to her by friends, Hashemite daggers given to her by Middle Eastern royals, New Age paintings and a portrait of her stretched across the hood of a black Mercedes.
* She could be sentenced to a lifetime of wearing flats or those sneakers women donned in the 80s while commuting: "I'm wearing a Cavalli top, a Versace belt, a Gucci skirt, and I believe Prada boots," she explains, throatily. She is also wearing four-inch stilettos. "I need to look sufficiently fierce to make sure that I garner the respect that I deserve."
* Or banned from telling her go-to, oft-repeated joke: “There are three universal lies: Margins are weak, but we’ll make it up in volume; the check’s in the mail; and I won’t come in your mouth.”
* And, if the SEC is really hellbent on hurting her? No more Christmas cards to clients, not even the ones on her "good" list.: For many years I had men asking me on the phone each day what I was wearing and what color my underwear was, so I sent out a Christmas card with me in a red lace sort of teddy, and red cowboy boots and a Santa hat, wishing them a Merry Christmas.
Earlier: Lynn Tilton Bares All; This Is A Story About Lynn Tilton’s Employees Doing Jello Shots Off Her Rack; Step Into Lynn Tilton’s Office; Lynn Tilton’s Unique Take On Trust Falls May Cause Side Effects; Lynn Tilton: Never Apologize For Sending Near-Naked Christmas Cards To Your Clients And Friends On Wall Street
1. That's an uneducated guess, I actually have no idea but it feels right.↩