The opportunity to make a substantial investment in a private company can be exciting — it offers the potential to share in the rapid growth of the company and may permit the investor to participate on the company’s governance team. But private company investing is not for the faint of heart as it also comes with significant risks.
These risks are not limited to the uncertainty of the company’s future business prospects, because once the investor delivers the funds, the majority owner’s full control of the company poses additional risks. Further, unless the minority investor is able to secure a contract exit, the majority owner will also control the investor’s ability to monetize his or her interest in the company. Unlike public company shareholders, investors cannot sell their shares or their units whenever they wish, because no market exists for them. In short, getting out of the business for investors is much harder than getting in, which is why they are wise to secure a path to an exit (the right to sell their interest) when making their investment. This post reviews some of the significant risks that minority investors face in making their investment, it considers protective measures investors can negotiate for to protect themselves, and it outlines legal claims that may be available if the majority owner engages in improper self-dealing.
The Post-Investment Risk Scenario
The majority owner will serve, invariably, in a management role as the company’s senior officer, as well as heading up its board or serving as the lead manager. In practice, this means that the owner is responsible for all major decisions in running the business. This unchecked power means that the majority owner can engage in self-dealing conduct in a variety of ways, including by entering into various interested (related party) transactions that favor the owner, by diverting business away from the company for the owner’s benefit, or by paying excessive salary and/or bonuses to the owner or the owner’s family members. In addition, the majority owner can elect to issue new shares in the company to third parties that require the minority investor to furnish additional capital to the business or become subject to dilution — which reduces the investor’s ownership percentage.
The investor likely lacks the power to block any actions taken by the majority owner, but if the investor openly expresses opposition, that can result in a vindictive response by the owner. Specifically, the majority owner can engage in squeeze-out or freeze-out tactics that may include removing the investor from any management role, terminating any compensated position that the investor holds in the business, cutting off all distributions, and effectively making the investor’s stake in the business worthless on a current basis unless or until the investor succumbs and sells out for a price well below the fair market value of the investor’s interest.
Protective Measures That Reduce Investment Risk
The potential risks the investor may be exposed to after making the investment, discussed in the previous section, can be mitigated to a large extent if the investor secures these protections in the governing documents before the investment is made. These contract protections are discussed below:
- The investor can insist on securing veto rights in the operating or shareholders agreement over key decisions made by the company’s management. These also are known as super-majority rights and cannot be taken unless they are approved by 85% of all shareholders, which applies if the investor holds 15% or more of the shares.
- Veto rights requiring approval may include making compensation changes above a certain percentage, adding new members or shareholders, taking on debt above a certain limit, selling the company or substantially all of its assets, removing the minority investor from a management role, and making any amendments to the governance documents.
- The final protective measure is for the minority investor to secure a buy-sell agreement as the exit mechanism that is available as a last resort. If the parties reach a point of impasse in their business relationship, the buy-sell provision gives the investor the contract right to require the company to purchase the investor’s interest for a value determined by an independent third party. We have written extensively about buy-sell agreements in previous posts.
Legal Claims Available for Improper Conduct by the Majority Owner
When a majority owner engages in conduct that is harmful to the business, that does not usually give rise to a direct action against the owner by the minority investor. This is due to the fact that the investor was not harmed directly and the injury was a decline in the value of the investor’s ownership interest in the business. For this reason, most investor claims must be made in a derivative capacity — the investor is required to bring the claims and seek relief in the name of the company. These derivative claims are governed by statute, and they are difficult to pursue successfully for shareholders and LLC members because they have to run the gauntlet created by the Texas Business Organizations Code (TBOC) (see TBOC Section 21.551 to 21.563 (corporate shareholders) and Sections 101.451 through 101.463 (LLC members)).
These statutory provisions create a number of procedural hurdles that shareholders and LLC members must surmount in bringing the derivative claim. These include the requirements that the investor must own the interest continuously from the time that the claim arose through completion of the litigation, demonstrating that the investor will fairly and adequately represent the company and, the most difficult of all, presenting the company with a written demand that specifies the act, error or omission that is the subject of the claim and requests the company to take suitable action(see TBOC Section 21.553(a)). Unless the company has suffered or will suffer irreparable injury, the shareholder cannot file a lawsuit against the fiduciary until the earlier of 90 days or a notice from the company that it has rejected taking the specific action that was called for by the shareholder’s demand letter.
If the directors or managers reject the shareholder’s or member’s demand, the trial court will consider in any lawsuit only whether the decision was made in good faith by directors (or managers) who are independent and disinterested, after conducting a reasonable inquiry. If the court determines that the decision was made in good faith, the derivative suit will be dismissed, and the shareholder will have no further recourse.
The three procedural hoops discussed above make it difficult for a shareholder or an LLC member to successfully prosecute a derivative lawsuit. Importantly, these requirements, do not apply to “closely held” companies (seeSection 21.563). A closely held company has fewer than 35 shareholders and is not listed on a public exchange. If the company is closely held, then the minority shareholder or member is not subject to the procedural requirements of establishing continuous ownership, proving fair and adequate representation, or issuing a written demand to the company before filing suit. Further, a shareholder or member in a closely held company who files a derivative lawsuit is permitted to recover legal fees if he or she can show that the proceeding resulted in a substantial benefit to the corporation.
In considering potential derivative litigation claims, minority investors need to be aware of the Texas Legislature’s passage of Senate Bill 29 last year, which amended the TBOC in ways that make it even more challenging for them to pursue claims for breach of fiduciary duties against company control persons, e.g., directors, managers and officers. Specifically, SB 29 eliminated the common law burden-shifting framework that previously applied to these claims, which had placed the burden on fiduciaries to demonstrate that they acted with fairness when engaging in self-interested transactions. The Legislature created a new affirmative pleading requirement: The plaintiff shareholder or member must now plead with specificity that the fiduciary’s conduct constituted fraud, intentional misconduct, an ultra vires act, or a knowing violation of law. If the company existed before Senate Bill 29 was passed, it must opt in to these requirements.
Outside of the derivative claim context, investors can pursue a breach of contract claim if they can establish that the majority owner or another control person at the company breached any of the terms contained in the company’s governance documents or in a shareholder agreement. Finally, investors can bring fraud claims if they can prove that they were fraudulently induced to make their investment by false statements made to them by the majority owner or others.
Conclusion
Investing in private companies has a strong potential upside, creating the opportunity for outsized returns from a fast-growing business. But this is a classic risk-reward scenario, because a private company investment often involves a degree of risk that far exceeds the investment in a public company. This is attributable to the majority owner’s largely unchecked control over the business, which brings to mind Lord Acton’s famous historical warning: “Power tends to corrupt, and absolute power corrupts absolutely.”
That assessment is unfair and inaccurate if applied to most private company majority owners, but majority control remains a risk factor. In exercising control, some majority owners will engage in self-dealing conduct causing economic harm to the company, will substantially dilute the investor’s stake in the business and will engage in squeeze-out tactics that place the investor in a difficult financial position without effective recourse.
In sum, an ounce of prevention is worth a pound of cure, and investors need to protect themselves before things go off the rails in their dealings with the company’s majority owner. This protection is secured by obtaining veto rights in the company’s governing documents or shareholder agreement and by securing a buy-sell agreement that will provide the investor with the right to sell the investor’s interest in the business. Absent these protections and without a buy-sell agreement in place, if the majority owner engages in an abuse of power, the investor will be left to seek legal relief against the owner by asserting derivative or other claims that are both procedurally challenging and expensive to pursue.



