The Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) is the federal legislation that was enacted to provide a special bankruptcy framework for Puerto Rico. 48 U.S.C. §§2101 et seq. An important component of PROMESA is the establishment of a Financial Oversight and Management Board (FOMB) with oversight authority over the financial affairs of Puerto Rico and sole authority over the Puerto Rico bankruptcy cases. 28 U.S.C. §§2121(b), 2121(d), and 2124(j)(1).

The FOMB has retained McKinsey and Company (McKinsey) as its strategic consultant. McKinsey is advising the FOMB on Puerto Rico’s debt restructuring. Mary Williams Walsh, McKinsey Advises Puerto Rico on Debt. It May Profit on the Outcome, The New York Times (Sept. 26, 2018). After McKinsey was retained, it was revealed that McKinsey, through its affiliates, holds at least $20 million of Puerto Rico’s debt. Id.