A senior legal source says the estate of former All Black Jock Hobbs could be included in a civil case if the financial markets watchdog goes ahead with legal action against Strategic Finance.
Hobbs, a founder and director of Strategic, died on Tuesday after a six-year battle with leukaemia.
Strategic struck trouble in 2008 and was placed into a moratorium owing over $400 million to 13,000 investors, many of whom were elderly.
It has since gone into receivership. So far secured debenture holders have received just 7c in the dollar, equating to $26 million.
Last week the receivers said another small payment was likely to be made in April.