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.

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Last week the receivers said another small payment was likely to be made in April.

A spokesman for the Financial Markets Authority yesterday confirmed its investigations into Strategic were ongoing.

He said it did not comment on open cases.

Hobbs was one of six company directors for Strategic alongside Graham Jackson, Marc Lindale, Denis Thom, David Wolfenden and former chief executive Kerry Finnigan.

The source said it was possible to include a deceased estate in a civil case. But it would be up to the FMA to decide whether to include Hobbs' estate in any possible proceedings.

Hobbs, a former chairman of the New Zealand Rugby Union, was a key instigator in securing the right to host the Rugby World Cup.

Strategic's money helped to fund a range of property developments including Neville Mahon's Fiji Beach Resort & Spa managed by Hilton. The company was behind several Pacific properties, including three Rarotonga resorts.