re: Trump owes lenders $450 million yet there were no complaints from the lenders.

You would think so and I don't think that the federal statutes have anything to say on the matter. But NY law is vastly different as it applies to things like this apparently. The state feeling like it should protect against fraud does not necessarily require a non state complaintant. It can be ostensibly enforcing the common good. It's a money grab, of course and it has seldom if ever been used.