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“Recapping” and Reconciling Merit Management and Nine West, the Second Circuit Holds That Boston Generating’s 2006...

Until recently, two of the most important cases interpreting the Bankruptcy Code’s “safe harbor” provisions appeared to be in potential tension. First, in the U.S. Supreme Court’s 2018 Merit Management decision, the Supreme...more

KYC – “Know Your Customer,” or Agent, or Financial Institution, to Qualify for the Bankruptcy Code Safe Harbors

Parties structuring certain financial transactions to comply with the Bankruptcy Code safe harbor provisions, including protections from the avoidance powers in Section 548 of the Bankruptcy Code, must be cognizant of recent...more

Eighth Circuit Follows Second Circuit and Affirms Broad Safe Harbor Protections for Bank Customers

In Kelley v. Safe Harbor Managed Account 101, Ltd., the Eighth Circuit Court of Appeals endorsed a broad view of parties protected from avoidance claims related to certain derivative and financial contracts (“QFCs”),...more

Second Circuit’s Lehman Flip Clause Decision Continues the Expansion of the Bankruptcy Code Safe Harbors

On August 11, 2020, the United States Court of Appeals for the Second Circuit affirmed lower court decisions rejecting Lehman Brothers Special Financing Inc.’s (“LBSF”) attempt to recover nearly $1 billion in payments to...more

No, You’re a Customer: Recent Second Circuit Decision Circumscribes Merit and Preempts State Law Impairment of Safe Harbor...

On December 19, 2019, the United States Court of Appeals for the Second Circuit (the “Second Circuit”) affirmed a ruling of the United States District Court for the Southern District of New York (the “District Court”)...more

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