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Entitled to Stay Relief? Prove it.

For example, you make a commercial real estate loan and record your deed of trust. The borrower pays you for a time but then defaults.  You tried loan forbearance and modification, but it was unsuccessful. The borrower falls...more

Risky Business: Distressed Companies and Payments in the Shadow of Bankruptcy

A hallmark of bankruptcy law is equal treatment of similarly-situated creditors. The Bankruptcy Code frowns upon a debtor who, while insolvent, pays some creditors but not others in the run-up to bankruptcy – whether...more

Shocker! Fraudulent Transfer Leads to Judgment Against Transferee

The 16th Century gave plenty to the world – Leonardo da Vinci's "Mona Lisa," the Scientific Revolution, the Protestant Reformation, Michaelangelo's "David," and the Statute of Elizabeth.  That last one may be a...more

The Perils of Over-Lawyering in Bankruptcy

For a lender in bankruptcy, the best situation is to be an over-secured creditor, meaning the value of your collateral exceeds your debt.  A creditor in this exalted category can recover principal, interest (including...more

Can I Require a "True Up" in a Subchapter V Plan of Reorganization?

For creditors, it can be difficult to navigate the financial difficulties of your customers. It seems like it would only get worse in bankruptcy, but that is not always the case.  Subchapter V of Chapter 11 of the Bankruptcy...more

Charging Order Limitations – You Can't Charge What They Don't Own

In North Carolina, a creditor who obtains a judgment against an individual with an ownership interest in a limited liability company or limited liability partnership may enforce its unsatisfied judgment by petitioning the...more

Don't Disrespect the Receivership

A recent decision by the North Carolina Business Court highlights the risks of interfering with property that is part of a receivership estate. The North Carolina Commercial Receivership Act celebrated its three-year...more

How to Get Your Own "Free" Private Investigator in Bankruptcy

Subchapter V of Chapter 11 of the Bankruptcy Code, which turned three earlier this year, created a more streamlined and less expensive Chapter 11 reorganization path for small business debtors. It also created a new position...more

Secured Lender Duffs Golf Course Valuation Hearing

In Chapter 11, value is king.  Secured creditors have rights in proportion to the value of their collateral.  When a secured creditor and the debtor can't agree on value, appraisals and appraiser testimony become...more

Fourth Circuit Says "Do the Math" For Attorneys' Fees Awards

In North Carolina, a loan agreement can require a borrower to pay attorneys' fees upon default to reimburse the lender for collection expenses....more

No Discharge for Bonnie, No Discharge for Clyde.

The Bankruptcy Code generally allows a debtor to wipe out all pre-bankruptcy debts and get a fresh start in life.  But not all debts are equal.  Some debts can't be discharged, meaning they survive bankruptcy, and the...more

In Foreclosure, Your Attorney Can Be Counsel or Trustee, But Not Both

Five years ago, the General Assembly amended the foreclosure statute to prohibit an attorney who serves as trustee or substitute trustee from representing the noteholder or the borrower during a foreclosure proceeding. ...more

"My Lawyer Made Me Do It" is Not an Absolute Defense to Bankruptcy Court Sanctions

Last year, we offered a lesson and a moral from a North Carolina district court decision reversing a $115,000 sanctions order by a North Carolina bankruptcy court.  The lesson from the case was that the bankruptcy court...more

More Bad News for Non-Debtors Seeking Releases in Chapter 11

In January, we wrote about the Purdue Pharma mega-bankruptcy.  A United States District Court in New York vacated Purdue Pharma's confirmed Chapter 11 plan, holding it was improper for the plan to contain non-consensual...more

Can I Hold a Debtor’s Bank Account Hostage?

For creditors dealing with debtors in the shadow of bankruptcy, a common scenario repeats itself.  The creditor repossesses collateral, attaches an account, or sets off a bank account, and then the debtor files a...more

Use Clarity to Avoid Contempt in Bankruptcy

This is a story about contempt and clarity - It comes to us from a July 2021 North Carolina district court decision reversing a $115,000 sanctions order by a North Carolina bankruptcy court. The story offers a lesson and...more

Congress Extends Higher Debt Ceiling for Small Business Bankruptcies

We previously informed you that if you are a small business that needed to file bankruptcy to save your company, then you may be able to take advantage of Subchapter V of Chapter 11 of the Bankruptcy Code. The new...more

What Do You Get When You Cross a $137,000 Cartier Necklace and a Debtor With Selective Amnesia? A Chapter 11 Trustee.

When a debtor files bankruptcy under Chapter 11, the bankruptcy court does not automatically appoint a trustee. Unlike Chapter 7, where the court appoints a trustee to investigate the debtor's assets, liquidate assets, and...more

Can a Business Owner Reorganize Guaranty Obligations Under Subchapter V?

We have previously informed you that if you are a small business that needed to file bankruptcy to save your company, then you may be able to take advantage of Subchapter V of Chapter 11 of the Bankruptcy Code. The new...more

40,979 Reasons Not to "Press Charges" Against a Debtor in Bankruptcy

It is a cardinal sin to attempt to collect a debt or repossess collateral after a borrower files bankruptcy. Bankruptcy triggers the automatic stay – a command, not a suggestion, that collection activity ceases. This is a...more

Can a Debtor Choose Salvation Over Creditors?

In a Chapter 13 bankruptcy, debtors propose a plan to re-pay all or a portion of their debts. The amount to be repaid depends on how much the debtors earn, the amount and types of debt owed, and how much property they own....more

Supreme Court Rules "Now or Never" to Appeal Stay Relief Denials

Under the Bankruptcy Code, filing a bankruptcy petition automatically halts efforts to collect pre-petition debts from the debtor outside of bankruptcy. This is the "automatic stay," and it is a command, not a suggestion....more

Harley-Davidson Dealer Violates Automatic Stay, Goes from Creditor to Judgment Debtor

If you lend money, you know – or should know – it is a cardinal sin to collect a debt or repossess collateral after a borrower files bankruptcy. Bankruptcy triggers the automatic stay – a command, not a suggestion, that...more

Is it Time to Re-Write Your Attorney's Fees Provision?

Bankruptcy court is not the first place that comes to mind when a lender thinks about full recovery on a loan. Usually, debtors file bankruptcy because they can't pay all their creditors in the ordinary course of business....more

Supreme Court Sets Standard for Bankruptcy Discharge Violations

When your customer is in bankruptcy, there are two major no-nos that you must remember. First, don't violate the automatic stay, which prevents a creditor from attempting to collect a debt while the debtor is in bankruptcy...more

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