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Debtors Cramdown

Jones Day

Revisiting Singapore's Corporate Restructuring and Insolvency Regime: Cross-Class Cramdown in Schemes of Arrangement

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On March 11, 2025, the Committee to Enhance Singapore's Corporate Restructuring and Insolvency Regime (the "Committee") published a report (the "Report") outlining its recommendations to further enhance and modernize...more

Latham & Watkins LLP

Cram-across: Sino-Ocean Restructuring Plan Makes Waves

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The evolution of the English RP continues to push the jurisdictional envelope. The English court’s sanction of the Sino-Ocean restructuring plan (RP) marks an interesting development in the evolution of the English RP....more

Jones Day

Cramdown of Equity in Chapter 11 Plan Requires Assessment of Equity's Value to Satisfy "Fair and Equitable" Standard

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Chapter 11 plans that propose to extinguish existing equity interests because the estate does not have any value remaining after the payment of creditor claims are common. The Bankruptcy Code's "absolute priority rule"...more

Jones Day

Business Restructuring Review Vol. 23 No. 6 - November–December 2024

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Hertz: Third Circuit Weighs In On Make-Whole Premiums And The “Solvent-debtor Exception” In Chapter 11 Cases - A handful of recent high-profile court rulings have considered whether a chapter 11 debtor is obligated to pay...more

Jones Day

Hertz: Third Circuit Weighs in on Make-Whole Premiums and the "Solvent-Debtor Exception" in Chapter 11 Cases

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A handful of recent high-profile court rulings have considered whether a chapter 11 debtor is obligated to pay postpetition, pre-effective date interest ("pendency interest") to unsecured creditors to render their claims...more

Mayer Brown

Adler: Court of Appeal sets aside sanction of a Restructuring Plan

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In the first appeal of a restructuring plan under Part 26A Companies Act 2006, the English Court of Appeal unanimously set aside the first instance decision sanctioning the plan proposed by AGPS BondCo PLC, part of the Adler...more

Tonkon Torp LLP

The Eighth Circuit’s Topp Decision Adds Flexibility to Cramdown Interest Rate Calculations

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The Eighth Circuit recently weighed in on the issue of how to determine appropriate cramdown interest rates for secured creditors in Chapter 11 bankruptcy plans under Section 1129 of the Bankruptcy Code....more

Goodwin

Till We Meet Again: Eighth Circuit Weighs in on Appropriate Interest Rate in a Cramdown

Goodwin on

Much has been written about how to calculate the appropriate interest rate for the deferred cash payments a debtor may propose to pay to a rejecting secured creditor under a “cramdown” Chapter 11 plan to meet the “fair and...more

Kennedys

Bermuda: Restructuring & Insolvency 2022

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1 Overview - 1.1 Where would you place your jurisdiction on the spectrum of debtor- to creditor-friendly jurisdictions? Bermuda is a self-governing British Overseas Territory. The systems of law administered in...more

Latham & Watkins LLP

UK and European Restructuring Tools: Choosing the Optimal Forum for Creditor and Shareholder Cramdown

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Debtors and investors have an enhanced choice of restructuring venues as the EU Restructuring Directive is rolled out in Member States - A number of key European jurisdictions have now implemented the EU Preventive...more

Latham & Watkins LLP

France Publishes Restructuring and Insolvency Law Reform Ordinance

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Ordinance 2021-1193, which effects into law the European Directive on preventive restructuring frameworks, applies to proceedings opened from 1 October 2021. Key Points: ..Certain preventive mechanisms are...more

McDermott Will & Emery

Special Report - Out-of-Court Restructuring Alternatives in the European Union, Germany and the United States - November 2020

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The Coronavirus (COVID-19) pandemic has had a huge impact on the global economy and most businesses, creating thousands of companies with urgent restructuring needs. Restructurings are ideally carried out early, quietly, and...more

A&O Shearman

Rough Justice: Third Circuit Holds in Tribune That a Cramdown Plan May Discriminate—But Not Unfairly—By Reallocating a Portion of...

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On August 26, 2020, the Court of Appeals for the Third Circuit held that the Bankruptcy Code does not require subordination agreements to be strictly enforced in order for a court to confirm a cramdown plan, so long as the...more

Jones Day

In Brief: On Remand, Momentive Bankruptcy Court Rules That Cramdown Notes Should Bear "Process Efficient" Market Interest Rate

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In Momentive Performance Materials Inc. v. BOKF, NA (In re MPM Silicones, L.L.C.), 874 F.3d 787 (2d Cir. 2017), cert. denied, 138 S. Ct. 2653 (2018), the U.S. Court of Appeals for the Second Circuit affirmed a number of lower...more

Perkins Coie

In re Fagerdale USA-LOMPOC Inc.: Defensive Purchase of Claims to Avoid Cramdown Deemed Not “Bad Faith”

Perkins Coie on

A secured lender facing the prospect of having the essential provisions of its loan re-written in a Chapter 11 plan of reorganization will look for options to prevent or minimize the likelihood of such a revision. Chapter 11...more

Sullivan & Worcester

Lenders Beware: The 9th Circuit Dilutes Voting Power in Multi-Debtor Cases (In re Transwest Resort Properties Inc.)

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Courts are often faced with the situation in which affiliated debtors file for Chapter 11 reorganization and request to have their cases jointly administered. While joint administration does not, without more, cause...more

Patterson Belknap Webb & Tyler LLP

One and Done. Cramdown Requirement for an Impaired Assenting Class Applies on a Per-Plan, Not a Per-Debtor, Basis.

Confirmation of a Chapter 11 plan of reorganization generally requires the consent of each impaired class of creditors. But, upon satisfaction of additional statutory requirements, a plan proponent can obtain confirmation of...more

Hogan Lovells

Impact of Second Circuit’s Momentive decision on interest rates under Chapter 11

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The Second Circuit recently issued its decision on an appeal to the Momentive Performance Materials Inc. (“MPM”) bankruptcy case. Amongst other issues, the Court found that when determining the appropriate interest rate in a...more

Jones Day

Second Circuit Issues Key Cramdown Interest Rate Ruling

Jones Day on

In Momentive Performance Materials Inc. v. BOKF, NA (In re MPM Silicones, L.L.C.), 2017 BL 376794 (2d Cir. Oct. 27, 2017) ("Momentive"), the U.S. Court of Appeals for the Second Circuit, in a long-anticipated decision,...more

Patterson Belknap Webb & Tyler LLP

Second Circuit Addresses Key Chapter 11 Plan Issue

It is a unique characteristic of debt restructuring under Chapter 11 of the Bankruptcy Code that a majority of a class of creditors can accept a modification of the terms of the debts owed to the class members, as provided in...more

BakerHostetler

Second Circuit: Secured Lender Not Entitled to a Make Whole Premium in “Cramdown” Restructuring, But May Be Entitled to Higher...

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On October 20, in Matter of M.P.M. Silicones, L.L.C. (“M.P.M. Silicones”), the United States Court of Appeals for the Second Circuit held that secured noteholders were not entitled to an approximately $200 million make-whole...more

Jones Day

Second Circuit Rules on Chapter 11 Cram-Down, Make-Whole, and Subordination Issues

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The Situation: In In re MPM Silicones, L.L.C., secured noteholders argued that replacement notes distributed to them under a cram-down chapter 11 plan should bear market-rate interest rather than the lower formula rate...more

Robinson & Cole LLP

Cramdown Interest Rate Best Set Based on Market Rates

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The Bankruptcy Code permits cramdown of a secured creditor but requires that the secured creditor receive deferred cash payments at least equal to the value of its collateral. This means that installment payments to the...more

Jones Day

Ninth Circuit Reverses Course on Measure of Collateral Value in Cramdown Confirmation of Chapter 11 Plan

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In First Southern Nat’l Bank v. Sunnyslope Hous. LP (In re Sunnyslope Hous. LP), 2017 BL 216965 (9th Cir. June 23, 2017), the U.S. Court of Appeals for the Ninth Circuit held en banc that, in determining whether a chapter 11...more

Ruder Ware

Recent Bankruptcy Decision from the Western District of Wisconsin Discusses Negative Equity, Car Loans, and the Chapter 13 Cram...

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A quick introduction for those of you who are not bankruptcy nerds. For certain types of collateral, Chapter 13 allows a Debtor to reduce a secured creditor’s claim down to the value of the collateral. This is called “cram...more

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