Judge Chapman’s judgment is obviously a welcome development for participants in the structured capital markets, particularly those who transact regularly with US counterparties.

When faced with multiple class action threats, there is little downside in a company giving consideration to a creditors’ scheme of arrangement to achieve a quicker and cheaper resolution of the underlying claims.

Changes to Singapore's statutory regime for schemes of arrangement, which came into effect in May 2017, are aimed at placing Singapore on the map as an international debt restructuring hub.