On Friday, the Illinois Department of Financial Professional Regulation - Division of Banking closed Midwest Bank and Trust Company, headquartered in Elmwood Park, Illinois, and appointed the FDIC as receiver.

The U.S. Court of Appeals for the Third Circuit, in In re Philadelphia Newspapers LLC,1 has ruled that secured creditors do not have a right, as a matter of law, to credit bid their claims when their collateral is sold under a plan of reorganization. The Third Circuit held that secured creditors may be barred from credit bidding where a debtor's reorganization plan provides secured creditors with the "indubitable equivalent" of their secured interest in the assets. The court's ruling follows a similar ruling last year by the U.S.

Today, the House Judiciary Committee’s Subcommittee on Commercial and Administrative Law held a hearing entitled “Ramifications of Auto Industry Bankruptcies; Part II.” Testifying before the committee was Ron Bloom, Senior Advisor, U.S. Department of Treasury.