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    A few additional thoughts… on the regulatory response in the wake of the FTX bankruptcy
    2022-12-07

    We recently had a chance to speak to The Independent and

    Filed under:
    USA, Banking, Capital Markets, Derivatives, Insolvency & Restructuring, IT & Data Protection, Reed Smith LLP, Bitcoin, Cryptocurrency, US Securities and Exchange Commission, Consumer Financial Protection Bureau (USA), Commodity Futures Trading Commission (USA), US Congress
    Authors:
    J.H. Jennifer Lee , Mark E. Bini
    Location:
    USA
    Firm:
    Reed Smith LLP
    Fifth Circuit Triples Down: Filed-Rate Natural Gas and Power Contracts Can Be Rejected in Bankruptcy Without FERC Approval
    2022-12-05

    In Gulfport Energy Corp. v. FERC, 41 F.4th 667 (5th Cir. 2022), the U.S. Court of Appeals for the Fifth Circuit tripled down on its nearly two-decades-long view that filed-rate contracts regulated under the National Gas Act (the "NGA") and the Federal Power Act (the "FPA") can be rejected in bankruptcy without the consent of the Federal Energy Regulatory Commission ("FERC"). Reaffirming its previous rulings in In re Mirant Corp., 378 F.3d 511 (5th Cir. 2004), and In re Ultra Petroleum Corp., 28 F.4th 629 (5th Cir.

    Filed under:
    USA, Energy & Natural Resources, Insolvency & Restructuring, Litigation, Jones Day, FERC, US Congress, United States bankruptcy court, Fifth Circuit
    Authors:
    Paul M. Green , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    Fifth Circuit Embraces Flexible Approach to Countryman Test of Executoriness in Bankruptcies Involving Multiparty Contracts
    2022-12-05

    Whether a contract is "executory" such that it can be assumed, rejected, or assigned in bankruptcy is a question infrequently addressed by the circuit courts of appeals. The U.S. Court of Appeals for the Fifth Circuit provided some rare appellate court-level guidance on the question in Matter of Falcon V, L.L.C., 44 F.4th 348 (5th Cir. 2022). The Fifth Circuit affirmed lower-court rulings determining that a surety contract was not executory because the surety had already posted irrevocable surety bonds and did not owe further performance to the debtors.

    Filed under:
    USA, Company & Commercial, Insolvency & Restructuring, Litigation, Jones Day, National Labor Relations Board (USA), US Congress, Supreme Court of the United States, United States bankruptcy court, Fifth Circuit, Third Circuit
    Authors:
    Dan B. Prieto , Mark G. Douglas
    Location:
    USA
    Firm:
    Jones Day
    FTX Bankruptcy—What Could Be Next for the Industry?
    2022-11-30

    One of the world’s largest cryptocurrency exchanges—FTX Trading Ltd.—and many of its affiliates filed for bankruptcy earlier this month.1 While the full impact of the FTX bankruptcy is not yet clear, various responses from the executive branch and federal and state regulators indicate that, in the short term, agencies will continue to use their existing authorities to seek information about the practices of crypto market participants and to enforce existing rules to protect customers and avoid further market contagion.2 The following statements may indicate what market

    Filed under:
    USA, Banking, Insolvency & Restructuring, IT & Data Protection, Wilmer Cutler Pickering Hale and Dorr LLP, Bitcoin, Due diligence, Cryptocurrency, US Securities and Exchange Commission, FINRA, Commodity Futures Trading Commission (USA), Federal Deposit Insurance Corporation (USA), US Congress, National Futures Association (USA)
    Authors:
    Yoon-Young Lee , Tiffany J. Smith , Matthew B. Kulkin , Michael Held , Susan Schroeder , Eliza Gonzalez
    Location:
    USA
    Firm:
    Wilmer Cutler Pickering Hale and Dorr LLP
    “It’s So Hard to Say Goodbye…”: Judge Drain Bids Farewell to Bench By Urging Congress to Curtail Section 546(e) Safe Harbor
    2022-11-21

    Four years after New York grocery chain Tops’ exit from Chapter 11, U.S. Bankruptcy Judge Robert Drain ruled that the Tops’ Chapter 11 trustee may proceed with litigation against certain private equity investors. The trustee alleged that the investors drove the company into bankruptcy by paying themselves more than $375 million in dividends while neglecting to address Tops’ unfunded pension liabilities.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Schulte Roth & Zabel LLP, Clawback/avoidance/preferences/fraudulent transfers, US Congress
    Authors:
    Douglas S. Mintz , Peter J. Amend , Kelly (Bucky) Knight
    Location:
    USA
    Firm:
    Schulte Roth & Zabel LLP
    Post-Petition Interest In A Solvent Bankruptcy: Resurrecting A Rule From 1898 Act vs. Applying Bankruptcy Code Language (Ultra vs. Hertz)
    2022-11-23

    Four decades and several years ago, Congress repeals the Federal Bankruptcy Act of 1898 and replaces it with the Bankruptcy Reform Act of 1978, aka the “Bankruptcy Code.”[Fn. 1]

    A decade later, Justices on the U.S. Supreme Court are still disparaging the new Bankruptcy Code as the “sweeping changes Congress instituted in 1978” and “the radical reforms of 1978.”[Fn. 2]

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Koley Jessen PC, Insolvency, US Congress, Supreme Court of the United States
    Authors:
    Donald L. Swanson
    Location:
    USA
    Firm:
    Koley Jessen PC
    Davies Insolvency Now: Financial Gloom and the Increase in Insolvency Filings (Issue 7)
    2022-11-17

    Bursting the Crypto Bubble and the Financial Turbulence Ahead With the FTX Group’s recent Chapter 11 filing, on the heels of the recent Celsius Network LLC Chapter 11 filing, we have entered what could be described as a “Lehman Brothers moment” for the crypto industry. This observation, together with the recent awarding of the Nobel Prize in Economics to former Federal Reserve chair Ben Bernanke and professors Douglas Diamond and Philip Dybvig for their pioneering research on banks and financial crises, has caused some of us to experience a déjà vu moment.

    Filed under:
    Canada, Ontario, Banking, Capital Markets, Insolvency & Restructuring, IT & Data Protection, Litigation, White Collar Crime, Davies Ward Phillips & Vineberg LLP, Blockchain, Cryptocurrency, Cybersecurity, Anti-money laundering, Non-fungible tokens, US Congress, Supreme Court of Canada, Ontario Superior Court of Justice, British Columbia Supreme Court
    Location:
    Canada
    Firm:
    Davies Ward Phillips & Vineberg LLP
    Parting Advice: Judge Drain Rules That Dividends Paid From the Proceeds of Safe-Harbored Transactions Are Not Safe-Harbored in In re Tops Holding II Corp.
    2022-11-02

    In his final opinion, Judge Robert D. Drain of the United States Bankruptcy Court for the Southern District of New York held that dividends paid from proceeds of safe-harbored transactions under section 546(e) of the Bankruptcy Code are not safe-harbored. While only approximately 15 pages of Judge Drain’s 109-page final opus are dedicated to consideration of the section 546(e) issue, the relevant analysis ends with a pressing question to Congress and an appeal to modify section 546(e) to “restrict to public transactions its currently overly broad free pass . . .

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Bracewell LLP, Private equity, US Congress
    Authors:
    Jonathan Lozano , Mark E. Dendinger
    Location:
    USA
    Firm:
    Bracewell LLP
    SCOTUS Grants Certiorari, Remands U.S. Trustee Fee Dispute to Second Circuit
    2022-10-31

    The ramifications of uneven increases to fees in chapter 11 bankruptcies continue to ripple through federal courts.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Patterson Belknap Webb & Tyler LLP, US Congress, Supreme Court of the United States, Fourth Circuit
    Authors:
    Maxwell K. Weiss , Daniel A. Lowenthal
    Location:
    USA
    Firm:
    Patterson Belknap Webb & Tyler LLP
    Fifth Circuit Rules on the "Solvent-Debtor Exception" and Make-Whole Premiums
    2022-10-28

    In Short

    The Situation: Courts have disagreed over whether a make-whole premium triggered by a borrower's bankruptcy filing must be disallowed as unmatured interest. They have also disputed whether the "solvent-debtor exception" requiring the payment of postpetition interest to unimpaired unsecured creditors of a solvent debtor survived the enactment of the Bankruptcy Code. Finally, courts have split on what rate of postpetition interest unimpaired unsecured creditors of a solvent debtor are entitled to receive.

    Filed under:
    USA, Insolvency & Restructuring, Litigation, Jones Day, US Congress, Fifth Circuit
    Authors:
    Heather Lennox , James O. Johnston , Joshua M. Mester , Bruce Bennett , C. Lee Wilson , Nicholas C.E. Walter
    Location:
    USA
    Firm:
    Jones Day

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