In re Energy Future Holdings Corp. (EFH), issued on November 17, 2016, the Third Circuit Court of Appeals held that contractual provisions providing for yield-maintenance or make-whole premiums to noteholders are enforceable on a debt accelerated by a bankruptcy filing. In EFH, the debtor redeemed certain notes containing two related provisions: an acceleration clause that made all outstanding notes due and payable immediately upon filing of the bankruptcy and a redemption provision that allows the borrower to redeem the notes at 100% of the principal value plus an applicable premium comprising accrued and unpaid interest. The ruling in EFH clarifies the relationship between clauses providing for make-whole yield maintenance/prepayment premiums and acceleration clauses and provides guidance on how noteholders can protect their interests in recovering through careful drafting of contractual provisions. The ruling also criticized the legal analysis of the bankruptcy courts in both EFH and In re MPM Silicones LLC (“Momentive”) from the Southern District of New York.