News & Analysis as of

Noteholders Debtors Chapter 11

Mayer Brown

Third Circuit Orders Hertz to Pay Noteholders Post-petition Interest, including Make-Whole Premiums, at Contract Rates

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The US Court of Appeals for the Third Circuit recently held that Hertz’s noteholders are entitled to post-petition interest payments, including make-whole premiums, at the contract rate as part of the company’s Chapter 11...more

Jones Day

Fifth Circuit Rules on the "Solvent-Debtor Exception" and Make-Whole Premiums

Jones Day on

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...more

Jones Day

Texas Bankruptcy Court Allows Make-Whole Premium as Liquidated Damages and Requires Solvent Chapter 11 Debtor to Pay Postpetition...

Jones Day on

On October 26, 2020, the U.S. Bankruptcy Court for the Southern District of Texas issued a long-awaited ruling on whether natural gas exploration and production company Ultra Petroleum Corp. ("UPC") must pay a make-whole...more

Jones Day

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

Jones Day on

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

Fifth Circuit Rules on “Impairment” Under Chapter 11 Plan, Provides Guidance on Make-Whole Payments and Default Interest

Perkins Coie on

A recent decision clarified the concept of impairment when a plan of reorganization provides for creditors to receive 100% of their allowed claims. The U.S. Court of Appeals for the Fifth Circuit held that creditors are...more

King & Spalding

Fifth Circuit Vacates Bankruptcy Court’s Order Requiring Payment of Make-Whole Premium and Interest in Ultra Petroleum Bankruptcy

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On January 17, 2019, the U.S. Court of Appeals for the Fifth Circuit delivered a much-awaited opinion with respect to whether Ultra Petroleum Corporation (“UPC”) was required to pay its noteholders contractual make-whole...more

Jones Day

Chapter 11 Plan Not Providing for Payment of Make-Whole Premium Impaired Noteholders

Jones Day on

In In re Ultra Petroleum Corp., 2017 BL 335015 (Bankr. S.D. Tex. Sept. 21, 2017), the U.S. Bankruptcy Court for the Southern District of Texas ruled that certain private-placement noteholders were entitled to receive 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

Jones Day

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

Jones Day on

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

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