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Business Restructuring Review Vol. 24, No. 4 | July–August 2025

The Ad Hoc Group of Senior Secured Noteholders and DIP Lenders (the “Ad Hoc Group”) obtained a unanimous judgment in their favor in an appeal following Sanchez Energy Company’s long-running, hard-fought bankruptcy case. Once...more

Business Restructuring Review Vol. 21, No. 6 | November-December 2022

On October 14, 2022, the U.S. Court of Appeals for the Fifth Circuit issued a long-awaited ruling on whether Ultra Petroleum Corp. (“UPC”) must pay a $201 million make-whole premium to noteholders under its confirmed chapter...more

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

On October 14, 2022, the U.S. Court of Appeals for the Fifth Circuit issued a long-awaited ruling on whether Ultra Petroleum Corp. ("UPC") must pay a $201 million make-whole premium to noteholders under its confirmed chapter...more

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

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

Divided Ninth Circuit Rules That Unimpaired Unsecured Creditors of a Solvent Debtor May Be Entitled to Post-Petition Interest at...

In Short - The Situation: Bankruptcy courts have split on what rate of post-petition interest unimpaired creditors of a solvent debtor are entitled to receive. Bankruptcy courts have variously ruled that such creditors...more

U.S. Supreme Court: Mere Retention of Property Does Not Violate the Automatic Stay

The Situation: Circuit courts were split on whether mere retention by a creditor of estate property violates the Bankruptcy Code's automatic stay, under 11 U.S.C. § 362(a)(3). The U.S. Supreme Court considered the question in...more

High Court Tightens Section 546(e) Safe Harbor for Securities Transaction Payments

The U.S. Supreme Court issued a highly anticipated ruling resolving a long-standing circuit split over the scope of the Bankruptcy Code's "safe harbor" provision exempting certain securities transaction payments from...more

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

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

From the Top: U.S. Supreme Court to Hear Case on Scope of Section 546(e)'s Safe Harbor

On May 1, 2017, the U.S. Supreme Court agreed to hear Merit Management Group v. FTI Consulting, No. 16-784, on appeal from the U.S. Court of Appeals from the Seventh Circuit. See FTI Consulting, Inc. v. Merit Management...more

EuroResource—Deals & Debt - March 2017

For the benefit of our clients and friends investing in European distressed opportunities, our European Network is sharing some current developments...more

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