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Study of Bankruptcies/Insolvencies in Various Jurisdictions spmxbk6.htm

 

 

 

 

RESEARCH PAPER ON

 

BANKRUPTCY/INSOLVENCY LAW IN VARIOUS COUNTRIES GENERALLY

WITH PARTICULAR ATTENTION FOCUSED ON

THE EFFECTS AND CONSEQUENCES OF BANKRUPTCY OF THE APPLICANT AND INSOLVENCY OF THE ISSUING BANK IN RELATION TO LETTERS OF CREDIT UNDER UNITED STATES LAW

 

 

Course: International Commercial Transactions

 

 

 

BY:       Metchi Palaniappan

Masters Program in International Trade Law 2002 – 2003

 

Under the supervision and valuable guidance of Professor Boris Kozolchyk

 

 

 

 

 

 

 

 

INTRODUCTION

 

This paper focuses on a study of:

  1. The procedures involved in insolvency/bankruptcy proceedings relating to individuals, corporations and banks in:
    1. United States
    2. Indonesia
    3. Malaysia
    4. Japan
    5. India
  1. Status of the creditor with regard to the insolvent corporation and/or bankrupt/insolvent applicant.
  2. Priority of rights of secured and unsecured creditors and third parties to the assets of the insolvent corporation and bankrupt/insolvent applicants.
  3. Distribution of the assets in the estate of the bankrupt/insolvent
  4. Cross-border insolvency issues.

A.  UNITED STATES

In the United States, bankruptcy procedures, rights and obligations of the parties involved in such proceedings, the status of the parties and their assets, the rights of third parties with respect to the debtors and matters incidental and relating to priority and preferences to claims are set out in the U.S. Bankruptcy Code – Chapter 7, 11 and 13.

Chapter 7 of the Bankruptcy Code

Chapter 7 of the Bankruptcy Code governs the liquidation of financially distressed companies and sets out the procedures for the distribution of liquidated assets to the debtor’s creditors. Chapter 7 is distinct from Chapter 11 in that, with a view to assist in rehabilitations, Chapter 11 provides for restructure and reorganization of a distressed company whereas Chapter 7 does not contemplate the retention of the debtor’s assets or the debtor’s rehabilitation.1

A case under Chapter 7 may be commenced voluntarily by a company or involuntarily by its creditors. The basis for a distressed company or its creditors to commence insolvency proceedings under Chapter 7 would be where the company lacks feasibility for successful reorganization of the business operation. Many Chapter 7 cases are ‘no-asset’ cases with little or no prospects of any meaningful distributions to unsecured creditors.

Upon the commencement of a Chapter 7 case, a trustee will be appointed who will then manage the debtor’s financial affairs. The trustee has broad statutory powers to manage the debtor’s business operation, to collect, liquidate and distribute the company’s assets and property to the creditors. This situation is similar to the bankruptcy law in Malaysia.

Also where the court determines cause e.g. where the debtor does not have reasonable proposals for a reorganization plan, a Chapter 11 case may be converted to a Chapter 7 case. Factors that courts would consider in determining ‘cause’ include continuing loss to or diminution of the value of the estate, inability to effectuate a plan of reorganization under Chapter 11 or unreasonable or prejudicial delay by the debtor.2

Under Chapter 7, an individual debtor would generally be entitled to apply for a discharge from insolvency and his debts unless there are instances of attempts to defraud creditors or conceal his assets. Similar provisions of law exist in India in this respect.

However a corporation or partnership debtor that liquidates under Chapter 11 is not entitled to a discharge, though in effect its assets are liquidated and distributed to creditors and thereafter the entity dissolves.3

Automatic Stay

Upon a voluntary or an involuntary Petition under Chapter 7 there will be automatic stay which prevents any commencement or continuation of litigation against the debtor, enforcement of a judgment against a debtor, any act to obtain possession or control of the debtor’s property or any act to collect, assess or recover a claim against the debtor.4 Similar provisions of Bankruptcy Laws apply in Malaysia.

Exceptions to the automatic stay principle are actions by government to enforce its police and regulatory powers.5

Distribution of Assets:

The assets of the insolvent will be distributed in the following order of priority:

  1. Payment of priority claims, certain unsecured claims for wages, salaries or commissions, unsecured claims for contributions to employee benefit plans, claims of fishermen or producers of grain, consumer deposits, claims for alimony, maintenance or support, tax claims and unsecured claims made by the debtor to an insured depository institution.6
  2. Payment of allowed unsecured claims where proofs are filed in time or if filed late then where the creditor did not have notice of the Chapter 7 case.
  3. Payment of any allowed unsecured claim, on proofs filed late and which do not fall within any exceptions.
  4. Payment of fine, penalty, forfeiture or punitive damages arising before the appointment of the trustee.
  5. Payment of interest on any of the claims from the date of the filing of the petition.
  6. Payment to the debtor.

It appears that the holders of highest priority claims must be paid in full before the trustee distributes to holders of claims in the subsequent priority class.7

Chapter 11 of the Bankruptcy Code

Chapter 11 is a ‘reorganization’ provision of the Code comprising provisions for the debtor’s restructuring. Example, Section 1145 provides for issuing new shares under the plan. Chapter 11 may be used to facilitate an orderly liquidation of the debtor. The debtor need not be ‘insolvent’ for the purposes of Chapter 11. Chapter 11 liquidations usually involves a sale of all or substantially all of the debtor’s assets to a single buyer or bulk asset sales such as inventory or leases to several purchasers. The court generally conducts a competitive auction process under section 363(b) of the Code. Professionals such as investment bankers are retained by the debtor in possession under Section 327 of the Code to assist in the sales process. Under Section 1125 a disclosure statement must be filed and the ‘feasibility’ and ‘best interest’ tests must be met. Therefore Chapter 11 process would appear to be a better process to liquidate an ongoing business debtor.8

There are numerous cases, which interpret and explain these statutory provisions and procedures as reflected in some of the cases set out here.

1)       Artis v Builder’s Transport, Inc., 1998 U.S. Dist. Lexis 18622 (E.D.N.C. 1998) deals with the principle of automatic stay in bankruptcy law and whether the enforcement of judgment for damages in tort would thereby be affected.

The defendant in the case sought voluntary bankruptcy protection under Chapter 11. The issues that arose before the court were whether there was an automatic stay of all further action by virtue of the bankruptcy/insolvency proceedings and whether the Plaintiff, an unsecured creditor in the circumstances, could nevertheless recover payment on the Letter of Credit issued.

The facts briefly: The Plaintiff’s son was killed in a road accident involving the Defendant’s truck. Pursuant to a settlement agreement, consent Judgment was entered against the Defendant for the sum of $100,000/- which was payable in four (4) installments. The Defendant posted a Letter of Credit under the US transportation law which required a self-insuring transportation company to file a ‘bond, insurance policy or other type of security. The terms of the Letter of Credit required the defendant to certify that (a) the plaintiff/claimant had obtained a final non-appealable judgment against the defendant, (b) the claim had not been paid for thirty (30) business days after a demand for it had been made by the plaintiff. The settlement agreement provided, inter-alia that in the event of default of payment, the Defendant would assist the Plaintiff to obtain the proceeds of the Letter of Credit. Then defendant defaulted on the final payments and filed for bankruptcy protection under Chapter 11 of the U.S. Bankruptcy Code. The Plaintiff claimed payment under the Letter of Credit from the trustee/beneficiary, whose duty is to look out for unsecured creditors. The trustee refused to pay and the defendant, for its part, refused to provide the required certification to enable the plaintiff to seek payment under the Letter of Credit.

The issue before the Court was what effects the defendant’s voluntary filing of the bankruptcy proceedings would have on the plaintiff’s claim for payment under the Letter of Credit which was posted by the defendant prior to the bankruptcy proceedings being initiated. And the Court held that:

“The letter of credit serves the same purpose as a surety bond. It was an emergency source of money for those injured by a self-insuring company, which was accessible to the plaintiff in the event the defendant defaulted liability.” The Court ruled that, because of this statutory purpose, the letter of credit should be regarded as outside the Bankruptcy Estate in the same fashion as a surety bond. Therefore an order requiring the judgment debtor to supply the required certifying statement did not violate the automatic stay principle.

 

2)       Development Specialists, Inc. v Hamilton Bank, N.A. (In re: Model Imperial, Inc.) 250 B.R. 776(Bankr.S.D. Fla. 2000) deals with a Chapter 11 bankruptcy proceeding and preferences of transfers of assets subsequent to the initiation of bankruptcy proceedings and as to whether these assets ought to have been subordinated.

The facts briefly: Model Imperial Liquidating Trust Company (Model) had ongoing business operations at the material time. ‘Model’ secured all its assets to obtain substantial revolving credit facilities from three (3) lenders, namely, NationsBank, BankBoston and South Trust. This credit facility restricted Model from borrowing from other financial sources. The Lenders refused to increase Model’s credit line, and Model obtained credit facilities from Hamilton Bank creating a ‘shell’ company, which existed only on paper with no assets whatsoever. Hamilton Bank also issued a Letter of Credit to enable Model to purchase “gift sets” for the Christmas season. The goods purchased through the financing from Hamilton were held as collateral and security for the credit facilities granted. The Lenders were never notified of this arrangement. Later, when the Lenders discovered this arrangement, Model reported losses of more than US$20 million. The Lenders thereupon recalled their loan/credit facilities. In the interim and during the process of all these transactions, an agreement was concluded whereby Hamilton could take possession of the goods in the bonded warehouse if the indebtedness was not cured by a certain date. Model filed for protection under Chapter 11 of the Bankruptcy Code. Following this Hamilton liquidated and sold the inventory and received in excess of US$1.2 million. Hamilton also extended short-term credit to Model including Letters of Credit and bankers’ acceptances. Hamilton then filed a proof of claim in the bankruptcy proceedings. The trustee objected on the grounds that the transfers of the inventory by Hamilton were with the intent to hinder, delay and defraud creditors and hence were avoidable and recoverable. Accordingly the trustee filed an adversary proceeding asking that Hamilton’s claim be equitably subordinated to other creditors’ claims. The trustee also contended that certain post-petition transfer were avoidable.

The United States Bankruptcy Court, Hyman, J., overruled the trustee’s objections and concluded that under the circumstances of the matter, the trustee was not entitled to recover any post-petition transfers.

The Court stated in obiter that “it is certainly consistent with the policies of the Bankruptcy Code to equitably subordinate Hamilton’s allowed claim, to Model’s allowed unsecured claims if the bank had acted according to the industry standards in which event Hamilton Banks’ claim might have been contractually subordinated.”

 

It appears from the language of the cases cited above and in particular, the Hamilton Bank’s case, that, assets held as collateral by the secured creditor may be sold, transferred and/or liquidated subsequent to the debtor/applicant filing an insolvency petition. Consequently such assets cannot be traced by the trustee for the benefit of the unsecured creditors in the general pool. The Bankruptcy Court in the Hamilton Bank case stated further, in obiter, that the secured creditor’s claim might have been subordinated by contractual arrangement in accordance with the norm of the industry.

EFFECT AND CONSEQUENCES OF THE APPLICANT’S BANKRUPTCY IN RELATION TO THE LETTER OF CREDIT ISSUED TO THE BENEFICIARY

 

A little Background on Letters of Credit*1

The need for letters of credit arose because of the uncertainty involved when a seller ships his goods to an unknown customer, especially if located in a foreign jurisdiction. The seller undertakes the risk of having to obtain his payment in the foreign jurisdiction. Hence the letter of credit was developed to remove this uncertainty and shift the risk of non-payment for the goods in international sales transactions. Letters of credit are governed by Article 5 of the Uniform Commercial Code (U.C.C) and the Uniform Customs and Practice for Documentary Credits (U.C.P.)

There are three parties to a letter of credit transaction i.e.

(a)     the applicant, who is usually the buyer and is the party requesting for the issuance of the letter of credit and ultimately funds the same;

(b)     the issuing bank, who is the applicant’s bank and the intermediary who makes the payment to the beneficiary; and

(c)     the beneficiary, who is usually the seller and the party receiving payment under the letter of credit.

Also there are three distinct and separate contracts involved in the letter of credit transaction:

(a)     An agreement between the issuing bank and the applicant that governs the terms by which the bank will issue the letter of credit and under which the bank will honor the drafts presented against the letter of credit. A debtor-creditor relationship is created between the issuing bank and the applicant when the bank issues the letter of credit.

(b)     A contract between the issuing bank and the beneficiary embodied in the terms of the letter of credit itself that governs how and when the beneficiary may request for payment.

(c)     The underlying agreement between the applicant and the beneficiary which creates the need for the letter of credit, which is in fact independent from the letter of credit, i.e. the issuing bank is obligated to honor the letter of credit regardless of the status of the underlying transaction.

The main function of the letter of credit is to shift the risk in a transaction from the beneficiary to the issuing bank. The theory is that the issuing bank is in a better position to assess the creditworthiness of the applicant. The primary essence of the letter of credit is the fact that the letter of credit is independent of the underlying transaction. It is this “independence” doctrine that makes the letter of credit a viable and effective commercial device. Because of the independence of the letter of credit, the issuing bank is bound to pay the beneficiary based solely on the terms of the letter of credit. In a documentary letter of credit transaction, the issuing bank is obligated to pay when present with proper documents regardless of any dispute between the beneficiary/seller and the applicant/buyer. The risk of non-payment is thus shifted from the beneficiary to the issuing bank. The beneficiary receives payment and the issuing bank must look to the applicant for reimbursement or pre-payment.

The mechanics of a standby letter of credit differ from a regular commercial/documentary letter of credit though the purpose remains the same, i.e. to reallocate the risk of the transaction to the party most able to evaluate the circumstances and bear the risk. Under a standby letter of credit, the beneficiary is using the letter of credit to secure the performance of the obligations by the applicant rather than to obtain direct payment in a sales transaction. Therefore the beneficiary only draws on a standby letter of credit when the applicant fails to perform his obligations under the contract. Hence the standby letter of credit usually requires an affidavit of non-performance from the beneficiary rather than presentment of documents of sale.

Letters of credit seem to pose a dilemma in the bankruptcy system because of the conflict that arises between the two important commercial and bankruptcy policies, namely, the “Independence Doctrine of Letters of Credit” law and the “Preference Provisions” of the Bankruptcy code.

On the one hand, the effectiveness of a Letter of Credit is based on the fact that the obligation of the issuing bank to pay the beneficiary is independent of the underlying transaction between the beneficiary and the applicant under the “Independence Doctrine: of letters of credit law. And on the other hand, bankruptcy law prohibits transfers at the eve of bankruptcy by the debtor, which may benefit one creditor to the detriment of the other similarly situated creditors. The preference provisions of the Bankruptcy Code allow the debtor or trustee to void pre-bankruptcy transfers and recover the property to the debtor's estate for the benefit of all creditors in equality.

The dilemma arises when the applicant of a letter of credit becomes a debtor in bankruptcy.

In the case of In re: Commco Tech (Commco Techjnology, LLC v Science Applications Int’l Corporation 258 B.R. 63; 2001 Bankr. LEXIS            77 (Bankr. D. Conn. 2001)[USA]

Facts: the applicant purchased computer software and hardware from the beneficiary and the bank issued a standby Letter of Credit to assure payment. Consequent to a repayment dispute between the applicant and the beneficiary, the parties entered into a settlement agreement to restructure the debt and the applicant issued a corresponding promissory note. The beneficiary refused to agree to the insertion of a clause in the promissory note stating that the letter of credit would be honored only ‘in the event the applicant fails to pay the note in full when due’. The parties also incorporated a statement recognizing the beneficiary’s right to draw on the letter of credit in whole or in part at any time with a view to partially satisfy amounts owed by the payee. The letter of credit had expired by the time applicant and the beneficiary had entered into the settlement agreement and the promissory note. Consequently the applicant caused the issuer to extend the expiration date of the letter of credit and was charged a fee for the extension of the letter of credit. The applicant did not contest the fee. Thereafter the applicant rearranged its financial affairs and sued the issuer and the beneficiary in the state court for a temporary restraining order prohibiting payment on the letter of credit on the grounds that any attempt to draw on the letter of credit by the beneficiary would be fraudulent because the settlement agreement stipulated that the letter of credit only secured payments that were outstanding prior to the settlement agreement. The state court granted the restraining order on the grounds that the beneficiary’s drawing on the letter of credit would cause irreparable harm. Subsequently the applicant commenced Chapter 11bankruptcy proceedings. The beneficiary then applied to the US Bankruptcy court to vacate the temporary restraining order, which was granted. The applicant’s response and request for a permanent injunction was denied.

Arguments before the Court:

Applicant:          if the funds held by the issuer collateral for the letter of credit were applied to reimburse a drawing by the beneficiary, it would cause irreparable harm to efforts for liquidating.

Court:               rejecting the argument, “there was no persuasive evidence” of such harm because the applicant could not show that efforts to liquidate its assets would be affected by the beneficiary’s drawing on the letter of credit.

Applicant:          drawing on the letter of credit would be fraudulent

Court:               the applicant would have to prove the likelihood of success on the merits of such a contention.

 

In this case the beneficiary was able to draw on the Letter of Credit unaffected by the bankruptcy/insolvency of the applicant. The decision in this case appears to reflect the notion that the funds held by the issuing bank as collateral for the letter of credit would not be affected by the bankruptcy of the applicant. It would appear that such funds would be independent of the bankruptcy proceedings unless the applicant proves fraud or puts forth persuasive evidence that irreparable harm would be occasioned to efforts to liquidate.

In the case of Prime Motor Inn; In re: Metrobility Optical systems, Inc. 268 B.R. 326; 2001 Bankr. LEXIS 1382 (Bankr. D.N.H. 2001)[USA]:

Facts: the applicant/debtor in bankruptcy proceedings applied for a preliminary injunction to prevent the beneficiary from drawing on the Letter of Credit. The underlying transaction involved a lease of real property. A standby Letter of Credit for US$1,792,000/- was issued. The letter of credit was silent as to the governing rules.

The letter of credit required that the beneficiary/lessor certify that the applicant had failed to pay or perform one or more of its obligations under the lease. The lease itself envisaged the filing of voluntary bankruptcy in the event of default. The lease provided that the beneficiary was entitled to draw against the letter of credit to satisfy itself with an amount equal to the total rent reserved for the balance of the term in the event of an uncured default. When the applicant filed for protection during its reorganization under Chapter 11 of the US Bankruptcy Code, the beneficiary served a notice of default and notice of intent to draw the full amount of the letter of credit despite the fact that the applicant was current on its lease payments. The Applicant then moved for a temporary restraining order and preliminary injunction in the bankruptcy action to prevent the beneficiary from drawing upon the letter of credit.

The United States bankruptcy court granted the applicant/debtor’s motion for a preliminary injunction, enjoining the beneficiary and its assignees from certifying that default existed on the part of the applicant or that the lease had terminated.

The rationale for the court’s decision as such was that, where a drawing on a letter of credit results from the exercise of an ipso facto clause in violation of the US Bankruptcy code, there is irreparable injury and a likelihood of success on the merits. As such an injunction would lie where the applicant is an immediate party to the transaction that gave rise to the letter of credit.

Arguments before the Court:

Beneficiary:       the bankruptcy court lacked jurisdiction to enjoin payment on a letter of credit because the bankruptcy court did not have jurisdiction to interfere with separate and independent contracts to which the debtors were not parties on the authority of the case of Fidelity Bank, N.A. Prime Motors Inns, Inc. (In re Prime Motor Inns, Inc.), 130 B.R. 610 (S.D. Fla. 1991).

Court:               the case cited involved letters of credit, issued on the debtor’s behalf, to secure bond indentures to which the debtors were not parties. In the present case, however, the court’s granting of a preliminary injunction stems from the terms of the lease to which the debtor is a party. The court is therefore well within its jurisdictional authority to make a determination about the terms of a lease between a debtor and a third party.

The Court proceeded to hold that there are four factors involved in considering the appropriateness of injunctive relief namely:

(1)     whether the plaintiff would suffer irreparable injury without the injunction;

(2)     whether the injury would outweigh harm that could occur if the injunction were granted;

(3)     whether the plaintiff showed likelihood of success on the merits of its case; and

(4)     whether the public interest would be adversely affected by the grant of a preliminary injunction.

Applying the requisite factors to the case:

(1)     Likelihood of success:

the Bankruptcy Code embraces the policy of preventing the enforcement of ipso facto clauses, which automatically terminate a contract or a lease or allow the other party to terminate in the event of a bankruptcy filing, therefore the debtor had demonstrated likelihood of success. Since the debtor was current on its lease payments, the filing of the bankruptcy triggered the default, making the notices of default without basis since they violated the Bankruptcy Code.

(2) Irreparable Injury:              

            because the amount of the letter of credit exceeds the amount that the landlord might be able to claim under the bankruptcy proceedings and the issuer would draw on the security provided by the debtor, the debtor would suffer irreparable harm;

(3)     Independence of Bankruptcy Policy:

an injunction would further the policy of the Bankruptcy Code in preventing ipso facto clauses. The issuance of a preliminary injunction would not affect the integrity of Letters of Credit.

 

This case seems to put forth the view that Letters of Credit may not be protected against insolvency notwithstanding the fact that there is no clear evidence of fraud and the beneficiary is rendered incapable of realizing under the letter of credit. This may be because based on the specific facts of the case where the Court found that irreparable harm would be occasioned if the beneficiary were permitted to draw on the letter of credit.

Thus, the general trend of bankruptcy laws in the United States would appear to be that Letters of Credit are/should be protected against insolvency unless there is fraud or where irreparable harm would be occasioned.

Consequently the beneficiary of the letter of credit should be at liberty to draw and realize the benefit under the letter of credit.

By necessary implication, it probably could be concluded that the monies/funds deposited as collateral for the issuance of a Letter of Credit would be deemed to be monies paid out and having ‘reached the hands’ of the intended beneficiary. Hence such monies would not be retraceable/retractable in the event of the applicant’s insolvency unless fraud or consequential irreparable harm can be shown.

Necessary implication would also indicate that the monies paid by the applicant to collaterize the issuance of the letter of credit does not form part of the applicant/insolvent’s estate in the event of the applicant’s insolvency prior to the letter of credit being realized.

Applicability of the Principles of Bankruptcy Laws to the Letter of Credit Transaction

The underlying goal in bankruptcy law is that similarly situated creditors must receive equal treatment. To effectuate this goal the Bankruptcy Code allows the trustee or debtor to avoid certain ‘preferential’ transfer and to recover the amounts transferred. Hence, certain transaction that give an advantage to one creditor over the others can be undone, and the property traced and returned to the debtor’s estate for the benefit of all unsecured creditors in the general pool.

Principles of preference in bankruptcy law involves two step procedure:

(a)     The trustee/debtor must prove that a preferential transfer occurred as provided in Section 547 of the Code.

(b)     The trustee/debtor must ascertain from whom to recover the preferentially transferred property as provided in Section 550 of the Code.

To establish that a preferential transfer has been made, the transfer must have taken place during one of the preference “reach-back” periods as envisaged in Section 547(c)(4) of the Code. The preference reach-back period establishes a specified timeframe before the filing of the bankruptcy/insolvency petition during which timeframe, the debtor or the trustee can “reach back” and undo the transfer, i.e. in the event the transfer is considered to have been effectuated on the eve of the bankruptcy.

On the other hand Section 547(c) sets out situations where preferential transfers may be exempted from preference treatment. The effect of Section 547(c) is to exempt certain transactions between a debtor and a creditor exempt from preference treatment under circumstances where the transactions in question do not deplete the debtor’s estate to the detriment of the other unsecured creditors.

Therefore the trustee or debtor must prove that the property of the debtor was transferred within the prescribed preference period for an antecedent debt and that the said transfer enabled the creditor to receive more that he would have received under liquidation of the debtor.

Once the debtor or trustee proves that a preferential transfer has taken place, Section 550(a) enables recovery of the property transferred. Consequently the debtor or trustee may recover the amount from the person to whom the transfer was initially made or from the person who benefited from the transfer. Accordingly the debtor’s estate would be restored to its pre-preference state and all equally situated unsecured creditors may have an equal share in the distribution of the bankrupt’s estate.

The issue that arises here is whether the debtor/trustee can recover payment:

(a)     from the beneficiary as an indirect transferee; or

(b)     from the issuing bank as the direct transferee.

A brief study of several cases cited below sheds light on these issues:

In Matter of Marine Distributors, Inc.,522 F.2d 791 (9th Cir.1975)

The trustee argued that the bank, although unsecured on the letters of credit, should be enjoined from honoring the letters of credit because the letters of credit were assets of the debtor’s estate and that the estate would be irreparably harmed if the issuing bank honored drafts against the letters of credit.

The Bankruptcy court granted the injunction and the district court affirmed. On appeal the 9th Circuit held that the letters of credit were not the property of the estate and that the bankruptcy court did not have jurisdiction over the irrevocable letters of credit or the monies.

 

This case therefore, confirms the independence doctrine for unsecured letters of credit.

But it must be noted that this decision was prior to the coming into force of the Bankruptcy Code.

In re Twist Cap, Inc., 1 Bankr.284 (Bankr.D.Fla.1979)

This case deals with secured letters of credit. In March 1978, the Twist Cap entered into a security agreement with its bank to secure any payments by the bank on Twist Cap’s behalf. The bank issued letters of credit on Twist Cap’s account in December 1977, June 1978 and March 1979. Twist Cap filed its bankruptcy petition in August 1979 prior to any drawings being made on the letters of credit. The bankruptcy court issued temporary restraining orders prohibiting the bank from honoring the letters of credit. The court distinguished the Marine Distributors’ case where the letters of credit were not secured whereas in the Twist Cap case, the letters of credit were secured.

The court in In re Twist Cap case held that: “to permit these two unsecured creditors to receive a payment, possibly in full, on the pre-petition indebtedness owed to them by the debtor would amount to an impermissible preferential treatment of these two unsecured creditors which is contrary to the scheme of Chapter XI.” The court held further that when a letter of credit is secured by the property of the debtor, an indirect preference would occur to the benefit of the unsecured creditor if the issuing bank were not enjoined from honoring the letter of credit. In effect, the secured letters of credit were the same as property of the debtor because some property of the debtor would be required to reimburse the issuing bank.

 

The Twist Cap case therefore represents the possibility that the independence of the letter of credit could be nullified in bankruptcy.

But this decision appears to give rise to a dilemma because the effectiveness of a letter of credit as a financing device depends on the independence of the letter of credit from the underlying transaction, including the insolvency of the applicant.

In Page, 18 Bankr. 713 (D.D.C.1982), the bankruptcy court enjoined payment under secured letters of credit. The District court reversed the decision of the bankruptcy court and held that the secured letters of credit were not the property of the debtor and not part of the debtor’s estate, even though they were secured by the property of the debtor. No doubt, the issuing bank, upon honoring the letter of credit, would resort to the collateral pledged by the debtor and thereby reduce the assets in the debtor’s estate in bankruptcy. However the court noted that the automatic stay principle would prevent the issuing bank from acting without the court’s approval.

 

The decision in the Page case reaffirms the independence doctrine in relation to letters of credit. However the question remains as to whether the pledging of property of the debtor to secure a letter of credit during the preference reach-back period would constitute a preferential transfer.

Sabratek Corp. v. LaSalle Bank, N.A. (In re: Sabratek Corp.)257 Bankr. 732 (B. D. Del. 2001) [U.S.A.]

Facts: The seller provided a Letter of Credit to the buyer to assure minimum share price at an agreed date with respect to the sale of a subsidiary. The Letter of Credit required a statement that the applicant defaulted on its payment obligations. The Letter of Credit stated that the beneficiary had no right to payment from the sale of the stock until 1 July 2000. Seller/Applicant failed to register the stock in a timely fashion as required by the agreement. Thereupon the parties entered into a Forbearance Agreement whereby  the beneficiary agreed not to commence any legal action to enforce its rights under the Letter of Credit until an agreed date. But the new agreement provided that if applicant filed for bankruptcy, the beneficiary could immediately draw on the Letter of Credit. On 17 December 1999, applicant filed for Chapter 11 reorganization bankruptcy. Shortly thereafter, the beneficiary demanded payment on the Letter of Credit. As required by the Letter of Credit, the beneficiary’s demand included the required statement. The issuing bank, however, refused to pay on the grounds that the beneficiary’s demand constituted fraud since the Letter of Credit said no default could occur under the agreement until 1 July 2000. The beneficiary sued the issuing bank for wrongful dishonor. The applicant then sought an injunction in federal bankruptcy court preventing the beneficiary from proceeding with the state action in federal bankruptcy court. The bankruptcy court denied the motion.

Rationale: Where the bankrupt has procured a Letter of Credit for a third party, it is not part of the estate, and in the absence of unusual circumstances, a bankruptcy court will not enjoin a state action by the beneficiary against the issuer to collect on the Letter of Credit.

On the issue of the application for injunction the trial court noted four criteria for granting an injunction:

(1)     the likelihood that the plaintiff will prevail on the merits at final hearing;

(2)     the extent to which the plaintiff is being irreparably harmed by the conduct complained of;

(3)     the extent to which the defendant will suffer irreparable harm if the preliminary injunction is granted; and

(4) the public interest” citing Duraco Procucts, Inc. v. Joy Plastic Enterprises, Ltd., 40  F.3d 1431 (3d Cir. 1994).

Noting that the letter of credit is not property of the estate and that the Debtor has no interest in either the letter or its proceeds, the bankruptcy court reasoned that the state action and a ruling for the beneficiary would not adversely impact the estate. Therefore, the court concluded that the applicant would not be likely to succeed on the merits.

The applicant argued that it would suffer irreparable harm if the state action continued. It claimed that it could not be certain that the issuing bank would aggressively raise its interests. The bankruptcy court pointed out that avenues of participation were open to the applicant and refused to grant an injunction. Moreover, because the time stated in the Letter of Credit had passed, the court observed that the beneficiary could draw on the Letter of Credit under the terms of the original Registration Rights Agreement.

The beneficiary argued that it would suffer irreparable harm from an injunction because it could not collect the Letter of Credit proceeds and thus could not fund its other initiatives.

While such an argument ordinarily does not constitute a defense against an injunction, the bankruptcy court stated that the involvement of an Letter of Credit distinguishes this case. The court reasoned that parties insist upon receiving letters of credit specifically so that they will not have to wait for payment or, even worse, sue and wait for payment. Consequently, the court concluded that any delay in the beneficiary’s right to draw on the letter of credit constitutes ‘irreparable harm’ because it eliminates the benefit of having obtained the letter of credit – the assurance of prompt payment.

The applicant argued that the public interest requires an injunction to preserve the integrity of letter or credit transactions.

The bankruptcy court disagreed noting that the underlying rule of letters of credit is “pay first, litigate later.” Therefore, the court concluded, “the public policies behind letter of credit transactions do not favor issuance of an injunction.”

 

Consequently because a letter of credit is an irrevocable obligation between the issuing bank and the beneficiary and because the letter of credit is independent of the underlying transactional relationship between the debtor and the beneficiary, the principle would be that the collateral posed to secure the letter of credit:

(i)                  is not the property of the debtor or the debtor’s estate;

(ii)                 is not a preferential transfer; and

(iii)               is not subject to automatic stay.

Two cases that illustrate the above principles are as follows:

(a)       In re M.J. Sales & Distributing Co., Inc., 25 Bankr. 608 (Bankr.S.D.N.Y.1982), the debtor pledged a Treasury bond as security for a standby letter of credit. The trustee argued that the pledge of the bond was an indirect preference for the benefit of an unsecured creditor because the issuing bank would use the debtor’s collateral to set off its obligation under the letter of credit to pay the beneficiary. The court held that the payment by the issuing bank to the beneficiary was not a preferential transfer.

(b)       In re Price Chopper Supermarkets, Inc., 40 Bankr.816 (Bankr.S.D.Ca.1984), the debtor caused a secured standby letter of credit to be issued as security for a promissory note. When the beneficiary drew on the letter of credit subsequent to the debtor’s bankruptcy petition, the trustee argued that the payment from the issuing bank to the beneficiary was an indirect preferential transfer for the benefit of an unsecured creditor because the bank had recourse against the property of the debtor that is held as collateral for the letter of credit. The court held that the payment by the issuing bank to the beneficiary was an independent transaction and was not a preferential transfer because the bank paid the obligation form its own funds, and not from the funds of the debtor. The court affirmed the independence of letters of credit in bankruptcy and the importance of the independence doctrine to commerce and stated:

“Accepting the Trustee’s and Bank’s argument would mean that the beneficiary of a letter of credit could never rely on a letter of credit as an absolute guarantee of repayment. The consequent result would be that in every case, a beneficiary would have to investigate the source of funds used by a bank to pay it in order to assure that the beneficiary was insulated from any later claims by a trustee in bankruptcy of the non-bank debtor. To hold as the Trustee contends, would inject an element of uncertainty in a long-standing commercial practice designed to eliminate uncertainty.”

 

These cases appear to protect the contract between the beneficiary and the issuing bank. Courts have held that payment by the issuing bank was from its own funds and therefore no a preferential transfer of property of the debtor.

However when the debtor pledges property to secure the letter of credit, courts have held that collateral securing a letter of credit is the property of the debtor’s estate.

(a)                In re W.L. Mead, 42 Bank. 57 (Bank.N.D.Ohio 1984), the court held that “it has not been decided whether or not the issuer may ‘foreclose’ on its collateral once performance on the letter has been rendered.” The court held further that the collateral, which has been pledged by a debtor as security for a letter of credit, is the property of the bankruptcy estate and the automatic stay principle prevents a pledgee from assuming title to the collateral.

This case thus establishes the rule that collateral pledged to secure a letter of credit is the property of the debtor and is subject to the automatic stay principle when the issuing bank seeks to foreclose on it after the debtor files a bankruptcy petition.

(b)                In re Air Conditioning, Inc., 845 F. 2d 293 (11th Cir.1988), the issuance of the secured letter of credit occurred one month before the debtor filed his bankruptcy petition. The bankruptcy court held that the debtor’s transfer of collateral to secure the letter of credit was a voidable preference because the letter secured an antecedent debt and therefore the transfer of property of the debtor to secure the letter of credit benefited the unsecured creditor. The court nullified the letter of credit transaction as an indirect preferential transfer because it was used by the parties to transfer the debtor’s property to the unsecured creditor through the bank as an intermediary.

On appeal, the court held that the debt owed by the debtor to the creditor existed prior to the issuance of the letter of credit, i.e. it was an antecedent debt. Thus if the debtor had given the creditor an additional security interest of any kind to secure payment of the debt, rather than providing for the issuance of the letter of credit, the transfer would clearly have been subject to being avoided as a preference by the trustee under 11 U.S.C. S. 547(b). The question that then arises is whether a debtor should be able to secure payment of an antecedent debt, through the recognized sanctity of a letter of credit, when he could not do so through any other type of security interest. The court held further that the nullification of the letter of credit was not the proper remedy because it failed to recognize the independence of the letter of credit. Based on the affirmation of the validity of the independence doctrine, the court held that recovery of the preference must be obtained from the unsecured creditor who directly benefited from it, and not from the issuing bank.

 

Therefore the effect of the Air Conditioning decision lays down the principles that:

(1)                 an indirect preference occurs when a debtor pledges property to secure a letter of credit if all the elements of a preference are present; and

(2)                 recovery of the preference must be from the beneficiary of the letter of credit and not the issuing bank.

The case of Matter of Compton Corporation, 831 F.2d 586 (5th Cir.1987) strongly endorses the policy of interpreting bankruptcy law in a manner that does not interfere with the sanctity of letters of credit.

Facts: One day before filing a bankruptcy petition, the debtor caused a secured standby letter of credit to be issued to guarantee a missed payment for goods. The letter of credit was secured by a future advances clause in a prior security agreement with the debtor’s issuing bank. The court held that the letter of credit was, actually, an indirect preference and that the trustee could recover from the creditor, but not from the issuing bank.  The court held that ‘a creditor cannot secure payment of an unsecured antecedent debt through a letter of credit transaction when it could not do so through any other type of transaction.

 

In the Matter of Val Decker Packing Company, 61 Bankr. 831 (Bankr.S.D.Ohio 1986), the bank had a blanket security agreement that covered all of the debtor’s liabilities to the bank. The debtor caused the bank to issue a standby letter of credit on April 22, 1977. A note covering the letter of credit and other existing indebtedness was executed and secured by a new security agreement in June 1980. The debtor filed a bankruptcy petition on August 8, 1980. The court held that a transfer of the debtor’s property occurred when the collateral was pledged to secure the letter of credit, and not when the bank looked to the collateral for reimbursement. The court held further that the letter of credit was unsecured when originally issued and that it was secured within the ninety-day preference reach-back period. Therefore the pledge of the collateral during the reach-back period was voidable preference for the benefit of the bank. As a direct preference, it was recoverable only from the bank.

 

Thus it appears that bankruptcy courts have held that the transfer of the debtor’s property under a letter of credit occurs when the issuing bank perfects a secured interest in the collateral and not when the bank makes payment on the letter of credit. Even though the bank’s claim on the debtor’s property is contingent, it is considered a transfer at the time it is perfected. Therefore, in order to constitute a preferential transfer, the transfer of collateral to secure the letter of credit must occur during or within the preference reach-back period and not the payment from the issuing bank to the beneficiary.

Section 547(c) provides for exceptions, which can operate to exempt an apparent preferential transfer from being avoided. Bankruptcy courts have held that regular commercial letters of credit are not preferential transfers based on the Section 547(c) exceptions.

For example, in re AOV Industries, Inc., 64 Bankr. 933 (Bankr.D.Col.1986), the court held that the ordinary course exception of Section 547(c)(2) protected the use of commercial letters of credit in an international sale transaction. The court’s rationale was that the commercial letters of credit were used by the parties as a method of payment in the ordinary course of selling and purchasing the goods. The court held that the judgment was in accordance with the general policies for facilitating commerce and maintaining the strength of the letter of credit as a national and international financing device.

 

In Matter of Fuel Oil Supply Terminaling, Inc., 837 F.2d 224 (5th Cir.1988), it was held that the ‘new value’ exception of Section 5437(c)(1) covered certain secured standby letters of credit. In this case, the secured standby letters of credit were used to guarantee payment in an oil exchange agreement. The debtor returned previously borrowed oil within the preference reach-back period and the creditor allowed the letters of credit to lapse/expire because the debtor had returned the oil. The court held that although the transfer of the debtor’s oil occurred within the preference reach-back period, the creditor’s release of the secured letters of credit constituted ‘new value’ and therefore exempted from preference attack.

 

In re Metro Communication, Inc., 115 Bankr. 849 (Bankr.W.D.Pa.1990), the court held that payments to a beneficiary under an unsecured letter of credit did not constitute a preferential transfer. In dicta, the court stated that any transfer of a debtor’s property occurs when the letter of credit is issued, not when the issuing bank pays.

 

In re Zenith Laboratories, Inc., 104 Bankr. 667 (Bankr.D.N.J.1989), the court held that letters of credit were not the property of the debtor’s estate. Payments made to the beneficiary were from the issuing bank’s funds and therefore the bankruptcy court could not enjoin payment to the beneficiary.

 

In re Gates Community Chapel of Rochester,Inc.,123 Bankr.700 (Bankr W.D.N.Y.1991), the court held that a secured letter of credit issued during the preference reach-back period to guarantee payment on an unsecured antecedent debt was an indirect preferential transfer for the benefit of the beneficiary.

 

Thus, from the trend of the cases it is apparent that in order to constitute indirect preferences, the letters of credit must be given to guarantee or secure payment on an unsecured or under-secured antecedent debt. In addition, any transfer of the debtor’s property to secure the letter of credit must occur within the preference reach-back period. Also, the debtor must have been insolvent at the time of the transfer and the transfer must have given the issuing bank a greater return than it would have received in a Chapter 7 liquidation.

It is evident that the problem facing the bankruptcy system in regard to letters of credit is to maintain the independence of letters of credit while applying the preference powers available in the Bankruptcy Code. This is of great concern because of the extensive use of letters of credit in international commerce. If courts were to allow recovery of direct payments to beneficiaries under letters of credit as preferential transfers, the effectiveness of letters of credit as a commercial financing system would be undermined. The impact of the bankruptcy action would be to interfere with the allocation of risk sought by the parties to the letter of credit transaction. In eff