Valuation—the estimation of an entity’s worth—plays a crucial role in all stages of a commercial bankruptcy, as well in any out-of-court restructuring.¹
Valuation can be critical at the beginning of a bankruptcy case in determining whether the debtor can use cash collateral or obtain debtor-in-possession financing. At the confirmation stage, valuation plays a critical role in determining whether a chapter 11 plan can be confirmed and, if so, how much each class of creditors will receive on its claim. Even after confirmation, valuation is an essential issue in litigation seeking recovery of alleged avoidable transfers. Creditors may seek to lift the automatic stay at any time during a case based, in part, on the value of the debtor’s assets. This article examines how valuation impacts the outcome of each of these aspects of a commercial chapter 11.
The importance of valuation, of course, is not limited to bankruptcy proceedings but extends to out-of-court restructurings (and to many situations in which a debtor seeks to pay a creditor less than in full or otherwise outside of contract terms) because parties frequently seek to negotiate fully consensual restructurings outside of court to avoid the substantial costs and uncertainties of chapter 11.
A party’s negotiating position, in turn, is based in substantial part on what that party believes a litigated outcome would yield absent settlement (whereas the strength of a party’s position depends in large measure on what the actual result of litigation would be). Yet it is impossible to know with certainty how any court will rule on any matter, let alone one in which value is in dispute. Absent an actual sale, a determination of value is inherently subjective. Moreover, bankruptcy judges are not valuation experts. Rather, they hear evidence from dueling experts, each generally with excellent credentials, hired by opposing parties for the very purpose of persuading the judge to accept its view of valuation. This is the proverbial battle of the experts.
But before we proceed to address specific examples of how valuation impacts a commercial chapter 11 case and what experts are called on to opine about, let’s begin with a very brief overview of bankruptcy to provide the reader with appropriate context.
The bankruptcy process in the United States is governed by federal law. Article I of the U.S. Constitution grants Congress the power to make bankruptcy law and to create bankruptcy courts. Congress exercised this power through the Bankruptcy Reform Act of 1978, which formally enacted the current Bankruptcy Code, codified at Title 11 of the U.S. Code. The Bankruptcy Code was most recently significantly amended by Congress under the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (“BAPCA”).
While chapters 7 and 11 of the Bankruptcy Code are the most commonly referred to chapters in the corporate bankruptcy process, chapters 1, 3, and 5 serve paramount roles in interpreting how chapter 7 and 11 cases are conducted. Stated another way, when a company (or a person) “files” chapter 7 or chapter 11, those chapters provide many of the rules that govern their respective proceedings, but chapters 1, 3, and 5 provide additional rules that apply in both chapters 7 and 11:
[Editor’s Note: For more information on clawbacks, please read How Unsecured Creditors Push Ahead of Lenders Who in Fact Invested, Part II – Clawback of “Loan Repayments”]
And the Bankruptcy Code is not the sole source of the rules that are applicable to a bankruptcy case. Quite to the contrary, there are several other major sources of such rules:
Each chapter of the Bankruptcy Code has a title. The title of Chapter 7 is “Liquidation” and the title of Chapter 11 is “Reorganization.” Chapter 11’s title, however can be as deceiving as a ferocious German Shepherd named “Cupcake” or a 6’5’’ WWE wrestler named “Tiny.”
A classic reorganization is a chapter 11 case in which the equity owners of the debtor before the chapter 11 are still equity owners after confirmation of the chapter 11 plan. It may involve some creditors agreeing to forgive some debt and/or to stretch out the time in which the debtor may pay their debt. It may involve some creditors agreeing to trade some of their debt for some of the debtor’s equity, thus diluting the original equity holders. It may involve the sale of some of the debtor’s assets. But it does not involve the sale of substantially all the debtor’s assets (i.e. a liquidation).
Years ago, nearly all chapter 11 cases were filed for the purpose of achieving a classic reorganization and successful classic reorganizations were quite common. The law and the practice, however, evolved and today most Chapter 11 cases result in (and are filed with the intention of resulting in) a sale of substantially all the debtor’s assets followed by the distribution of the sale proceeds to creditors (and equity holders in the rare cases where there are enough proceeds) according to the Bankruptcy Code’s “priority scheme.”
If you were to go back and study the history of bankruptcy, including the legislative history surrounding the enactment of the Code, you would readily see that business bankruptcy exists to serve two primary, but ostensibly conflicting, goals.
One of these goals is that of maximizing the value of the debtor’s assets. The other is that of preserving “going concern” and all that implies (i.e. preserving jobs, generating future tax revenue, serving other good social ends, and perhaps even permitting the equity owners to continue to own equity). This second goal is one of the reasons that U.S. bankruptcy law generally leaves “old equity” (the pre-petition equity owners) in control of the debtor after the filing of bankruptcy.²
A fundamental problem with leaving equity in control is that when a business is insolvent (or nearly so), equity (and junior creditors) nearly always gains from taking risk. Liquidate today and equity holders get nothing. Keep the business going and they may have a chance to recover.
Creditors tend to be correspondingly risk-averse. Liquidate today and they (at least the most senior creditors) are more likely to get paid. Take a gamble by keeping the business going equity has the highest upside, while the creditors bear the greatest risk of loss.
The point is not that creditors always favor liquidation—clearly, that’s not true—but the risk-reward calculation is different for creditors than for equity holders. It is similarly different for junior creditors (unsecured creditors, for example) than it is for senior creditors (secured creditors, for example). There can be no doubt that chapter 11 encourages, rather than resolves, this tension—as if deliberately to allow the court to choose, from case to case and even from time to time within a case, whether “assets” or “equity” will dominate.
At this point we reach back again to the concept of valuation, which bears a central role in determining who gets to decide the direction in which a chapter 11 case will go.
In bankruptcy valuation is a critical issue in disputes regarding the “adequate protection” of a secured creditor’s collateral. Whether a creditor is adequately protected, in turn, is the key question that a court must answer when faced with whether to permit a debtor to (i) use cash collateral, (ii) enter into DIP financing, and (iii) overcome a lender’s request to lift the automatic stay and take its collateral. And as we explore valuation in each of these disputes, take note that while the context for each is different, the evidence at issue and, the issue itself is largely the same.
Adequate protection, and thus valuation, also plays a pivotal role in most lift stay motions. The automatic stay prevents creditors from foreclosing on the debtor’s assets but the automatic stay can be overcome by a creditor’s motion seeking to lift the automatic stay. To successfully lift the automatic stay, a secured creditor must show that its collateral will not be “adequately protected” if left in the possession of the debtor.
If a lender has a security interest in a debtor’s cash, which includes both cash and cash equivalents (e.g., cash in a bank account, the proceeds of accounts receivable, rents from an office building or hotel), the debtor must have the lender’s consent or a court order before it can use that cash collateral. Bankruptcy Code § 363(c) provides that a debtor may use “cash collateral” only with (1) creditor consent or (2) court order.
A debtor will typically need immediate access to cash collateral in order to continue operating when it files for bankruptcy and will therefore commonly file a motion for authority to use cash collateral as one of its “first-day motions.”³ If the parties do not reach an agreement regarding the use of cash collateral, a contested hearing will be held to determine the debtor’s right to use the cash collateral. In a hearing on the matter, the prepetition creditor must prove the “validity, interest, extent” in the cash collateral; and the debtor must prove that the cash collateral is adequately protected. The issue of valuation is commonly the sine qua non of determining whether a lender’s interest is in fact adequately protected.
When the use of cash collateral is not sufficient to fund ongoing operations, a debtor must look to other sources of funds. In these instances, a debtor may need to borrow “new money.” In doing so, a potential lender will often be willing to loan only if it is granted a security interest that is superior to that of existing secured creditors. And for a debtor to grant such priming lien, it must show that the creditor whose lien is to be primed will be adequately protected, which again is often decided by the determination of a valuation of the lender’s interest in its collateral.
Bankruptcy Code § 364 authorizes the debtor to “obtain credit,” and outlines the following four paths by which a lender may be granted priority status for money advanced to a debtor after it filed for bankruptcy:
[Editor’s Note: to read more about how Debtors finance Chapter 11 cases, read When Your Borrower Files for Bankruptcy (DIP Financing, Cash Collateral, and Adequate Protection) and Dealing With Distress for Fun & Profit – Installment #17 – Overview of DIP Financing and Cash Collateral Motions. You may also benefit from attending the webinar, BANKRUPTCY BATTLE ROYALE- Cash Collateral and DIP Loan Contests.]
Bankruptcy Code § 362(d) offers two principal paths by which a creditor can obtain relief from the automatic stay that goes into effect immediately upon a debtor’s entry into bankruptcy (which, in the absence of stay relief prevents a creditor from seeking to take its collateral from the debtor). The first is “cause, including lack of adequate protection.” If the court finds that the lender is entitled to adequate protection, but the debtor cannot or will not provide it, then the lender is entitled to stay relief. This provision suggests that a lack of adequate protection is not the only “cause” justifying relief from the stay, but it is the only one we will focus on here.
The second path to obtaining stay relief is satisfied if there is no equity in the property and the property is “not necessary to an effective reorganization.” The no-equity prong means the debt secured by liens on the property exceeds the value of the property. The secured creditor bears the burden of proving the no-equity prong. The import of value should be clear.
A debtor can combat a motion to lift the automatic stay by showing that it is able to adequately protect (per Bankruptcy Code § 361) the lender’s collateral via periodic cash payments to the lender, paying post-petition interest, or granting the lender additional liens on previously unencumbered assets.
For example, where the primary collateral encumbered by the lender’s lien is accounts receivable, it is common for the lender to be granted a “replacement lien” on the debtor’s receivables generated post-petition. Such protection is significant because Bankruptcy Code § 552 operates to cut off any receivables lien as of the bankruptcy filing date. A replacement lien enables the debtor to spend the proceeds of the receivables that are subject to the lender’s original lien in exchange for a lien on new “replacement” receivables. If the debtor continues to generate new receivables at the same rate or a higher rate as it spends the proceeds of old (prepetition) receivables, then the lender is adequately protected.
Alternatively, if the secured lender has an “equity cushion” in the collateral it is seeking stay relief to foreclose upon, then that lender will be deemed adequately protected because the use of cash collateral is unlikely to present an unfair risk to the secured lender.
Even in the absence of an equity cushion, adequate protection may be deemed to exist. If the debtor is using the proceeds of the secured lender’s hard collateral to preserve that hard collateral, for example, it may be deemed adequately protected. Rents generated by an apartment building if used to preserve and maintain the building, for example, can result in a court concluding that the secured lender’s interest will be adequately protected.
[Editor’s Note: Read Dealing With Distress For Fun & Profit – Installment #12 – Stay Relief Strategy? to learn more about the automatic stay. You may also benefit from attending the webinar, BANKRUPTCY BATTLE ROYALE- Lift-Stay Battles]
As can often be the case in politics, “where you stand depends on where you sit.” Valuation is the crucible in which a restructuring plan is negotiated, and parties take fairly predictable positions depending on where they stand in the capital structure.
When a chapter 11 plan is confirmed, senior secured creditors must be paid in full up to the value of their interest in the collateral before junior secured creditors can be paid anything. Likewise, all secured creditors must be paid the value of their collateral before unsecured creditors can be paid anything. The gradations do not stop there. Some unsecured creditors take priority over others. Finally, all creditors must be paid before equity holders can be paid anything on account of their equity. This is the so-called priority ladder in action.4
When a chapter 11 plan allocates consideration (whether cash, promissory notes, or equity securities) to various creditor (and possibly equity) classes, it must do with reference to a value of the reorganized company. Those at the bottom of the priority ladder are apt to argue that the reorganized company is more valuable because if it less valuable they may get no distribution at all. Likewise, parties at the top of the ladder will be inclined to argue that the reorganized company is less valuable because a lower valuation means they will get more of the total distribution.5
This concept is best illustrated by a simple hypothetical: Senior “Class A” is owed $1 million by a debtor, and the reorganization plan calls for Class A to get 100% of the stock of the reorganized debtor as payment of its claims. “Class B” consists of the existing interests of equity holders of the debtor and is therefore junior to Class A. Under the absolute priority rule, Class A has priority over Class B and is entitled to receive payment in full of its claims before any payment is made to Class B.<sup?6 But since Class A is set to receive 100% of stock of the new equity, there will be nothing left to pay Class B. This plan can be confirmed (assuming all other requirements are met), as long as the value of the new equity does not exceed $1 million. As a result, junior Class B will have a strong incentive to argue that the enterprise value is higher than $1 million.
With that warm-up, let’s take a stab at a case study.
Exide Technologies manufactured and supplied lead acid batteries for transportation and industrial applications. It has operations across the world.8 Prior to its chapter 11 filing, Exide owed a group of bank lenders about $700 million and it had also issued many senior and convertible notes.
In September 2003, Exide proposed a second amended disclosure statement and its related third amended joint plan of reorganization.9 A few days later, the bankruptcy court approved the disclosure statement and allowed the debtor to solicit acceptances of its amended plan.10
The plan called for the following:
Several parties, including the creditors’ committee, filed objections to the plan arguing that the reorganized debtor’s enterprise value would be worth far more than the debtor estimated and that as a result, the secured lenders would be receiving more than payment in full of their claims.
The Court held a confirmation hearing and heard evidence relating to each party’s assertion as to what the reorganized debtor’s enterprise value would be, to determine whether the proposed plan was fair and equitable. The debtor presented evidence through its valuation expert that the reorganized debtor’s enterprise value would be between $950 million and $1.050 billion. The committee presented evidence through its valuation expert assessing the reorganized debtor’s enterprise value as being significantly higher—between $1.478 billion and $1.711 billion.
The court considered (as is common) three distinct valuation methods:
Exide’s expert attempted to argue that a chapter 11 “taints” the enterprise and thus impacts negatively its securities and future earning potential. The court disagreed, concluding that Exide’s expert subjectively and inappropriately altered the valuation methods, and holding that restructuring is a benefit to the enterprise value. The court found the reorganized enterprise’s value between $1.4 billion and $1.6 billion and thus found the proposed plan to not be fair and equitable, because it would have paid the senior lenders more than what they were owed, leaving nothing for junior classes of creditors.
Now take another look at footnote 10 above. Then look at the use of the phrase “fair and equitable” in the discussion of Exide above. Do you see that the fight in Exide was a “cramdown” fight? Let’s discuss this in a bit more detail.
Valuation is also central in a plan “cramdown” context. The Bankruptcy Code permits a debtor to force plan confirmation over the objection of a class of creditors (“cramming” the plan down despite creditor protests). To cram down on a secured creditor, a debtor must demonstrate that the creditor will either receive a lien on property retained by the debtor, or cash totaling the value of the secured portion of the creditor’s claim.13 To illustrate, consider the following hypothetical:
Suppose a debtor owes $1 million to a creditor under a secured lending agreement providing for payment in annual installments over 10 years, with interest at 10% (your calculator will tell you this amounts to $162,000 per year). The debt is secured by Farm, which, luckily, is worth $1 million- as it just so conveniently happens for the sake of this example- the same amount as the debt.
The creditor has made it clear that it favors no resolution other than immediate payment in full. The debtor certainly can’t do that; indeed, it can’t even meet the installments. But the debtor could pay a lower installment.
The debtor analyzes its options and determines that if the creditor increases the loan period from 10 to 20 years at the same rate of interest, then the debtor’s annual payment would fall to around $127,000. The debtor concludes it can pay $127,000 each year.
Can the debtor impose this deal under the cramdown rule? It’s a close call. The rule provides that a debtor can impose the plan if the creditor gets a payment stream with a present value equal to the amount of its secured claim. In this case, the debtor is proposing a payment stream with a value equal to the creditor’s claim—if 10 percent is the right interest rate.
The creditor will argue that a 20-year loan is riskier than a 10-year loan, and so it has a right to a higher interest rate. But if the interest rate is higher than 10%, a stream of 20 payments of $127,000 has a present value less than $1 million.
The exact fight here would be one over what the interest rate should be. And who would be the participants in this fight? Dueling experts (the lawyers would be more like the boxer’s trainers- think Mickey to Rocky).
In In re Sunnyslope Housing Limited Partnership,14 the Ninth Circuit held that the proper “cramdown” valuation of a secured creditor’s collateral is replacement value rather than foreclosure value—even if foreclosure value might yield a higher valuation of the secured creditor’s collateral.15
The debtor in Sunnyslope developed a low-income housing development, borrowing money to do so. The loans were provided under a condition that the debtor, indeed, develop low-income housing.16 The housing restrictions were ingrained in the deed and ran with the land unless foreclosed-on.
After defaulting on its loans, but before a $7.65 million foreclosure sale was finalized, Sunnyslope filed for chapter 11, where it sought to cramdown a reorganization plan over the objection of its first mortgagee, First Southern National Bank, which held a secured claim against Sunnyslope for approximately $5 million.
In its proposed chapter 11 plan, Sunnyslope provided for payment in full of First Southern’s secured claim over a term of 40 years at a rate of 4.4% interest, and a balloon payment at the end of the loan term (without interest).17 In doing so, Sunnyslope’s plan valued First Southern’s collateral at $2.6 million, based on the property’s continued use as low-income housing by the reorganized Sunnyslope.18
In opposition, First Southern argued that Sunnyslope’s plan did not treat First Southern’s claim as secured to the extent of the value of its interest in Sunnyslope’s property and could therefore not be crammed down. First Southern offered expert testimony in its favor that the correct valuation of the property at $7.74 million, based on the assumption that, in foreclosure, the property would be freed from restrictions that it be used for low-income housing.19
Thus, the pivotal issue in the case became how to appropriately value First Southern’s collateral.
The bankruptcy court concluded that the debtor’s proposed $2.6 million valuation was appropriate, based on the property continuing to be used as low-income housing. It confirmed the plan over First Southern’s objection on that basis. On appeal, the Ninth Circuit affirmed the bankruptcy court’s decision.
The Ninth Circuit held that, when determining valuation in the context of a cramdown, a court must consider the actual use of the property, and that replacement value was the value of the property assuming its continued use after reorganization.
In discussing its holding, the Ninth Circuit adopted the reasoning of the Supreme Court’s opinion in Associates Commercial Corp. v. Rash,20 the main case over which Sunnyslope and First Southern fought. In Rash, the Supreme Court adopted a replacement value standard for valuing collateral in a cramdown context and rejecting a foreclosure value standard since the foreclosure sale would not take place, and therefore the value of the collateral “hinged [on] the property’s ‘disposition or use.’”21 Thus, even though First Southern’s collateral could have a higher value at foreclosure, the Ninth Circuit adhered to the replacement value standard from Rash.
Sunnyslope provides a window into understanding not only the importance of valuation, but also the level of discretion courts can exercise when valuation is in dispute. Notwithstanding its importance in a case, a judge still has wide latitude to make a determination as to how value should be measured.22
Most, but not all, corporate bankruptcy cases proceed in the same general order. The first part of a case is often occupied by activities necessary to assure continued operations, for example, and plan confirmation generally occurs toward the end of a case. In fact, many business people without prior experience with bankruptcy assume that plan confirmation marks the end of a case. And while that is in some ways accurate, it is in other ways not accurate at all.
Avoidance actions are commonly brought after confirmation, and the issue of valuation is pivotal in such actions.
Bankruptcy Code § 548 gives the debtor (or a successor in interest to the debtor, like a liquidating trustee) the authority to avoid fraudulent transfers under two circumstances.23
In the first scenario, under Bankruptcy Code § 548(a)(1)(A), the debtor may avoid a transfer that was made with the actual intent to “hinder, delay or defraud” a creditor—call it an “actual fraud” fraudulent transfer. In the second scenario, under § 548(a)(1)(B), the debtor may avoid a transfer made for “less than a reasonably equivalent value,” sometimes referred to as “constructive fraud.” If the debtor relies on this constructive fraud premise, then it must also show that the debtor was one of the following (these are simplified):
In the context of an actual fraud claim, if the plaintiff can show that the debtor intended to defraud interested parties, then it doesn’t have to worry about issues of solvency or value. But showing actual intent is very difficult to do. Thus, most fraudulent transfer actions are brought under § 548(a)(1)(B), thus making a valuation expert very important to analyze and opine both on solvency, as well as reasonably equivalent value.
A sine qua non of bankruptcy is equality of distribution among similarly-situated creditors. To use a simple example, assume a debtor has 10 unsecured creditors, owes eight of them $10 each and owe the other two $100 each. The general rule is that each creditor will be paid pro rata.
How is this calculated? First, we divide what the creditor is owed (say, $10 in the case of any of the eight) by the total the debtor owes to all similarly situated creditors ($280 in this example). The math tells us that each of those creditors who is owed $10 is owed 3.57% of the total amount owed by the debtor to all is unsecured creditors. Since there is $100 to go around, each of the creditors who is wed $10 will be paid $3.57.
But what if one of those creditors, let’s call him Peter, was paid in full shortly before the bankruptcy case was filed? How might have this happened? Well:
Regardless of the reason, Peter may be the recipient of a preference. And the debtor (or trustee, standing in the debtor’s shoes) can seek to avoid the preference so that the funds are returned to the estate and all creditors (including Peter) can be paid pro rata as if the preferential payment had not been made.
The core of preference law is in § 547 of the Bankruptcy Code. The elements of a preference claim are stated in § 547(b). It provides that a debtor may (subject to certain defenses) avoid a transfer to a creditor for a preexisting debt, if the transfer was made while the debtor was insolvent and was made in the 90 days24 before the debtor filed for bankruptcy—so long as the payment constituted more than would get as a distribution in a chapter 7 bankruptcy case.
Akin to avoiding the fraudulent transfers, two elements of the prima facie elements involve valuation: insolvency and the determination as to whether the creditor received more than it would have in a chapter 7 liquidation. And while these two elements are not often contested in preference litigation, parties must hire valuation experts if they are.
Valuation’s crucial role in a restructuring/insolvency situation is undeniable. Trying to guide a company through the maze that is corporate restructuring (regardless of the company’s size and regardless of whether it in bankruptcy) without at least a basic understanding of valuation is like trying to understand Better Call Saul without first having watched Breaking Bad—it can be done but it’s not a good idea.
This point is especially well illuminated by the example of the Sunnyslope case, illustrating the wide latitude courts may exercise in determining the proper method of valuation, swinging the pendulum in favor of debtors or lenders as they may see fit, and serving as a cautionary tale to those wading into the deep end of the distressed debt investing pool.
[Editor’s Note: To learn more about corporate restructuring, we suggest these Financial Poise webinars. To learn more about valuation fights in the context of corporate restructuring, we suggest these Financial Poise webinars.]
The comparable company analysis assesses a company’s going concern value. Exide argued that it was best to assess the reorganized enterprise’s value based on historical EBITDAR (earnings before interest, taxes, depreciation, amortization, and restructuring costs). It used the EBITDAR from a year ending in June 2003, the latest available at the confirmation hearing, resulting in $179 million. The Committee argued that projected EBITDAR would best reflect the valuation of the reorganized Exide because it would bestow on it the benefit of the restructuring. The court agreed with the Committee, reasoning that valuation should be forward-looking, and concluded it was appropriate to use the projected EBITDAR.
Each side chose a multiple by comparing the enterprise value of comparable publicly-traded companies to their trailing twelve months EBITDA, and both sides seemed to have arrived at a similar multiple, with Exide at 7.2x and the Committee at 7.7x. Exide’s expert, however, adjusted his multiple downward to 5.0x to 6.0x, based on his judgment that this comparable for a particular part of Exide’s business should be given less weight. The Court rejected the subjective adjustment and determined that the proper multiple was between 7.2x and 7.7x.
The debtor’s valuation expert used two merger and acquisition transactions from 2002, which placed the values of the companies at EBITDA multiples of 6.0x and 7.2x. The Committee argued that valuation should be assessed based off multiple acquisitions that occurred since 1992, but the court disagreed arguing the market has changed. As a result, the court applied a straightforward method and adopted the 6.4x factor, that was later applied to Exide’s $188 million EBITDA figure.
The objective of the DCF analysis is to provide enterprise value by discounting the projected cash flow based on the weighted average of cost of capital, which is the weighted average costs of equity and debt. Exide argued that because it was emerging from a reorganization, it may face a substantial risk in meeting its five-year plan. The court found Exide’s valuation expert’s subjective DCF approach strayed from generally accepted approaches in the field.
Jonathan Friedland is a partner in Sugar Felsenthal Grais & Helsinger LLP’s Chicago office. He is ranked AV® Preeminent™ by Martindale.com, has been repeatedly recognized as a “SuperLawyer”, by Leading Lawyers Magazine, is rated 10/10 by AVVO, and has received numerous other accolades. He has been profiled, interviewed, and/or quoted in publications such as Buyouts…
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