A recent case from the Sixth Circuit Bankruptcy Appellate Panel, In re Buttermilk Towne Center, LLC, 2010 Bankr. LEXIS 4563 (BAP 6th Cir. 2010), appears to have strengthened the undersecured lender’s hand in single asset real estate Chapter 11 cases. An undersecured lender is one whose collateral is worth less than the amount the debtor owes, a common scenario in today’s market. In the Buttermilk case, the Debtor defaulted on its obligation to repurchase bonds whose proceeds had funded a significant, multimillion dollar loan. The Debtor had borrowed the money to develop a commercial center in Crescent Springs, Kentucky. The Debtor leased the center from Crescent Springs, and paid its lease payments with rents generated by subleases with the center’s tenants.
The Debtor filed a single asset real estate Chapter 11 case after defaulting, and sought bankruptcy court authority to use the rents as cash collateral to pay the Debtor’s counsel’s attorney fees. The Debtor offered the lender a replacement lien in the rents (which constituted substantially the Debtor’s sole income source) as adequate protection. The Sixth Circuit Bankruptcy Appellate Panel ruled that the replacement liens did not constitute adequate protection of the lender’s secured claim because there was no equity cushion in the collateral, i.e., the lender was undersecured, and because the lender already had a security interest in the rents. Accordingly, the Debtor was not allowed to use rents to pay professional fees without the lender’s consent.
It seems apparent that the lender’s undersecured status is a key factor in the decision. The single asset real estate debtor cannot reorganize if it cannot use the rents unless the lender consents or the debtor owns unencumbered assets, which is not the case if the secured creditor is undersecured. So a practice pointer from the lender’s standpoint is to be prepared immediately upon the filing of a Chapter 11 case by a single asset debtor to prove through a valuation hearing that the lender is undersecured. If the lender succeeds, it can either cause the case to be dismissed or can use its leverage to obtain highly favorable terms in any attempted reorganization by the debtor. The single asset real estate debtor, on the other hand, needs to realistically evaluate its options upon default. If there is no equity in the property, the debtor’s principals are probably better advised to consider non-bankruptcy alternatives to retaining control of the property.
Recently, representatives from our firm were invited to meet with and participate in executive level meetings at Cisco Systems headquarters in San Jose, California. We thought we were going to spend two days playing with top secret tech toys which are being developed behind darkened windows and screens. Although we did see some really innovative things, most of our time was spent interacting with Cisco executive team members discussing organizational strategies relating to how people collaborate and execute the organization’s mission statement. From the moment the first session commenced we knew we were in for a transformative experience. Perhaps the best way to describe it is that we participated in a mini MBA boot camp. Over the next several posts I will share some of the information we learned.
2011 is the year when the Baby Boomers begin to turn 65 years old. This trend will continue for the next twenty years. How is the Real Estate industry going to respond to this demographic reality ? The impact on society is enormous: housing, transportation and work force issues abound.
After 15 years of annual increases, the overall number of residential and commercial foreclosures in Ohio actually decreased by 4% in 2010 compared to 2009, according to a report by the Supreme Court of Ohio. Of course, not every county was so fortunate with 30 out of 88 counties experiencing an increase in foreclosures. Cuyahoga County, home to our Cleveland office, still leads the state in the sheer number of foreclosures although at 12,825, there were 9% fewer foreclosures than in 2009. In Franklin County, home of our Columbus office, foreclosures rose by 2%. In Hamilton County, home of our Cincinnati office, foreclosures decreased by 2%. For complete information for all 88 Ohio counties from 2001-2010, the Supreme Court’s spreadsheet is available at:
A recent article in REJournals.com
The ubiquitous refrain at any gathering of commercial real estate professionals in the past 24 months can be summed up in a few short questions: Are you busy? Who is lending? No, seriously, who is lending? And — of course — when will this end?
The Associated General Contractors of America’s and Navigant’s recent industry-wide survey "Finds More Construction Firms Plan to Hire than Lay Off in 2011." Read the
Thanks to our friend, Norm Khoury of Cassidy Turley, for sharing the 2011 Handbook of Living a Balanced Life. The start of the year is a good time to remind us of these thoughts.
Jones Lang LaSalle seems to think so. We hope that they are right. As reported by
A federal lawsuit in New York