Posted by Kenneth Anderson:
What New Bond Covenants Would You Demand
http://volokh.com/archives/archive_2009_05_31-2009_06_06.shtml#1243955114


   as protection against political risk following the government's
   pressures on senior and secured creditors of Chrysler?

   In my development finance work in the developing world, I have
   undertaken a lot of negotiations with businesses (mostly media
   companies) in places ranging from South Africa to Guatemala to Serbia
   looking to borrow money. The nonprofit private equity fund I work with
   has standard loan documents, of course, and over the years has looked
   to tailor them to fit risky investment in these environments with less
   than perfect adherence to the rule of (contract) law.

   As I watch the Detroit restructurings unfold, particularly the
   strong-arming of senior and secured creditors, I wonder what new
   covenants creditors might want to put into new bond issuances by US
   businesses that might eventually become entangled with government.
   I've been reflecting on this looking back over the standard documents
   that I have used over the past twenty years. Interestingly, the
   contract forms I've used do not have very many special political risk
   terms.

   Why not? Because the general assumption is that no political risk
   covenant can really protect you in a place where contracts are not
   enforced -- political risk of that kind involves yanking the floor out
   from under the investor altogether. If a contract term that provides
   for secured creditor status will not be enforced, why think that a
   covenant requiring repayment in case of political risk such as
   expropriation will be enforced either? The nature of political risk is
   that it is a risk running to the very rules of the game.

   Of course that is not completely true. There are political risks and
   there are political risks, if you are investing in the developing
   world or, alas, today the United States. The United States seems, in
   these contract matters, not to resemble the rule of law in Angola,
   sure -- but it is distinctly starting to resemble, ever so
   little-bit-by-little-bit, the rule of law in China. There is a certain
   amount of neutral contract enforcement, but also a hefty amount of
   political thumb on the scale, and many uncertainties attached -- and
   without getting hysterical about it, the American trend line is going
   that direction. It might be most useful to look at Western contracts
   with Chinese companies to get good ideas on "mixed" cases of this
   'sort-of-rule-of-law, sort-of-not', because that seems to be the drift
   of Obama administration industrial policy.

   So here's my question. What covenants would you put into a new bond
   issuance by an American company -- say a non-Detroit car manufacturer
   -- or an insurance company or a health care provide? Some company in
   which you thought the chances of US government behavior of the kind on
   display in Chrysler were not negligible or hypothetical over the next
   decade. Assume you are looking for senior creditor status; not so
   worried about special issues of secured versus senior status - focus
   on political risks common to all senior creditors in this new (third)
   world.

   Plenty of commentators have said that creditors will, over time,
   demand higher interest rates to compensate them for higher risk from
   political re-ordering of creditor priority. True. Less discussed (as
   far as I know but I welcome links to good discussions) is that
   creditors and borrowers will presumably also look to reduce that
   interest rate hike by trying to reduce the uncertainties of political
   risk, through bond covenants that would allocate the risks today of
   future political contingencies. If you can't trust the rule of
   contract law at all, then those efforts are for naught. But if what
   happens if you think you can't trust creditor priority in bankruptcy
   -- but other kinds of contract terms might be enforced? Should you
   negotiate for those covenants, or is this like being a little bit
   pregnant?

   Here's an example. Something I have sometimes negotiated into
   developing world debt covenants is a political risk form of a poison
   put. It is merely a standard poison put, used to address changes of
   corporate control, adapted to political risk. Nothing special. It
   simply says that if certain political contingencies occur, such as a
   government (or union) move to take direct or indirect control of the
   borrower-corporation, the creditor bondholders can at their option put
   the bonds back to the corporation and require full repayment of
   principal, and whatever is negotiated for interest and penalties. It
   is a response to this particular political risk, not of full-blown
   rule of law breakdown -- but instead of what might be under local law
   a legal move by the government. It allocates the risk and presumably
   gives the borrower-corporation some incentive not to seek government
   involvement.

   I haven't inserted it often, and have never even thought about trying
   to enforce it (Montenegro or Macedonia? Zimbabwe? Indonesia?). Is this
   kind of political risk poison put worth using in future American
   corporate bonds? Or is it 'a little bit pregnant' and no matter what
   you wrote in the poison put, it would be subject to the same political
   re-writing? After all, though I haven't looked, isn't it likely that
   Detroit's existing bonds have change of control provisions anyway?
   Leaving aside its practical effect (or not), what about the effect on
   the interest rate? Would this be likely to reduce the uncertainties
   and so reduce the interest rate for risk? Or is it a mostly futile
   exercise?

   Finally, let me ask if there are any other covenants you would think
   to negotiate into future bond issuances to protect against political
   risks. (And I have to say, the idea that I would ever be publicly
   airing such a question about leading US corporations and the bond
   market, looking to my experiences in the developing world for counsel
   and advice is, well, shocking.)

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