tommy271
Forumer storico
Winston Capital reseñó sobre el artículo de @FT para la reestructuración económica de #Venezuela en un futuro (https://www.youtube.com/watch?v=1ItvN1KAK4g …).
Titoli di Stato paesi-emergenti VENEZUELA e Petroleos de Venezuela - Cap. 2
- Creatore Discussione tommy271
- Data di Inizio
Jsvmax79
Forumer storico
Scenari possibili.
1. Gli osservatori e conoscitori della crisi del Venezuela considerano come primo probabile scenario la vittoria delle opposizioni e l’immediata negazione di tale vittoria da parte del governo. Anzi, ritengono che la frode del chavismo è già in preparazione e sarà messa in essere ben prima che gli elettori si rechino alle urne. Ovviamente se così fosse vuol dire che in Venezuela si aprirà, con conseguenze dolorose imprevedibili, un vero scontro finale che potrebbe coinvolgere direttamente la maggioranza dei Paesi latinoamericani e gli stessi Stati Uniti.
2. Seconda possibilità, forse allo studio da parte di alcuni “esperti”. Di fronte ad una sconfitta certa, il governo, usando qualsiasi pretesto del tipo “attacchi terroristici” (argomento già usato da Maduro in questi mesi), decida di sospendere la consultazione rinviando a data da destinare una nuova elezione. Formalmente il governo non potrebbe essere accusato di atti antidemocratici ma al tempo stesso gli attuali 20 governatori chavisti verrebbero prolungato senza scadenza il loro mandato.
3. Vittoria delle opposizioni riconosciuta dal Consiglio Nazionale elettorale (controllato dal governo), ma senza nessuna conseguenza politica o istituzionale. Il Governo continuerebbe la sua strada con i suoi metodi e i suoi stili come se niente fosse. Maduro e i suoi farebbero di tutto per depotenziare politicamente la vittoria dell’opposizione “separandola” dalla crisi generale del Paese. Forse l’Assemblea Costituente, come nel caso del Parlamento, potrebbe decidere di legiferare (in modo illegale e illegittimo) per ridurre e condizionare il potere dei governatori neoeletti.
4. Il quarto scenario, ritenuto non solo improbabile ma impossibile, ipotizza una vittoria del Governo di Nicolás Maduro. Se vera, autentica e accettata dalle opposizioni e dalla comunità internazionale, ciò rappresenterebbe la fine della crisi con una sconfitta storica per il Tavolo dell’unità democratica e i gruppi alleati
Venezuela, la sfida di ottobre
1. Gli osservatori e conoscitori della crisi del Venezuela considerano come primo probabile scenario la vittoria delle opposizioni e l’immediata negazione di tale vittoria da parte del governo. Anzi, ritengono che la frode del chavismo è già in preparazione e sarà messa in essere ben prima che gli elettori si rechino alle urne. Ovviamente se così fosse vuol dire che in Venezuela si aprirà, con conseguenze dolorose imprevedibili, un vero scontro finale che potrebbe coinvolgere direttamente la maggioranza dei Paesi latinoamericani e gli stessi Stati Uniti.
2. Seconda possibilità, forse allo studio da parte di alcuni “esperti”. Di fronte ad una sconfitta certa, il governo, usando qualsiasi pretesto del tipo “attacchi terroristici” (argomento già usato da Maduro in questi mesi), decida di sospendere la consultazione rinviando a data da destinare una nuova elezione. Formalmente il governo non potrebbe essere accusato di atti antidemocratici ma al tempo stesso gli attuali 20 governatori chavisti verrebbero prolungato senza scadenza il loro mandato.
3. Vittoria delle opposizioni riconosciuta dal Consiglio Nazionale elettorale (controllato dal governo), ma senza nessuna conseguenza politica o istituzionale. Il Governo continuerebbe la sua strada con i suoi metodi e i suoi stili come se niente fosse. Maduro e i suoi farebbero di tutto per depotenziare politicamente la vittoria dell’opposizione “separandola” dalla crisi generale del Paese. Forse l’Assemblea Costituente, come nel caso del Parlamento, potrebbe decidere di legiferare (in modo illegale e illegittimo) per ridurre e condizionare il potere dei governatori neoeletti.
4. Il quarto scenario, ritenuto non solo improbabile ma impossibile, ipotizza una vittoria del Governo di Nicolás Maduro. Se vera, autentica e accettata dalle opposizioni e dalla comunità internazionale, ciò rappresenterebbe la fine della crisi con una sconfitta storica per il Tavolo dell’unità democratica e i gruppi alleati
Venezuela, la sfida di ottobre
Jsvmax79
Forumer storico
Jsvmax79
Forumer storico
OPEC Eyes U.S. Frackers as Venezuela Oil Rigs Hit Low
Venezuela's oil rig count reached a new low in September and OPEC wants U.S. producers to help support prices.
By
Dimitra DeFotis
Oct. 10, 2017 10:28 a.m. ET
The number of oil rigs in Venezuela fell to a new 15-year low in September as the country’s indebted government and economy struggle to invest.
Only 44 oil rigs are operating in Venezuela, half the number of rigs at work in 2013, according to the latest Baker Hughes data. The United States Oil Fund (USO) was up more than 2% in recent trading with the U.S. price of crude up 1.9% to a recent $50.51 per barrel, and the international Brent oil price up 1.3% to $56.52.
Venezuela is a member of the Organization of Petroleum Exporting Countries (OPEC), which on Tuesday pressured U.S. oil producers -- and hedge funds -- to meet with OPEC in its efforts to support oil prices. "U.S. anti-trust legislation prohibits any collective action to influence prices, precisely what OPEC has been doing for ... decades," Reuters notes in its OPEC story today. On Wednesday, OPEC releases production data.
Russ Dallen, a lawyer, publisher and the managing partner of Caracas Capital, notes today that U.S. energy services companies are keeping a presence in Venezuela despite U.S. government sanctions, given the investment needed to tap Venezuela's bountiful oil reserves. He writes:
"Last year with great fanfare, the Venezuelan government announced billions of dollars of new investments in its oil industry to increase production, from Halliburton (HAL), Schlumberger (SLB) and a small, unknown U.S. company known as Horizontal Well Drillers, based out of Oklahoma. As the drilling data above shows, those investments do not seem to have been forthcoming and the number of active drills continues to fall. One of the reasons is that PDVSA is not paying its debts. ... Venezuela's unpaid $636 million debt to Halliburton does not include $200 million in Promissory Notes that Halliburton swapped into PDVSA Promissory Notes in 2016. Likewise, Schlumberger is owed even more by PDVSA according to Schlumberger's 1Q2017 financials - $1.2 billion. Schlumberger then swapped $700 million of that debt into new 2017 issue PDVSA Promissory Notes during the 2nd Quarter of 2017. ... By the way, both the 2016 and 2017 issue PDVSA Promissory Notes are 3 year amortizing financing deals that total over $2 billion and would seem to fall afoul of some parts of the U.S. Government's August O.F.A.C. sanctions on financing PDVSA. ... So, it was with much bemusement that we noticed 2 gringos from a small Oklahoma outfit named Horizontal Well Drillers being trotted out live on Venezuelan TV signing a contract to invest in a $3.2 billion drilling project. It turns out that the firm doesn't have much capital ..."
Bonds issued by the Venezuelan government and government controlled energy producer Petroleos de Venezuela or Pdvsa are among the holdings in the iShares J.P. Morgan USD Emerging Markets Bond ETF (EMB), which was up 0.3% in recent trading. The iShares Latin America 40 exchange-traded fund (ILF) was up 1.5%.
Venezuela's oil rig count reached a new low in September and OPEC wants U.S. producers to help support prices.
By
Dimitra DeFotis
Oct. 10, 2017 10:28 a.m. ET
The number of oil rigs in Venezuela fell to a new 15-year low in September as the country’s indebted government and economy struggle to invest.
Only 44 oil rigs are operating in Venezuela, half the number of rigs at work in 2013, according to the latest Baker Hughes data. The United States Oil Fund (USO) was up more than 2% in recent trading with the U.S. price of crude up 1.9% to a recent $50.51 per barrel, and the international Brent oil price up 1.3% to $56.52.
Venezuela is a member of the Organization of Petroleum Exporting Countries (OPEC), which on Tuesday pressured U.S. oil producers -- and hedge funds -- to meet with OPEC in its efforts to support oil prices. "U.S. anti-trust legislation prohibits any collective action to influence prices, precisely what OPEC has been doing for ... decades," Reuters notes in its OPEC story today. On Wednesday, OPEC releases production data.
Russ Dallen, a lawyer, publisher and the managing partner of Caracas Capital, notes today that U.S. energy services companies are keeping a presence in Venezuela despite U.S. government sanctions, given the investment needed to tap Venezuela's bountiful oil reserves. He writes:
"Last year with great fanfare, the Venezuelan government announced billions of dollars of new investments in its oil industry to increase production, from Halliburton (HAL), Schlumberger (SLB) and a small, unknown U.S. company known as Horizontal Well Drillers, based out of Oklahoma. As the drilling data above shows, those investments do not seem to have been forthcoming and the number of active drills continues to fall. One of the reasons is that PDVSA is not paying its debts. ... Venezuela's unpaid $636 million debt to Halliburton does not include $200 million in Promissory Notes that Halliburton swapped into PDVSA Promissory Notes in 2016. Likewise, Schlumberger is owed even more by PDVSA according to Schlumberger's 1Q2017 financials - $1.2 billion. Schlumberger then swapped $700 million of that debt into new 2017 issue PDVSA Promissory Notes during the 2nd Quarter of 2017. ... By the way, both the 2016 and 2017 issue PDVSA Promissory Notes are 3 year amortizing financing deals that total over $2 billion and would seem to fall afoul of some parts of the U.S. Government's August O.F.A.C. sanctions on financing PDVSA. ... So, it was with much bemusement that we noticed 2 gringos from a small Oklahoma outfit named Horizontal Well Drillers being trotted out live on Venezuelan TV signing a contract to invest in a $3.2 billion drilling project. It turns out that the firm doesn't have much capital ..."
Bonds issued by the Venezuelan government and government controlled energy producer Petroleos de Venezuela or Pdvsa are among the holdings in the iShares J.P. Morgan USD Emerging Markets Bond ETF (EMB), which was up 0.3% in recent trading. The iShares Latin America 40 exchange-traded fund (ILF) was up 1.5%.
Jsvmax79
Forumer storico
Buchheit calls for post-Maduro Venezuelan debt standstill
Christopher Spink
3 MIN READ
LONDON, Oct 10 (IFR) - Any incoming regime in Venezuela replacing President Nicolas Maduro will have to consider how to gain temporary relief from paying its creditors without giving them legal grounds to accelerate their outstanding debts, according to legal experts.
One solution will be to create “some form of temporary standstill on creditor actions”, according to Lee Buchheit, partner at law firm Cleary Gottlieb, and Mitu Gulati, law professor at Duke University.
Venezuela is struggling to service debts with a combined face value of US$63bn after a collapse in oil prices left it with dwindling revenues and a huge fiscal shortfall. Talks are already being carried out bilaterally between Venezuela and its sovereign creditors, China and Russia, which are owed US$37.2bn between them, but policy-makers in the country still face complex challenges to find a long-term solution.
In an article for FT Alphaville, Buchheit and Gulati acknowledge that their earlier idea of persuading holders of Venezuelan sovereign bonds and those of state-owned oil company PDVSA simply to extend the maturities of their instruments while keeping most other terms the same, may not be workable in this situation. Voter thresholds of up to 100% are too high in the bonds.
Instead they say a standstill mechanism would be best approved by a “bare majority of the holders of each instrument” or two-thirds of each republic bond, since the latter have collective action clauses that can sweep up holdouts from such votes. That level of votes is enough to amend the voting threshold to allow an acceleration of the bonds from 25% plus one to a higher level.
Buchheit and Gulati suggest this could be used as soon as a new administration takes over to lift voting thresholds to over 50% for six months to allow the regime, and outside bodies like the IMF, to assess the situation and then propose a more lasting debt restructuring. This would stop accelerations during this six-month period if principal or interest is unpaid in that time, unless a majority opted to do so.
This contrasts with a plan put out by Mark Walker, former lead adviser to Greece for Lazard during the country’s €200bn debt restructuring in 2012 and now managing director at Millstein & Co. He and Richard Cooper, another partner at Cleary Gottlieb, suggested that a new Venezuelan regime should put PDVSA into bankruptcy protection, either through US Chapter 15 or another regime, before defaulting.
“Our preference is to look for solutions that can be implemented in a manner consistent with the underlying legal instruments rather than jettison the contracts in favour of more adventuresome approaches such as trying to jury-rig a bankruptcy proceeding in one jurisdiction or another,” Buchheit and Gulati wrote.
Buchheit also advised Greece on its debt restructuring in 2012. (Reporting by Christopher Spink)
Our Standards:The Thomson Reuters Trust Principles.
Christopher Spink
3 MIN READ
LONDON, Oct 10 (IFR) - Any incoming regime in Venezuela replacing President Nicolas Maduro will have to consider how to gain temporary relief from paying its creditors without giving them legal grounds to accelerate their outstanding debts, according to legal experts.
One solution will be to create “some form of temporary standstill on creditor actions”, according to Lee Buchheit, partner at law firm Cleary Gottlieb, and Mitu Gulati, law professor at Duke University.
Venezuela is struggling to service debts with a combined face value of US$63bn after a collapse in oil prices left it with dwindling revenues and a huge fiscal shortfall. Talks are already being carried out bilaterally between Venezuela and its sovereign creditors, China and Russia, which are owed US$37.2bn between them, but policy-makers in the country still face complex challenges to find a long-term solution.
In an article for FT Alphaville, Buchheit and Gulati acknowledge that their earlier idea of persuading holders of Venezuelan sovereign bonds and those of state-owned oil company PDVSA simply to extend the maturities of their instruments while keeping most other terms the same, may not be workable in this situation. Voter thresholds of up to 100% are too high in the bonds.
Instead they say a standstill mechanism would be best approved by a “bare majority of the holders of each instrument” or two-thirds of each republic bond, since the latter have collective action clauses that can sweep up holdouts from such votes. That level of votes is enough to amend the voting threshold to allow an acceleration of the bonds from 25% plus one to a higher level.
Buchheit and Gulati suggest this could be used as soon as a new administration takes over to lift voting thresholds to over 50% for six months to allow the regime, and outside bodies like the IMF, to assess the situation and then propose a more lasting debt restructuring. This would stop accelerations during this six-month period if principal or interest is unpaid in that time, unless a majority opted to do so.
This contrasts with a plan put out by Mark Walker, former lead adviser to Greece for Lazard during the country’s €200bn debt restructuring in 2012 and now managing director at Millstein & Co. He and Richard Cooper, another partner at Cleary Gottlieb, suggested that a new Venezuelan regime should put PDVSA into bankruptcy protection, either through US Chapter 15 or another regime, before defaulting.
“Our preference is to look for solutions that can be implemented in a manner consistent with the underlying legal instruments rather than jettison the contracts in favour of more adventuresome approaches such as trying to jury-rig a bankruptcy proceeding in one jurisdiction or another,” Buchheit and Gulati wrote.
Buchheit also advised Greece on its debt restructuring in 2012. (Reporting by Christopher Spink)
Our Standards:The Thomson Reuters Trust Principles.
Jsvmax79
Forumer storico
Buchheit and Gulati: The Coming Need for a Standstill in Venezuela
4
11 HOURS AGO
By: Guest writer
By Lee C Buchheit and Mitu Gulati
When officials of a new administration finally take office in Venezuela they will not have a pleasant first day on the job. On the present trajectory, they are likely to find international reserves exhausted, an oil sector in disrepair, a colossal debt, ruptured relations with the international community, hungry and angry citizens. Something disagreeable is apt to slither out of every file drawer they open.
Approaching official sector institutions such as the IMF for financial assistance will also present unusual problems. The Venezuelan authorities have not spoken to the IMF in many years. The last Article IV consultation took place over a decade ago. Unlike other sovereign debt crises, when an IMF mission arrives for the first time in Caracas it will have little or no reliable information about the state of the economy or public sector assets and liabilities. Several months will be needed for the IMF to make even a preliminary assessment of the situation, and no recommendations on an appropriate adjustment program or a debt policy can be formulated in the absence of that assessment.
What happens to Republic of Venezuela and PDVSA debt during this interim period? If the new administration arrives while the external debt is being serviced (the current policy), the authorities may well decide that continuing full debt service is neither feasible nor prudent. But defaulting on the bond debt may result in accelerations, lawsuits and attachments — all remarkably adhesive substances that are difficult to reverse and unravel once a debt restructuring begins. (This risk will be most acute for Republic of Venezuela bonds, all of which are issued under a fiscal agency agreement. Once an acceleration occurs, each holder will be free to pursue independent litigation.) Argentina defaulted on its bond debt in December 2001 but did not get around to proposing a restructuring of the instruments until 2005. By the time that proposal arrived, the litigation machinery had already been grinding on for years. It would do so, relentlessly, for another decade thereafter.
What will be needed in this situation is some form of temporary standstill on creditor actions that will give the new administration and the IMF time in which to assess the situation on the ground and allow the authorities, in consultation with the IMF and affected creditors, to formulate a plan for the treatment of outstanding liabilities. To be acceptable to creditors, however, a standstill must not prejudice the financial interests of creditors nor attempt to predict or prescribe the outcome of an eventual debt restructuring. It must do no more than inhibit maverick creditor actions during the standstill period.
As always, our preference is to look for solutions that can be implemented in a manner consistent with the underlying legal instruments rather than jettison the contracts in favor of more adventuresome approaches such as trying to jury-rig a bankruptcy proceeding in one jurisdiction or another.
Unfortunately, simply shifting the due dates of payments falling due on Republic and PDVSA bonds during the standstill period will probably not work. Such an amendment would require the approval of 100% of the holders of the PDVSA bonds and 100% of the holders of Republic bonds that do not contain collective action clauses. It would need the affirmative vote of holders of 75% (principal amount) of most Republic CAC bonds, 85% in the case of two series; thresholds that may not be achievable. Nor could a payment default under PDVSA bonds be waived with less than the unanimous consent of holders. Constructing a standstill mechanism will therefore require finding a measure that can be approved by a bare majority of the holders of each instrument (or two-thirds in the case of Republic CAC bonds).
One feature shared by both PDVSA and Republic bonds is a requirement that holders of at least 25% of the principal amount of the bonds of a series must consent before the principal of the bonds can be accelerated. Each of these instruments, however, permits holders of 50% of the principal amount of the bonds of that series (66⅔% in the case of Republic bonds containing collective action clauses) to amend this provision to specify a higher voting threshold to accelerate the bond.
One possible approach is this: Immediately upon taking office, a new administration in Venezuela could request the holders of each outstanding PDVSA and Republic of Venezuela bond to approve an amendment increasing the voting threshold for acceleration from 25% to, say, 51%. That modification would terminate after six months — long enough for the IMF to make a preliminary assessment of the economy and for the authorities, in consultation with the IMF and the affected creditors, to formulate a plan for restructuring the debt. Scheduled payments of principal and interest falling due during the standstill period would continue to be outstanding and would continue to bear interest. The failure to pay those amounts on the scheduled due dates during the standstill period could not, however, result in an acceleration of the instrument unless at least a majority of holders voted in favor of that acceleration. The majority holders would thus at all times control the process.
Making an acceleration of a bond series more difficult will naturally be of little help if the full principal amount of the bond had matured during or before the standstill period. If the bond in question had a collective action clause, the authorities could seek to use that provision to defer the maturity date until the end of the standstill period. If not, the authorities might request holders to roll over maturing principal until the end of the standstill period, but they probably could not force holders to do so without attempting more coercive measures.
This is the optimistic scenario; the new authorities take office before the Venezuelan external debt has been allowed to slip into a messy, litigious default. If the new administration is not that lucky, it may need to ask creditors (or courts) to suspend any pending enforcement actions while the situation is being assessed and a recovery plan is being formulated.
Would the majority of bondholders support a temporary standstill? We think they would. With the memory of Argentina still fresh, investors realize that chaotic and litigious sovereign debt workouts rarely improve the recovery value for most creditors.
Lee C Buchheit and Mitu Gulati are at Cleary Gottlieb Steen & Hamilton LLP and Duke University, respectively.
4
11 HOURS AGO
By: Guest writer
By Lee C Buchheit and Mitu Gulati
When officials of a new administration finally take office in Venezuela they will not have a pleasant first day on the job. On the present trajectory, they are likely to find international reserves exhausted, an oil sector in disrepair, a colossal debt, ruptured relations with the international community, hungry and angry citizens. Something disagreeable is apt to slither out of every file drawer they open.
Approaching official sector institutions such as the IMF for financial assistance will also present unusual problems. The Venezuelan authorities have not spoken to the IMF in many years. The last Article IV consultation took place over a decade ago. Unlike other sovereign debt crises, when an IMF mission arrives for the first time in Caracas it will have little or no reliable information about the state of the economy or public sector assets and liabilities. Several months will be needed for the IMF to make even a preliminary assessment of the situation, and no recommendations on an appropriate adjustment program or a debt policy can be formulated in the absence of that assessment.
What happens to Republic of Venezuela and PDVSA debt during this interim period? If the new administration arrives while the external debt is being serviced (the current policy), the authorities may well decide that continuing full debt service is neither feasible nor prudent. But defaulting on the bond debt may result in accelerations, lawsuits and attachments — all remarkably adhesive substances that are difficult to reverse and unravel once a debt restructuring begins. (This risk will be most acute for Republic of Venezuela bonds, all of which are issued under a fiscal agency agreement. Once an acceleration occurs, each holder will be free to pursue independent litigation.) Argentina defaulted on its bond debt in December 2001 but did not get around to proposing a restructuring of the instruments until 2005. By the time that proposal arrived, the litigation machinery had already been grinding on for years. It would do so, relentlessly, for another decade thereafter.
What will be needed in this situation is some form of temporary standstill on creditor actions that will give the new administration and the IMF time in which to assess the situation on the ground and allow the authorities, in consultation with the IMF and affected creditors, to formulate a plan for the treatment of outstanding liabilities. To be acceptable to creditors, however, a standstill must not prejudice the financial interests of creditors nor attempt to predict or prescribe the outcome of an eventual debt restructuring. It must do no more than inhibit maverick creditor actions during the standstill period.
As always, our preference is to look for solutions that can be implemented in a manner consistent with the underlying legal instruments rather than jettison the contracts in favor of more adventuresome approaches such as trying to jury-rig a bankruptcy proceeding in one jurisdiction or another.
Unfortunately, simply shifting the due dates of payments falling due on Republic and PDVSA bonds during the standstill period will probably not work. Such an amendment would require the approval of 100% of the holders of the PDVSA bonds and 100% of the holders of Republic bonds that do not contain collective action clauses. It would need the affirmative vote of holders of 75% (principal amount) of most Republic CAC bonds, 85% in the case of two series; thresholds that may not be achievable. Nor could a payment default under PDVSA bonds be waived with less than the unanimous consent of holders. Constructing a standstill mechanism will therefore require finding a measure that can be approved by a bare majority of the holders of each instrument (or two-thirds in the case of Republic CAC bonds).
One feature shared by both PDVSA and Republic bonds is a requirement that holders of at least 25% of the principal amount of the bonds of a series must consent before the principal of the bonds can be accelerated. Each of these instruments, however, permits holders of 50% of the principal amount of the bonds of that series (66⅔% in the case of Republic bonds containing collective action clauses) to amend this provision to specify a higher voting threshold to accelerate the bond.
One possible approach is this: Immediately upon taking office, a new administration in Venezuela could request the holders of each outstanding PDVSA and Republic of Venezuela bond to approve an amendment increasing the voting threshold for acceleration from 25% to, say, 51%. That modification would terminate after six months — long enough for the IMF to make a preliminary assessment of the economy and for the authorities, in consultation with the IMF and the affected creditors, to formulate a plan for restructuring the debt. Scheduled payments of principal and interest falling due during the standstill period would continue to be outstanding and would continue to bear interest. The failure to pay those amounts on the scheduled due dates during the standstill period could not, however, result in an acceleration of the instrument unless at least a majority of holders voted in favor of that acceleration. The majority holders would thus at all times control the process.
Making an acceleration of a bond series more difficult will naturally be of little help if the full principal amount of the bond had matured during or before the standstill period. If the bond in question had a collective action clause, the authorities could seek to use that provision to defer the maturity date until the end of the standstill period. If not, the authorities might request holders to roll over maturing principal until the end of the standstill period, but they probably could not force holders to do so without attempting more coercive measures.
This is the optimistic scenario; the new authorities take office before the Venezuelan external debt has been allowed to slip into a messy, litigious default. If the new administration is not that lucky, it may need to ask creditors (or courts) to suspend any pending enforcement actions while the situation is being assessed and a recovery plan is being formulated.
Would the majority of bondholders support a temporary standstill? We think they would. With the memory of Argentina still fresh, investors realize that chaotic and litigious sovereign debt workouts rarely improve the recovery value for most creditors.
Lee C Buchheit and Mitu Gulati are at Cleary Gottlieb Steen & Hamilton LLP and Duke University, respectively.