Enforcement bank guarantees

What happens if the beneficiary of a bankthat have not voted in favour of the
guarantee or other surety decides to enforce itarrangement will not be bound thereby in terms
against a payment default by a debtor who hasof the full subsistence of their rights vis-à-vis
been declared insolvent? This is a crucial questionthose joint and severally bound with the insolvent
not only for the beneficiary of the guarantee butparty and vis-à-vis its guarantors or guaranteeing
also the granter thereof – in many cases aparties, who will not be entitled to invoke the
financial institution. Neither one nor the otherapproval or effects of the arrangement to the
should be unaware of the consequences if theirdetriment of the former" (article 135.1).
debtor and guaranteed party, respectively, isThis is without detriment to whether the
declared to be insolvent.guarantee in question constitutes a first-demand
In the interests of the utmost clarity thebank guarantee. In such a case, it is our opinion
guarantor will be called herein "the guaranteeingthat the guaranteeing party could never invoke
party". The debtor involved in the insolvencyagainst the creditor with guarantee the debt
proceedings, for its part, will be called "thereductions and/or postponements of the
secured debtor", while the surety beneficiary willarrangement with creditors, not even if the latter
be called the "the creditor with guarantee".had voted in favour of said arrangement. Along
1.- The general rule of article 87.6 of the Spanishthese lines the LC lays it down that "the liability of
Insolvency Proceedings Act (Ley Concursal: LC)those joint and severally bound, guarantors or
This article lays it down that "the credits in whichguaranteeing parties of the insolvency proceedings
the creditor enjoys a third-party surety will beagainst the creditors that have voted in favour of
recognised at their face value with no limitationthe arrangement will be governed by the rules
whatsoever and regardless of any change in theapplicable to the obligation they may have taken
credit holder in the event of payment by theon or by such arrangements as may have been
guarantor".made thereon" (article 135.2).
This means that, after declaration of the4.- Guarantee in favour of the creditor specially
insolvency, the guaranteeing party will remain therelated to the debtor
bound party vis-à-vis the creditor with guarantee,Special mention must be made of the situation
benefited by the remaining term until the obligationwhere the creditor with guarantee is considered
falls due. Should this term run its course during theto be a "person especially related with the
insolvency proceedings and the creditor withinsolvent party". Pursuant to article 93.2 of the LC,
guarantee hold the guaranteeing party to itswhen the secured debtor is a company, the
surety obligation, then the latter, i.e., thefollowing persons will be deemed to be specially
guaranteeing party, will then, by virtue of therelated thereto:
payment, become the holder of the credit against- Shareholders that, pursuant to the law, are
the secured debtor, being entitled to take overpersonally liable without limit for company debts
the original creditor's payment demand right.and those others that, at the moment when the
Royal Decree Law (Real Decreto-ley) 2/2009 ofcredit right arises, are holders of at least 5% of
27 March has added the following rider to saidthe share capital, if the company declared to be
article 87.6: "Whenever the payment-driveninsolvent has securities trading on an official
subrogation should occur, these credits will thensecondary market, or 10% otherwise.
be classified in such as a way as may be least- The directors, the liquidators and generally
onerous for the insolvency proceedings, betweenempowered agents of the company plus those
those corresponding to the creditor or guarantor".who may have been any of the above within the
2.- The case of only partial credit payment by thetwo year period running up to the declaration of
guaranteeing party after enforcement of thethe insolvency proceedings.
guarantee- The companies forming part of the same group
Article 87.7 of the LC runs as follows: "at theas the company declared to be insolvent and the
behest of the creditor that has received paymentshareholders thereof, provided these meet the
of part of its credit from a guaranteeing party,same circumstances as under paragraph 1 hereof.
guarantor or joint and several debtor of theAlong these lines article 97.2 of the LC runs as
insolvency proceedings, the list of creditors mayfollows:
include in its favour not only the rest of the"If the creditor classified in the list of creditors as
unpaid credit but also the total sum correspondingespecially related with the debtor does not
to whoever made the partial payment, bychallenge this classification in due time and form,
reimbursement or the part corresponding to athe insolvency-proceedings judge, as soon as the
joint and several debtor …"deadline for doing so has passed, and without any
This precept, for the credit recognition phase,other requisite, will dictate an order declaring any
enshrines the general principle that the right of theguarantees of any sort furnished in favour of the
creditor with guarantee to be compensated forformer's credits to be extinguished, ordering, as
the unpaid part of the credit overrides the rightthe case may be, the possessory restitution and
of the guaranteeing party that has made a partialcancellation of the entries in the corresponding
payment vis-à-vis the same debtor.registries ".
Pursuant to this provision (article 87.7 of the LC),The practical importance of this provision is clear:
the original creditor has the possibility ofdoes it mean that if I have a debt security from
recovering in the insolvency proceedings the resta company of which I am a shareholder (or of its
of its unpaid credit against payment of the creditgroup of companies) and this is declared insolvent,
as corresponding to the guaranteeing party.I will forfeit my guarantee? Will I forfeit it too if I
Bearing out this idea, article 160 of the LC, in theam the CEO (general empowered agent) of a
section dealing with payment to creditors, lays itcompany that owes me several sums secured by
down that "any creditor that, before declarationa bank guarantee?
of the insolvency proceedings, has received partA strict reading of article 97.2 would disfavour the
payment of the credit from a guarantor orcreditor with guarantee especially related to the
guaranteeing party or from a joint and severaldebtor, since it would mean that in every case
debtor will be entitled in the insolvencythe insolvency-proceedings judge "without any
proceedings to receive the paymentsother requisite" will dictate an order declaring the
corresponding to the former until such time asguarantee granted in its favour to be extinguished.
they add up to the total sum of the latter".Some writers have criticised the mercantile
3.- Relationship of the arrangement with creditorsjudges' tendency to such "strict interpretations"
and the secured creditand claim that, pursuant to article 97.2, the judge
The doubt now crops up of whether, in the eventshould weigh up the circumstances of the case
of the approval of an arrangement with creditorsbefore adopting the drastic measure of
involving corresponding debt reductions andextinguishing the guarantee.
postponements, the guaranteeing party would beUnfortunately, the current wording of article 97.2
able to pay the creditor with guarantee byis not conducive to this discretionary interpretation
applying the debt reductions and postponementsby the judge, so there is a high risk of the judge
authorised by said arrangement.simply extinguishing the guarantee in question
The LC rules as follows on this point: "creditorswithout a second thought.