SEPTEMBER 2020 BAR BULLETIN | Page 7

BANKRUPTCY CORNER The Small Business Reorganization Act Five Months In JASON S. RIGOLI Two issues from the recently enacted Small Business Reorganizations Act (SBRA) have been percolating through the courts. While neither has made it to the Eleventh Circuit, yet, they are two important issues. Individual Guarantors and Sub V Chapter 11 Eligibility One issue that has been an issue for the new subchapter V small business chapter 11 bankruptcy cases (11 U.S.C. §§ 1181-1195) is eligibility, especially for guarantors of business debts when the entity is defunct. A “small business debtor” is defined as a person engaged in commercial or business activities (including any affiliate of such person that is also a debtor under this title and excluding a person whose primary activity is the business of owning single asset real estate) that has aggregate noncontingent liquidated secured and unsecured debts as of the date of the filing of the petition or the date of the order for relief in an amount not more than $2,725,625 (excluding debts owed to 1 or more affiliates or insiders) not less than 50 percent of which arose from the commercial or business activities of the debtor[.] 11 U.S.C. § 101(51D). The objection to eligibility in cases of individual guarantors of defunct business is whether the “engaged in commercial or business activities” “limits application to debtors currently engaged in business or commercial activities.” In re Wright, Case No. 20-01035- hb, 2020 Bankr. LEXIS 1240 at *7, 2020 WL 2193240 at *3 (Bankr.D.S.C. April 27, 2020) (emphasis in original). Courts that have had this issue have, applying the cannons of statutory construction, determined that nothing in the definition limits the application of subchapter V to debtors currently engaged in business. It is enough that the debts equaling 50% or more of the total debts of the debtor were from business or commercial activities. See Wright, LEXIS at *8, WL at *3 (holding debtor “is ‘engaged in commercial or business activities’ by addressing residual business debt and otherwise meets the remaining requirements under § 101(51D).”); In re Blanchard, Case No.: 19- 12440, 2020 Bankr. LEXIS 1909 at *7 (Bankr. E.D.La. July 16, 2020) (holding same); see also In re Bonert, No. 2:19-BK-20836, 2020 Bankr. LEXIS 1783 at *14, 2020 WL 3635869, at *5 (Bankr. C.D. Cal. June 3, 2020). Venue for Small Dollar Preferences The SBRA also amended the venue statute, 28 U.S.C. § 1409(b). Section 1409(b) creates an exception to venue generally lying in the court where the bankruptcy case was filed, including for certain smaller dollar amount claims. The SBRA increased the threshold for a proceeding to recover a debt owing by a noninsider from $13,650 to $25,000, however, by not specifically referring to 11 U.S.C. § 547, the majority of courts continue to hold that 28 U.S.C. § 1409(b) does not apply to preference actions. Why? Because 28 U.S.C. § 1409(b) only places venue in “the district in which the defendant resides” for “a proceeding arising in or related to” a bankruptcy case and not for a “a proceeding rising under title 11” – the Bankruptcy Code, which is the title of the United States Code § 547 is found. See Novak v. Parts Authority LLC, Case No. 20-2948, 2020 U.S. Dist. LEXIS 126202 (E.D.N.Y. June 16, 2020) (holding the SBRA amendment to 28 U.S.C. § 1409(b) still does not include preference actions brought pursuant to 11 U.S.C. § 547 ). See also In re Tadich Grill of Washington DC LLC, 598 B.R. 65, 67-72 (Bankr. D.C. 2019) (finding 28 U.S.C. § 1409(b) does not apply to avoidance actions and collecting cases on both sides at page 67). Accordingly, trustees or debtors in possession can still make recipients of avoidable small dollar preference payments defend the action in the bankruptcy court where the bankruptcy is pending instead of having the matter tried in the local bankruptcy court – “home venue” – of the defendant, making it costlier for the defendant and less costly for the plaintiff. This article is submitted by Jason S. Rigoli, Esq., Furr Cohen, 2255 Glades Road, Suite 301E, Boca Raton, FL 33431, jrigoli@ furrcohen.com 1 As a result of the COVID-19 Pandemic, this definition was temporarily modified by the CARES Act, to increase the debt limit to $7,500,000.00 for all case filed between March 21, 2020 and Mach 21, 2021, when it automatically sunsets back to the $2,725,625, barring any further congressional action. UPCOMING PBCBA CLE WEBINARS SEPTEMBER 16TH, 2020 12:00 PM - 1:00 PM Live via Zoom Pandemonium Avoiding Ethical and Technical Pitfalls while Utilizing Florida’s New Remote Online Notarization Statue SEPTEMBER 17TH, 2020 11:00 AM - 12:00 PM Live via Zoom Credibility for Sale: Keeping Client Info off the Dark Web During COVID-19 SEPTEMBER 18TH, 2020 11:00 AM - 12:00 PM Live via Zoom The Hidden Gems of Microsoft 365 NOVEMBER 13TH, 2020 9:00 AM - 2:30 PM Live via Zoom Virtual Mental Health First Aid Training