Chapter 15 and the objecting creditors’ new playbook
We’re over halfway through 2026 and 9fin’s LME count is up to 25 with H1’s completed transactions — just above the 24 transactions recorded for the first half of 2025.
When 9fin wrote about the rise of Chapter 15 as an enforcement mechanism for foreign restructurings, the US courts had signalled unease about engineered COMI and jurisdictional arbitrage. The comments would appear in the occasional dicta of a decision, but the recent opinion in New Fortress Energy has now provided a framework for scrutinizing petitions for Chapter 15 recognition.