Summary
Under the ISDA Master Agreement, section 2(a)(iii) suspends a payment obligation while the counterparty’s Event of Default continues; it does not permanently extinguish it. A suspended obligation does not, however, survive the natural expiry of the relevant transaction if the condition remains unsatisfied.
No term should be implied requiring the non-defaulting party to elect for Early Termination within a reasonable time, or at the transaction’s expiry. The election is exercisable in that party’s own interests. In the context of these net-basis interest-rate hedges, the condition precedent did not infringe the anti-deprivation rule. It was neither a penalty nor a forfeiture from which relief was available.
Factual background
The joint administrators of Lehman Brothers International (Europe) sought directions concerning five interest-rate swaps governed by the 1992 or 2002 ISDA Master Agreement. After the company entered administration, its counterparties relied on section 2(a)(iii), which made their payment obligations conditional on there being no continuing Event of Default affecting the other party.
The administrators contended that the condition should operate only temporarily, that the counterparties should have terminated the swaps, and that the resulting non-payment offended the anti-deprivation rule, was a penalty, or was a forfeiture. The counterparties and the intervening International Swaps and Derivatives Association advanced competing constructions. The central issue was the effect and duration of the section 2(a)(iii) condition precedent.
Held
The administrators’ construction, anti-deprivation, penalty and forfeiture arguments were rejected. Directions were given substantially in favour of the respondent counterparties.
Under the 1992 Master Agreement, a payment obligation prevented from falling due by section 2(a)(iii) is suspended, rather than permanently destroyed. If the relevant default is later cured, the obligation may arise. The same result was express under the 2002 form because of section 9(h)(i)(3). However, where the condition remains unsatisfied at the natural expiry of a transaction, section 9(c) means that the suspended obligation does not survive that expiry.
There was no basis for implying a reasonable time limit on section 2(a)(iii), a compulsory netting process at expiry, or a duty to designate an Early Termination Date. Those implications conflicted with the express scheme. Section 6(a) gave the non-defaulting party a contractual choice between remedies, exercisable in its own interests. The respondents’ decisions not to terminate were neither dishonest nor irrational.
Section 2(a)(iii), as incorporated into these net-basis interest-rate swaps, did not contravene the anti-deprivation rule. The contingent rights to future net payments were consideration for an ongoing hedge, not payment for performance completed before insolvency. An insolvency-related condition could therefore qualify those future rights from the outset without removing property that insolvency law required to be distributed pari passu. This conclusion was confined to the transactions considered and depended on the parties’ net-basis convention.
The penalty doctrine did not apply because entry into administration was not a breach of contract. Nor was section 2(a)(iii) a forfeiture: the relevant contingent contractual right to money was not property for which relief from forfeiture was available, and the clause was a condition precedent.
On the parties’ agreed net basis, the respondents had no present provable claim because LBIE was net in the money. The court made no decision on whether the condition precedent could be unilaterally waived.
The court’s approach to earlier authorities
Available to signed-in members.
Appellate history
not stated in the judgment.
Key cases cited
12 authorities cited.
- Attorney General of Belize v Belize Telecom Ltd [2009] UKPC 10
- Perpetual Trustee Company Ltd & Anor v BNY Corporate Trustee Services Ltd & Ors [2009] EWCA Civ 1160
- SOCIMER INTERNATIONAL BANK LTD v STANDARD BANK LONDON LTD [2008] 1 Lloyd's Rep 558
- EURO LONDON APPOINTMENTS LTD v CLAESSENS INTERNATIONAL LTD [2006] 2 Lloyd's Rep 436
- LUDGATE INSURANCE COMPANY LTD v CITIBANK NA [1998] Lloyd's Rep IR 221
- Enron Australia v TXU Electricity [2003] NSW SC 1169
- ABU DHABI NATIONAL TANKER CO. v. PRODUCT STAR SHIPPING LTD. (THE “PRODUCT STAR”) (No. 2) [1993] 1 Lloyd's Rep 397
- Scandinavian Trading Tanker Co AB v Flota Petrolera Ecuatoriana (The Scaptrade) [1983] QB 529
- British Eagle International Air Lines Ltd v Cie Nationale Air France [1975] 1 WLR 758
- Trollope & Colls Ltd v North West Metropolitan Regional Hospital Board [1973] 1 WLR 601
- Associated Distributors Ltd v Hall [1938] 2 KB 83
- ex parte Mackay
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Cases citing this case
17 later cases · 7 positive · 6 neutral · 4 caution
Most senior citing decisions:
- Belmont Park Investments PTY Limited v BNY Corporate Trustee Services Limited and Lehman Brothers Special Financing Inc [2011] UKSC 38 approved
- The State of the Netherlands v Deutsche Bank AG [2019] EWCA Civ 771 mentioned
- Folgate London Market Ltd v Chaucer Insurance Plc [2011] EWCA Civ 328 distinguished
- Macquarie Bank Limited v Phelan Energy Group Limited [2022] EWHC 2616 (Comm)
- ALISON GRANT & Ors v FR ACQUISITIONS CORPORATION (EUROPE) LTD & Anor [2022] EWHC 2532 (Ch)
- Kwik Lets Ltd & Ors v Khaira & Ors [2020] EWHC 616 (QB)
- Lehman Brothers International (Europe) v Exxonmobil Financial Services BV [2016] EWHC 2699 (Comm)
- Lomas & Ors (Joint Administrators of Lehman Brothers International (Europe)) v Burlington Loan Management Ltd & Ors [2016] EWHC 2417 (Ch)
- Kaupthing Singer & Friedlander Ltd v UBS AG [2014] EWHC 2450 (Comm)
- Pioneer Freight Futures Company Ltd v TMT Asia Ltd [2011] EWHC 1888 (Comm)
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