Evolution and Challenges of Liability Management Exercises in Europe

This chapter explores the evolution and increasing use of liability management exercises (LME) in Europe, as well as the challenges and limitations that arise when implementing them compared to the US. It discusses the convergence between US and European documentary terms, the involvement of private credit and special sits lenders, and the tension between companies/sponsors and creditors. The chapter also delves into the differences between exit consents in the UK and US, the advantages of court-sanctioned schemes, and the collaborative culture within the European market.