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ASIAN DEVELOPMENT BANK
REGIONAL TECHNICAL ASSISTANCE
TA NO: 5795-REG
INSOLVENCY LAW REFORM
CASE STUDY FROM THAILAND
Punjaporn Kosolkitiwong
Dej-Udom & Associates Ltd
CaseBackground
In July 1997, the Board of X Company ("Company") commissioned an
investigation into the affairs of the Company and accounting irregularities
were discovered which are now the subject of criminal charges against
a number of former employees. The financial position of the Company
as determined following the investigation disclosed significant
irregularities. Based on the investigation, it is alleged that the
managing director and some former employees misappropriated approximately
Baht 18,000 million from the Company. Following the investigation,
the then CEO of the company resigned, and the financial creditors
formed a Creditors Steering Committee ("CSC") to work with the company
on a restructuring Plan. Uncertainty concerning the Company's future,
lack of financial stability and the absence of necessary working
capital over the following 12-month period adversely affected the
Company's business.
On May 13, 1998, a request for business reorganization was filed
with the Civil Court by six banks that are members of the CSC with
the support of the Company.
On June 4, 1998 the Civil Court ordered accepting the business reorganization
of the Company and appointed company W (an accounting firm) to be
the Planner of Company. The role of the Planner is to prepare a
reorganization Plan of the Company to be presented to creditors
and the Court for their review and approval.
Apart from the Plan, the Planner appointed a representative to lodge
a complaint against the managing director et al with the Economic
Crime Investigation Office on grounds of misappropriation and fraud.
The investigator found that the accountant used false documents
to withdraw money for the directors' benefit. For example, the price
specified in Purchase Agreements was higher than the actual purchase
price. In addition, the Planner filed a case with the Central Labor
Court against the directors demanding the return of the money they
misappropriated from the Company. Prior to such filing, the Planner
filed a petition with the Civil Court seeking permission to file
the case with the Central Labor Court against the fraudulent directors.
The Court ruled that filing the latter case would be a form of debt
collection which is within the normal business and even the duty
of the Planner under Section 90/25. The Planner was therefore entitled
to file the case without specific permission from the Civil Court.
Moreover, the Planner used the Civil Court's ruling as a basis for
filing a civil case against an auditing firm and a certain auditors,
alleging that because of their unprofessional auditing, a misleading
financial position was created causing damage and loss to shareholders
and the Company. The lawyers representing the auditing firm/auditors
defended the case on the grounds that the Planner had no right to
file the case, as the Civil Court did not authorize the Planner
to extend to the filing of cases against what are in effect, third
parties. Hence, the filing of the case is not within the meaning
of the normal business of the Planner, and the Planner has no authority
to do act without the permission of the court and creditors of the
Company under Section 90/25 .
On November 5, 1998, the Official Receiver called for a creditors'
meeting to consider the Plan prepared by the Planner. There were
1,137 creditors who attended the meeting and were entitled to vote.
The major creditors were Krung Thai Bank Plc, Bangkok Bank Plc and
Union Bank Plc. At the time of voting, 1,106 creditors representing
debt of Baht 6,647,237,190.82 voted for the Plan but 20 creditors
representing debt of Baht 6,330,046,015.32 objected and asked the
Planner to revise the Plan. The Planner did not agree to revise
the Plan. The creditors' meeting therefore terminated the Planner's
appointment under Sections 90/46 , 90/51 and 6
of the Bankruptcy Act, B.E.2541 as the vote did not meet with requirements
of a special resolution.
1. Section 90/25 - Subject to Section 90/42
and Section 90/64, upon appointment of the Planner made by the court,
the power and duties in managing the business and asset of the debtor
and all legal rights of the debtor's shareholders, except the right
to receive dividend, shall be vested to the Planner, and the provision
of Section 90/12(9) shall apply to the Planner mutatis mutandis.
2. Section 90/46 - The resolution passed at
the creditors' meeting approving the Plan must be a special resolution.
3. Section 90/51 - In the event that the Planner
refuses to revise the Plan, either in part or in full, pursuant
to the resolution passed at the creditors' meeting, if the creditors'
meeting fails to pass a special resolution approving the Plan formulated
by the Planner, the receiver shall ask the creditors' meeting if
they want to appoint a new Planner. If the creditors' meeting passes
a resolution to appoint a new Planner, the meeting shall discuss
the selection of a new Planner that day. Any creditor present at
the meeting or the debtor has the right to propose the name of a
new Planner with a written consent of such person. If no creditor
proposes the name of the new Planner, the receiver shall adjourn
the meeting in order to select a new Planner within a period of
not less than 3 days but not more than 7 days. The provisions concerning
notification of the new meeting pursuant to paragraph of Section
44 shall apply mutatis mutandis.
4. Section 6 - "Special Resolution" means a
resolution by a majority of creditors whose claims equal three quarters
of the total claims of creditors present at the creditors' meeting
in person or by proxy, and voting on such resolution.
5. Section 90/1 - "Plan administrator" refers
to a person who manages the business operations and assets of the
debtor pursuant to the operations reorganization plan.
A new Planner was appointed at the next creditors' meeting. The
new Planner presented a revised Plan to the creditors at the meeting.
The revised Plan was accepted by creditors with claims sufficient
to meet the special resolution requirement. The new Planner was
also appointed to be the Plan Administrator of the Company [Section
90/1]. Some minority creditors did not agree to appoint the
new Planner, as it was obvious that the new Planner was an affiliate
company of the previous Planner. They testified to the Court that
the new Planner' s name was similar to the previous Planner's name
and the directors of the new Planner were almost the same as the
former Planner. The Court decided that it was a different entity
and ordered held that the appointment of the new Planner was legal.
The new Planner then ratified all the previous Planner's actions.
The new Planner also submitted a ratification and appointment letter
to the Court in the civil case against the auditing firm/auditors,
who opposed such ratification.
Issues:
1. The Cause of Insolvency of the Company
2. Corporate Governance
3. The Role of the Auditor
4. The Authority and Duty of the Planner and Plan Administrator
5. The Involvement of Creditors
1. The Cause of Insolvency of the Company
X is a large public company with substantial income. Although much
of the Company's debt is denominated in foreign currency, so too
is its income. Hence, the sharp depreciation of the Baht from mid-1997
and concomitant economic recession were not the primary causative
factors of the Company's insolvency. If even part of the alleged
fraudulent and dishonest conduct of the Company's directors and
employees is correct, it is reasonable to surmise that the Company
would not be insolvent were it not for such conduct.
2. Corporate Governance
X is administered by a group of directors against whom very serious
allegations of misconduct have been raised. Notwithstanding the
seriousness of the allegations, the directors remain at large and
most are still involved in various business activities. Some of
the directors are from major creditor banks. The Managing Director's
whereabouts are currently unknown, but his legal representatives
have appeared on his behalf at the hearings for the delivery of
the Plaintiff's evidence. The apparent scale and duration of the
misconduct is evidence of real standards of corporate governance
as opposed to the legal standards and requirements. Enforcement
rather than legislative change is the key issue. One aspect of enforcement
is shareholder apathy in pursing irregularities and exercising their
powers to remove directors and change the company's policy and direction.
There are a substantial number of "proxy" shareholders, who hold
shares on behalf of foreigners in order to comply with foreign ownership
laws, which is one explanation for this shareholder apathy.
3. The Role of the Auditor
Similarly, serious allegations have been raised concerning the
role of X's auditors. The filing of the civil case by the Planner
against the auditors is unprecedented. If judgment is awarded in
favor of the Planner, it will have a material effect on accounting
standards and the exercise of the duties of the shareholders. The
old Planner in the reorganization case is itself an accounting/auditing
firm. The new Planner is directly linked to the old Planner, even
though it is a separate legal entity. Hence, speculation as to the
motivation for filing the case has surfaced. However, if the end
result is accountability for negligent and/or fraudulent auditors,
not only will justice have been served, it will create a much needed
precedent.
4. The Authority and Duty of the Planner and Plan Administrator
The X case has raised interesting issues concerning the authority
and duty of the Planner. If there is jurisdictional acceptance by
the Civil Court of Planner's right to pursue the claim against the
auditors, it will be a very broad interpretation of the statutory
powers of the Planner under the Bankruptcy Act. It is noteworthy
that the amounts claimed in both cases against the directors and
auditors is the same, and awards would mean "double judgements".
The Planner has taken a robust approach in the exercise of its authority.
While there is no prohibition under the Bankruptcy Act of the same
entity being appointed as both Planner and Plan Administrator, arguably
such an appointment does not accord with what was envisaged by the
legislators as the involvement of separate entities in the respective
roles.
5. The Involvement of Creditors
Creditors play a pre-eminent role in the reorganization process
under Section 90 of the Bankruptcy Act No.4, as opposed to shareholders.
The bottom line of any proposed Plan is that it must gain the support
of creditors representing at least 75% of total creditor claims
at the time of voting. This is not an easy task when there are 1,137
creditors and the Planner's/Company's success in soliciting this
requisite level of support is an accomplishment in itself. Whether
the Plan can be successfully implemented remains to be seen. The
exercise of the creditors right to reject the Plan, and the refusal
of the Planner to amend the Plan, leading to the termination of
the Planner's appointment, are curious given the subsequent de facto
reappointment of the Planner under a new corporate guise. An explanation
lies in the mandatory requirements under Section 90/51 of the Bankruptcy
Act and the time required to negotiate acceptable amendments to
the Plan.
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