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§ 546(e)

IIG Global Trade Fin. Fund Ltd., In re--IIG Global Trade Fin. Fund Ltd. v. Int’l Inv. Grp

Ruling
Safe harbor for transfers in connection with a securities transaction did not attach to claims based on state law that had no relation to bankruptcy law. (Bankr. S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on November 08, 2024 , LexisNexis #0125-059

FTX Trading Ltd., In re--Alameda Rsch. Ltd. v. Giles

Ruling
Motions to dismiss fraudulent transfer claims denied as lack of details on transfer logistics precluded application of the safe harbor for transfers in connection with a securities contract. (Bankr. D. Del.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Consumer opinion summary, case decided on October 23, 2024 , LexisNexis #0125-015

Petr v. BMO Harris Bank N.A.

Ruling
District court did not err in dismissing appellant's fraudulent transfer complaint as precludedpursuant to the safe harbor. (7th Cir.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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:
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on March 15, 2024 , LexisNexis #0524-041

Securities Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Madoff trustee sufficiently pled the initial transferees had actual knowledge that the debtor was not trading securities, which made the safe harbor inapplicable. (Bankr. S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on March 28, 2023 , LexisNexis #0523-065

Quorum Health Corp., In re--Golden v. Cmty. Health Sys.

Ruling
Dismissal of claims seeking avoidance of a spin-off dividend was warranted as the transfer was protected by safe harbor provisions. (Bankr. D. Del.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on March 16, 2023 , LexisNexis #0523-037

Quorum Health Corp., In re--Golden v. Cmty. Health Sys.

Ruling
Dismissal of claims seeking avoidance of a spin-off dividend was warranted as the transfer was protected by safe harbor provisions. (Bankr. D. Del.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on March 16, 2023 , LexisNexis #0523-037

Securities Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Dismissal of trustee's suit to recover subsequent transfers consisting of debtor's customers'property was not warranted as the complaint sufficiently alleged personal jurisdiction. (Bankr.S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on November 18, 2022 , LexisNexis #0123-093

Tops Holding II Corp., In re--Halperin v. Morgan Stanley Investment Mgmt.

Ruling
Dividends paid to investors for three years did not qualify as safe harbor transfers where therewas no qualifying transaction and no qualifying recipient had been identified. (Bankr.S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Judge or Jurisdiction information not available
Commercial opinion summary, case decided on October 12, 2022 , LexisNexis #1222-062

Sec. Inv. Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Any defendant who actually knew about the debtor’s Ponzi scheme was not entitled to theprotections of the safe harbor against trustee’s efforts to recover subsequent transfers. (Bankr.S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on September 27, 2022 , LexisNexis #1222-016

Sec. Investor Prot. Corp. v. Bernard L. Madoff Inv. Sec. LLC

Ruling
Defendants who actually knew that debtor was running a Ponzi scheme were not entitled tothe protections of the safe harbor. (Bankr. S.D.N.Y.)
Issue(s)
Limitations on Avoiding Powers; Margin or Settlement Payments.

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Commercial opinion summary, case decided on September 22, 2022 , LexisNexis #1122-088