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Octus on Credit: A Unique LME Landscape is Evolving in Europe, Inspired by the U.S.
Aditya Khanna, Head of Legal Research, EMEA
Europeans watched from the sidelines as liability management exercises (LMEs) reshaped the U.S. leveraged finance landscape in recent years. That changed with a single cryptic earnings call in 2024, when Altice France imported the playbook from across the Atlantic. Since then, Hunkemoller, Ardagh and Victoria plc have deployed increasingly aggressive creditor-on-creditor violence tactics.
Octus has covered these developments from every angle, combining market intelligence, legal expertise and financial analysis to deliver timely, actionable insights. Our legal analysts called the Victoria LME with precision, identifying documentary weaknesses that could enable an uptier transaction, days before its announcement.
Beyond individual transactions, we’ve focused on educating clients about the broader European LME landscape. Among key findings: high-yield bonds face greater coercive LME risk than leveraged loans—a pattern that continues to hold.
Yet Europe isn’t America. Selecta shone a light on the use of distressed disposals under contractual intercreditor arrangements unique to European markets. Other critical differences span the evolving English restructuring regime, director duties, and exit consent validity.
To deepen market understanding, Octus launched our “LMEs in Europe” series in partnership with premier European law firms. Join us September 23 for a landmark webinar analyzing European LMEs, hosted with Paul Weiss and South Square Chambers.
For those navigating the alphabet soup of LME terminology, the Octus team’s LME Jargon Buster report remains an essential reference.
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