UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

In re:

The Financial Oversight and Management Board for 

Puerto Rico, 

as representative of

The Commonwealth of Puerto Rico, et al.,

Debtors.1

PROMESA

Title III

Case No. 17-3283-LTS

Court Filing Relates Only to 

PREPA

In re:

The Financial Oversight and Management Board for 

Puerto Rico, 

as representative of

The Puerto Rico Electric Power Authority,

Debtor.

PROMESA

Title III

Case No. 17-4780-LTS

(Jointly Administered)

SUPPLEMENTAL OBJECTION OF SYNCORA GUARANTEE, INC. TO THE

MOTION OF PUERTO RICO ELECTRIC POWER AUTHORITY FOR AN ORDER (I) 

APPROVING DISCLOSURE STATEMENT, (II) FIXING VOTING RECORD DATE, 

(III) APPROVING CONFIRMATION HEARING NOTICE AND CONFIRMATION 

SCHEDULE, (IV) APPROVING SOLICITATION PACKAGES AND DISTRIBUTION 

PROCEDURES, (V) APPROVING FORMS OF BALLOTS AND VOTING 

PROCEDURES, (VI) APPROVING NOTICE OF NON-VOTING STATUS, 

(VII) FIXING VOTING AND CONFIRMATION DEADLINES, AND 

(VIII) APPROVING VOTE TABULATION PROCEDURES

1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number 

and the last four (4) digits of each Debtor’s federal tax identification number, as applicable, are the 

(i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits of Federal 

Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-

BK-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation 

Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); 

(iv) Employees Retirement System of the Government of the Commonwealth of Puerto Rico (“ERS”) 

(Bankruptcy Case No. 17-BK-3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico 

Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780-LTS) (Last Four Digits of 

Federal Tax ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No. 

19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations).

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Pursuant to the Court’s February 13, 2023 order (ECF No. 3210 in Case No. 17-4780-LTS) 

(the “February 13 Order”), Syncora Guarantee, Inc. (“Syncora”) hereby respectfully submits this 

supplemental objection to the Disclosure Statement for First Amended Title III Plan of Adjustment 

of the Puerto Rico Electric Power Authority (ECF No. 3201) (the “Disclosure Statement”), and 

respectfully states as follows:2

SUMMARY OF SUPPLEMENTAL OBJECTION3

1. The Sequel Is Even Worse. On February 9, 2023, the Oversight Board filed the 

Amended Plan and accompanying Disclosure Statement. The most significant change in the 

Amended Plan and Disclosure Statement from the initial versions is the disclosure of the terms of 

the Oversight Board’s long-awaited settlement with National Public Finance Guarantee 

Corporation (“National”). National, like Syncora, is one of the monolines that insured the bonds 

issued by PREPA (the “National Settlement”).4 Although the Oversight Board touts the National 

Settlement as progress, the patent defects in the Amended Plan are even more glaring than in the 

original.

2

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed 

to such terms in the Disclosure Statement and the First Amended Title III Plan of Adjustment of 

the Puerto Rico Electric Power Authority (ECF No. 3200) (the “Amended Plan”), as applicable. 

Reference to ECF numbers are to Case No. 17-4780-LTS unless otherwise noted.

3

 On February 3, 2023, Syncora filed its objection to the Disclosure Statement Approval

Motion and the initial Disclosure Statement (ECF No. 3190) (the “Initial Syncora Objection”). 

Syncora is filing this Supplemental Objection solely to address new information that has come to 

light since that filing.

4

 Syncora insured approximately $100 million of PREPA bonds that have been fully repaid 

by Syncora, as well as an additional approximate $77 million of PREPA bonds that continue to 

accrue interest and be paid by Syncora. 

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2. National Deal Reeks Of Unfair Discrimination. In order to orchestrate the 

National Settlement, the Amended Plan proposes the creation of two (2) new classes of claims for 

PREPA Revenues Bonds: Class 5—The National Insured Bond Claims and Class 6—The 

National Reimbursement Claim (collectively, the “National Claims”). See Am. Plan. at § III.A. 

The Amended Plan then deems the National Claims to be Allowed5in their full amount under the 

Plan and would receive the following treatment: (i) Series B Bonds (just like other holders of 

PREPA Revenue Bond Claims) issued in the face amount equal to 71.65% (unlike other holders 

of PREPA Revenue Bonds Claims) of the Allowed National Insured Bond Claims, plus (ii) Series 

B Bonds in the aggregate amount of 5.86% (unlike other holders of PREPA Revenue Bond 

Claims) of the Allowed National Insured Bond Claims, for a total of 77.51% of the Allowed 

National Insured Bond Claims,6 plus (iii) Series B Bonds in the face amount equal to twenty 

5

 The National Insured Bond Claims are Allowed in the aggregate amount equal to 

$836,145,928.13, and the National Reimbursement Claim is Allowed in the aggregate amount 

equal to the payments made by National after the Petition Date and, as they may continue to be 

made up to, but not including, the Effective Date to holders of the National Insured Bonds on 

account of interest accrued on such bonds. In other words, the National Reimbursement Claim 

is for payment of post-petition interest on National Insured Bonds.

6

 The Oversight Board can also elect to pay this incremental 5.86% of the Allowed 

National Insured Bond Claims in cash. This ‘gift with purchase’ is purportedly to compensate 

National for the reasonable fees and expenses incurred by it during the Title III Case and for the 

structuring of payments to be made to holders of claims arising from or relating to National Insured 

Bonds. That’s an almost $50 million payment going to a single creditor who at all times 

negotiated exclusively for its own recovery, that provided zero benefit to anyone else, let alone an 

entire class of creditors. To be clear, Syncora has no objection to a holder of Bond Claims 

receiving a 77.51% recovery as a good-faith settlement with PREPA. It does object, however, 

to absurd postulates purporting to justify obvious discriminatory treatment that is unfair to all 

similarly situated creditors. Why doesn’t the Oversight Board just admit it is paying 77.51% to 

National on account of its National Insured Bond Claims plus an additional amount of post-petition 

interest on such claims? 

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percent (20.0%) of the amount of the National Reimbursement Claim (unlike other monoline 

insurers of PREPA Revenue Bond Claims).7 See Plan at §§ VIII.A., II.D.2., and IX.A.,

respectively. The Oversight Board proffers no rationale for the disparate treatment of National 

Claims from other PREPA Revenue Bond Claims. Syncora submits that, while there could be 

legitimate reasons to classify a monoline insurer’s PREPA Revenue Bond Claims separately so as 

to facilitate commutation elections for its wrapped bondholders, there is no rationale for PREPA’s 

discriminatory treatment of otherwise identical PREPA Revenue Bond Claims. 

3. Omitted Litigation Scenario Was Intentional. The Initial Syncora Objection 

asserted that the original Plan did not comply with the Court’s instruction for the Oversight Board 

to file a plan that would be confirmable whatever the outcome of the Amended Lien & Recourse 

Challenge. See Initial Syncora Objection at ¶ 22 (pointing out that if the Trustee has a lien on 

PREPA’s future revenues and the arbitrary 56% recovery cap is insufficient to pay the PREPA 

Bondholders’ entitlement, then the Initial Plan “may not be confirmable or feasible without 

material amendments”) (quoting initial Disclosure Statement at 37-38). Rather than cure this 

important deficiency, in a recent filing, the Oversight Board explained that it intentionally omitted

the scenario where PREPA Bondholders have a lien on future revenues because it did not deem 

that scenario “plausible.” See Omnibus Reply of the Puerto Rico Electric Power Authority to the 

(I) Adequacy of the Disclosure Statement, (II) Relief Requested in the Disclosure Statement 

Motion, and (III) Relief Requested in the Confirmation Discovery Procedures Motion (ECF No. 

7

 The Oversight Board estimates that 20% payment on the National Reimbursement Claim 

equals another approximate $50 million on top of the approximate $50 million in fees.

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3206), at ¶ 73. The Oversight Board cannot self-select litigation scenarios (under the guise of plan 

exclusivity) based on its view of creditors’ rights; indeed, that is presumably the reason the Court

gave its instruction to file a confirmable plan which contemplates all litigation scenarios. What 

the Oversight Board keeps missing is that it is not writing on a clean slate in this Title III case, 

with an exclusive right to take a few ‘free shots on goal.’ The Court imposed a deadline on the 

Oversight Board because PREPA is approaching its sixth year in bankruptcy with no viable path 

for emergence thanks to the Oversight Board’s flip-flops in legal positions. Yet, the Oversight 

Board has again admitted it did exactly what the Court asked it not to do: File a placeholder plan

that will have to be scrapped entirely if the Court disagrees with the Oversight Board’s litigation 

position.

4. Rather than enhancing the Plan to make it more confirmable (or at least, less ‘dead 

on arrival’), the Oversight Board has actually exacerbated and highlighted the reasons why it is 

patently unconfirmable as a matter of law and under this Court’s prior instruction. 

ARGUMENT

5. In the Syncora Objection, Syncora noted that the Oversight Board’s settlement with 

the Fuel Line Lenders constituted unfair discrimination among similarly-situated creditors 

embedded in the initial version of the Plan. The Amended Plan conspicuously doubles down on 

such unfair discrimination by providing National, as the holder/insurer of PREPA revenue bond 

claims, a 77.51% recovery on its claims (and by the Oversight Board’s own estimate more than 

83% recovery if the post-petition interest payment is approved), while it offers a 50% recovery to 

other similarly situated Bondholders (including monoline insurers) who agree to settle their claims. 

To add insult to injury, the Oversight Board arbitrarily sets 56% as the recovery cap for NonCase:17-03283-LTS Doc#:23563 Filed:02/17/23 Entered:02/17/23 14:31:02 Desc: Main

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Settling Bondholders who litigate and win on both the recourse and lien issues. That’s right: The 

Amended Plan proposes to pay National more in a “good-faith settlement” than Non-Settling 

Bondholders can receive if they win.8 

6. Notably, the Settlement Offer Notice to Uninsured Bondholders distributed on 

January 27, 2023 (ECF No. 3171) made no mention of the National Settlement or the terms thereof. 

And even the Oversight Board’s solicitation to Syncora,9 which does reference the National 

Settlement, only did so for purposes of ensuring Syncora would receive “customary monoline 

accommodation provisions,” while continuing to offer a 50% settlement. Without realizing it, the 

Oversight Board has admitted through the Syncora solicitation that the materially higher treatment

for National (77.51% vs 50.0%) has nothing to do with National’s status as a monoline insurer. 

7. The unfair discrimination standard prevents creditors “with similar legal rights 

from receiving materially different treatment under a proposed plan without compelling 

justifications for doing so.” In re Hermanos Torres Perez Inc., 2011 WL 5854929, at *9 (Bankr. 

D.P.R. Nov. 21, 2011); see also In re LightSquared Inc., 513 B.R. 56, 99 (Bankr. S.D.N.Y. 2014)

(“The purpose of the requirement is to ensure that a dissenting class will receive relative value 

8

 The Oversight Board has had ample time to formulate a purported rationale since it 

announced the National Settlement months ago, yet the Court will not find one in the Disclosure 

Statement.

9

 A copy of the February 14, 2023 solicitation to Syncora (via counsel) is attached hereto 

as Exhibit A. Syncora wishes to make clear that despite the “Privileged and Confidential” stamp 

on the solicitation, this was not an offer made in mediation, no communications were made with 

Syncora about the offer other than this email, and the Mediation Team was not even copied on the 

solicitation. Syncora submits nothing in the solicitation is confidential as the communication is 

what the Oversight Board advertised it would be sending in the Disclosure Statement (as crossreferenced in the communication) and on the first page of the public Notice to Uninsured 

Bondholders referenced above.

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equal to the value given to all other similarly situated classes.”). The Court would be hard-pressed 

to find a more blatant form of unfair discrimination among holders of the same instrument with 

the same legal rights than the Oversight Board proposes to provide in the Plan. Syncora challenges 

the Oversight Board to name a single precedent to defend this unfair discrimination gambit in its 

final reply in support of the Disclosure Statement. 

8. Critically, unlike the Commonwealth Title III case and plan of adjustment, this is 

not a situation where holders of PREPA bonds have different risk profiles based upon the unique 

challenges to the bonds they held. The Oversight Board offers no justification (let alone a 

convincing one) for the disparate treatment among holders of PREPA revenue bond claims based 

upon any unique legal risks or rights. The Oversight Board does not have a magic wand to remove 

critical statutory protections from creditors, and it cannot make the “unfair discrimination” 

standard disappear from the Bankruptcy Code. 

9. Syncora, a monoline insurer of PREPA bonds like National, is not aware of any 

legal grounds that would justify the disparate treatment between a creditor who holds an uninsured 

bond and the monoline that insures the bonds. Certainly, none of the plans of adjustment in which 

Syncora participated in these jointly-administered cases contained disparate treatment of a bond 

claim by the debtor based upon whether or not the bond claim was insured. Any differences in 

bondholder outcomes in those other plans was a result of how the monoline proposed to treat 

holders of its insured bonds—the monolines’ contract counterparties—to resolve their 

relationships with third parties (e.g., commutation, acceleration, creation of trusts, etc.).10 The 

10 Most financial guaranty policies provide that a bond issuer’s default, including nonpayment or an issuer’s bankruptcy filing, does not accelerate the payment of the insured bond by 

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debtor was (and should be) agnostic as to whether a particular bond claim was insured or uninsured 

because the rights vis-à-vis the debtor are identical as between uninsured and insured bondholders. 

10. By contrast, the Amended Plan here provides extreme differences in the treatment 

of claims based not only on whether the bond is insured, but whether it was insured by a particular 

monoline. Moreover, the Amended Plan goes so far as to propose different treatment to bonds that 

were insured by National depending on whether or not National has sold, assigned, and transferred

its interests and rights to third-party buyers. See Amended Plan at §I.A.148 (definition of National 

Insured Bonds). In other words, the treatment provided to a holder of a National insured bond 

claim will change depending on the owner of the claim. There is a simple reason why the 

Oversight Board offers no justification for the unfair and discriminatory treatment between holders 

the monoline insurer. Rather, following such a default and an acceleration of the issuer’s payment 

obligations under the operative bond documents, the monoline is generally required to make only 

regularly scheduled payments of principal and interest as and when such payments would 

otherwise be due in the absence of an acceleration. As a result of this tripartite relationship among 

the issuer, the monoline insurer and the holder of insured bonds, a bankruptcy plan involving 

financial guaranty insurers often provides the monoline with the plan consideration distributed on 

account of its insured bond claim from the debtor with monoline remaining liable to its insureds 

for the duration and under the terms of the original governing bond documents. Consequently, the 

monoline will often offer its insured an option to receive an accelerated distribution of the plan 

consideration plus some form of commutation consideration in lieu of the insurer’s ongoing 

payment obligations and an insured may be incentivized to prefer to settle its outstanding claims 

with its insurer rather than take the long-term credit risk of the insurer. See Modified Eighth 

Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, et al., dated 

December 20, 2021 (ECF No. 19568 in Case No. 17-3283), at Art. LXXV (Provisions Regarding 

Assured Insured Bonds, National Insured Bonds, Syncora Insured Bonds, Ambac Insured Bonds

and FGIC Insured Bonds). 

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of Class 1 claims (Settling Bondholder and Settling Monoline Claims) and Class 5 claims 

(National Insured Bond Claims); namely, there is none.

11

11. In what can only be described as a weak attempt to distract viewers from the brazen 

unfair discrimination in Class 5, the Oversight Board purports to take a higher road when creating 

Class 6.12 Class 6 on its face (without even needing to compare it to another class) recognizes a 

novel category of claim (called the National Reimbursement Claim), in order to attempt a 

distribution that is incompatible with the Bankruptcy Code and PROMESA. First, the allowance 

and treatment of the National Reimbursement Claim constitutes payment of post-petition interest 

to National that is not provided to any other bondholder or monoline. Second, the allowance of 

the National Reimbursement Claim violates section 509(c) of the Bankruptcy Code by providing 

payment of the National Reimbursement Claims before holders of the underlying National Insured 

Bonds are paid in full. See 11 U.S.C. § 509(c) (“The court shall subordinate to the claim of a 

creditor and for the benefit of such creditor an allowed claim, by way of subrogation under this 

section, or for reimbursement or contribution, of an entity that is liable with the debtor on, or that 

has secured, such creditor’s claim, until such creditor’s claim is paid in full, either through 

payments under this title or otherwise.”).

11

 See Amended Plan at § 1.A.227 (defining Settling Monoline to mean “a Monoline 

Insurer (other than National) that, by the Settlement Offer Deadline, became party to a Monoline 

Settlement Agreement.”) (emphasis added).

12

 The Oversight Board recognizes the inherent unfairness in the allowance and treatment 

it proposes to provide only to the National Reimbursement Claim, and voluntary offers to excise 

it. See Amended Plan §§ IX.B. and XVIII.I. (providing for the proposed treatment of the National 

Reimbursement Claim to be eliminated if the Court does not approve its allowability and 

treatment). The Oversight Board’s inclusion of Class 6 alone mimics life in the bazaar: “You 

make a good point about Class 6, so just let me have Class 5 and we’ll call it a deal.” 

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12. As acknowledged in the Initial Syncora Objection, finding that a plan is 

unconfirmable as a matter of law at the disclosure statement stage is generally a very high bar to 

meet. The Amended Plan, however, easily breaks the boundaries of what any plan proponent 

could propose in good faith. Moreover, while the Oversight Board appears to believe that it has 

an unlimited number of “free shots” in this case, this behavior is unfair to creditors who are being 

kept at bay by the automatic stay. The cost of pursuing a patently unconfirmable plan only to learn 

in July that the plan must fail is simply too high for all stakeholders. Accordingly, the Court should 

decline to approve the Disclosure Statement and, if it deems appropriate, the Court should provide 

the Oversight Board with one final opportunity to propose a confirmable plan. And since the 

Oversight Board did not hear it the first time, the Court should make clear that failing to do so will 

result in real consequences, such as dismissal of this Title III case or lifting the stay to facilitate 

the appointment of a receiver. Absent real consequences, the Oversight Board will continue to 

view the Title III process as a perpetual free option to attempt to evade legal requirements. 

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

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CONCLUSION

WHEREFORE, Syncora respectfully requests that the Court deny the Disclosure Statement 

Approval Motion, and provide Syncora such other and further relief as the Court deems 

appropriate.

DATED: February 17, 2023

Respectfully submitted,

REICHARD & ESCALERA

By : /s/ Rafael Escalera

Rafael Escalera

USDC No. 122609

escalera@reichardescalera.com

Sylvia M. Arizmendi

USDC-PR 210714

arizmendis@reichardescalera.com

Carlos R. Rivera-Ortiz 

USDC-PR 303409

riverac@reichardescalera.com

255 Ponce de León Avenue

MCS Plaza, 10th Floor

San Juan, Puerto Rico 00917-1913

QUINN EMANUEL URQUHART & 

SULLIVAN, LLP

Susheel Kirpalani (pro hac vice)

susheelkirpalani@quinnemanuel.com

Daniel Salinas

USDC-PR 224006

danielsalinas@quinnemanuel.com

Eric Kay (pro hac vice)

erickay@quinnemanuel.com

Kate Scherling (pro hac vice)

katescherling@quinnemanuel.com

51 Madison Avenue, 22nd Floor

New York, New York 10010-1603

Co-Counsel for Syncora Guarantee, Inc.

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CERTIFICATE OF SERVICE

I hereby certify that on this same date, I electronically filed the foregoing with the Clerk 

of the Court using the CM/ECF system which will send notification of such filing to counsel for 

the parties of record.

/s/Carlos R. Rivera-Ortiz

USDC-PR 303409

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EXHIBIT A

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From: Esses, Joshua <JEsses@proskauer.com>

Sent: Tuesday, February 14, 2023 8:07 PM

To: Susheel Kirpalani

Cc: Barak, Ehud; Possinger, Paul V.; Desatnik, Daniel

Subject: Oversight Board Settlement Offer to Syncora

[EXTERNAL EMAIL from jesses@proskauer.com]

Privileged & Confidential, subject to FRE 408 

Susheel, 

As you know, on February 9, 2023, the Oversight Board filed the First Amended Title III Plan of Adjustment of the Puerto 

Rico Electric Power Authority [Case No. 17-bk-4780, ECF No. 3200] (the “Plan”) and a corresponding disclosure 

statement. 

Article IV of the Plan sets forth the treatment to be provided to Settling Bondholders and Settling Monolines who accept 

the Oversight Board’s settlement offer by the Settlement Offer Deadline of February 24, 2023 at 4:00 p.m. (ET). As 

explained in further detail in the Plan and the disclosure statement, Settling Bondholders and Settling Monolines are to 

receive cash and Series B Bonds in the nominal amount of 50% of the value of their claim. Settling Bondholders will also 

receive upside in the form of (i) additional Series B Bonds if the Oversight Board is successful in its prosecution of the 

Amended Lien & Recourse Challenge and (ii) CVI. 

As explained in the Disclosure Statement, the Oversight Board hereby offers to settle Syncora’s PREPA Revenue Bond 

Claims for the recoveries set forth in Article IV of the Plan and as detailed in the foregoing paragraph. Please let us know 

by no later than February 21, 2023, if you would like to settle your claims and become a “Settling Monoline” under the 

Plan, and we will provide a draft settlement agreement for your review. The settlement agreement will be similar in all 

respects (including the same recovery) to the settlement agreement provided to all uninsured bondholders but would 

also include the customary monoline accommodation provisions, consistent with the Title III plans for the 

Commonwealth and HTA, and with the Plan’s current accommodations with respect to National. 

Best, 

Josh 

Joshua A. Esses

Associate - Business Solutions, Governance, Restructuring & Bankruptcy Group 

Proskauer

Eleven Times Square 

New York, NY 10036-8299 

d 212.969.3667 

c 203.912.2064

jesses@proskauer.com

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