If you are having trouble navigating through the newsletter, the online version can be found here: http://www.cllabankruptcy.org/bankruptcy/december2003.htm

Sua Sponte

Louis S. Robin
Fitzgerald, O'Brien, Robin & Shapiro
Longmeadow, Massachusetts
Email: louis.robin@prodigy.net

I am pleased to inform you that the League has submitted an amicus brief in support of the Sixth Circuit's decision in Hood v. Tennessee Student Assistance Corp. , 319 F.3d 755 (6 th Cir. 2003). There the Sixth Circuit rejected the State's assertion of sovereign immunity as a defense to a debtor's complaint to have a student loan discharged.

• read more...

Case Analysis

Karen J. Porter
Law Office of Karen J. Porter, Ltd.
Chicago , IL
Email: kjp@kjplaw.net

In re Bethea v Robert J. Adams & Associates, —F3d----, 2003 WL 22981377 (7 th Cir. Dec. 17 2003)

Case Analysis: In Bethea v Robert J. Adams & Associates, —F3d----, 2003 WL 22981377 (7 th Cir. Dec. 17 2003), the Seventh Circuit rules that chapter 7 debtors may discharge the unpaid legal fees owed to their attorneys along with their credit card debts and other bills.

• read more...

Case Law Update

Paige Barr
DePaul University J.D. Candidate
paigebarr@yahoo.com

Section 1123(a) “Notwithstanding” Clause Merely a Clarification. The court held that a reorganization plan proposed under § 1123(a)(5) expressly preempted otherwise applicable nonbankruptcy laws only to the extent that such laws were already preempted before the addition of the "notwithstanding" clause to § 1123(a) by amendment in 1984. The court found that the "notwithstanding" clause was merely a clarification and confirmation of the preemptive effect of a reorganization plan that already existed under the 1978 Bankruptcy Code. The “notwithstanding” clauses of §§ 1123(a)(5) and 1142(a) must be read together; the express preemption of § 1123(a)(5) is limited to otherwise applicable nonbankruptcy laws “relating to financial condition,” as specified in § 1142(a). Pac. Gas & Elect. Co. v. California , 2003 U.S. App. LEXIS 23567 (9th Cir. Nov. 19, 2003).

• read more...

Sua Sponte

I am pleased to inform you that the League has submitted an amicus brief in support of the Sixth Circuit's decision in Hood v. Tennessee Student Assistance Corp. , 319 F.3d 755 (6 th Cir. 2003). There the Sixth Circuit rejected the State's assertion of sovereign immunity as a defense to a debtor's complaint to have a student loan discharged. I have discussed this Circuit Court's opinion previously; see the case note on this opinion at : http://www.cllabankruptcy.org/bankruptcy/march2003.htm#6 .

The League's amicus brief was prepared by Laurence Kaiser. Laurence graduated Georgetown University Law Center in 1975 and has been in private practice in New York City since then. He has specialized in bankruptcy since 1980, and was one of the founders of Piliero Goldstein Kaiser & Mitchell, LLP. He is a recurrent contributor of amicus briefs. For example, he successfully contributed to the representation of six bankruptcy judges over whether the judges continued in office during the Marathon constitutional crisis in 1984. Richard Lieb, Esq., and old friend of the League and presently a professor at St. John's Law School recommended him, and he was a wise choice. His effort can not be measured by routine procedures, and we owe him the greatest of thanks. Although he acknowledges the contributions of others in the amicus brief, the tribute belongs only to him.

I will attempt to quote and summarize some of Laurence Kaiser's arguments for your benefit. He starts by noting that:

The CLLA has long represented and advocated creditor interests, but its members recognize that the fair, equitable, uniform and efficient administration of bankruptcy cases and debtor-creditor relations requires that all parties, including the States, participate in the bankruptcy process. Had the States retained sovereign Immunity from the discharge of indebtedness (or from other generally applicable bankruptcy court powers) that would have perpetuated the very disunity, disorder and uncertainty which the Framers and the People confronted and rectified when they granted Congress the power to enact “uniform laws on the subject of bankruptcies.

Laurence Kaisers discussion turned to the background of bankruptcy at the end of the 18 th Century:

When the Constitution was enacted, debtors and creditors confronted differing State laws, rights and remedies

• • •

The hodgepodge of laws and their uneven enforcement offered debtors no assurance that the protections afforded by the bankruptcy law of one state would be enforced in another state: “a state cannot by such a law discharge one of its own citizens from his contracts with citizens of other states, though made after the passage of the law, unless they voluntarily became parties to the proceedings in insolvency.” Brown v. Smart , 145 U.S. 454, 457 (1892).

• • •

The disparate laws and multiple jurisdictions also adversely affected creditors. The Colonies began to recognize that the property of an insolvent belonged to all creditors, not simply the quickest (Mann at 47-48), but the realization of that ideal was difficult.

• • •

The Framers' response to these problems was two-fold. First, of course, was to grant Congress the power to enact “uniform laws on the subject of bankruptcies.” Second, was the early bankruptcy legislation enacted under that power.

• • •

Congress turned to bankruptcy legislation in the first session of the 1 st Congress and returned to the subject of bankruptcy in each of the next four Congresses [enacting bankruptcy legislation in 1800] . . . Three aspects of the Bankruptcy Act of 1800 provide compelling evidence that the States did not retain – and were understood at the time as having not retained – sovereign immunity over the subject of bankruptcies. First, the Bankruptcy Act of 1800 was enacted only three years after the enactment of the Eleventh Amendment and only seven years after Chisolm v. Georgia , 2 Dall. 419 (1793) – the decision that “shocked” the nation into enacting that amendment. College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board , 527 U.S. 666, 669 (1999). It is illogical – if not extraordinary – to assume that the Congress in 1800 disregarded or ignored the recent reaffirmation of the States' sovereignty immunity. Yet, the 1800 Act expressly made debts owed to the States immune from discharge. Bankruptcy Act of 1800, § 62. That affirmative statutory grant of immunity would have been superfluous if the States had retained sovereign immunity in bankruptcy.

Second, the 1800 Act contained uniform exemptions for debtors. Id . , § 34. Nothing in the Act suggests an individual debtor could not enforce those exemptions against the States or recover exempt property in the possession of the State. Congress must have understood that that would be the result and that debtors would be without a remedy if the States – as they argue today – enjoyed sovereign immunity.

Third, the 1800 Act expressly authorized federal courts to issue writs of habeas corpus to free debtors from state prisons. Id . , § 38. Judge Haines has noted that this provision uniquely conferred federal jurisdiction over the States and their conduct (and his analysis need not be repeated here). Haines at 174-81. The inclusion of the writ of habeas corpus – without recorded dissent or concern – in the 1800 Act demonstrates compellingly that the Framers understood that the power to enact “uniform laws on the subject of bankruptcies” was intended to invade the usual prerogatives and protections of State sovereignty.

Laurence Kaiser also focused on the language of the Constitution, noting the language and placement of the bankruptcy clause (It is a cardinal principle of statutory construction that a statute ought to be so construed that no clause, sentence, or word shall be superfluous, void, or insignificant). Further, the bankruptcy discharge is enforced by private suits, ordinarily subject to sovereign immunity defenses, as opposed to the federal government bringing suit to enforce the discharge, which might not be subject to sovereign immunity defenses. Lastly, the dignity of the states is not affected because the discharge is not utilized to collect any debts from the states, the uniform application of the discharge against all creditors, and that the action in the case at bar is an action to determine whether the discharge applies to a particular debt.

Although Laurence Kaiser concentrated on the discharge issues at bar, the history of the Constitution, the language of the clause, and other related historical issues, he also notes the other aspects and scope of the states' sovereign immunity arguments. Taken to an extreme, the States could avoid automatic stay violations, circumvent fraudulent transfer and preference actions, frustrate sales free and clear of liens, and evade turnover actions. All would deny creditors and debtors necessary remedies for effective bankruptcy relief.

Once again I must thank Laurence Kaiser, on behalf of the League and myself, for his remarkable effort. One cannot thank Laurence enough. We hope that his efforts provide the Supreme Court with some constructive guidance. You may view the entire brief by clicking here.

My best to all for a happy and healthy new year.

Louis S. Robin
Fitzgerald, O'Brien, Robin & Shapiro
1200 Converse Street
Longmeadow, MA 01106
Phone: 413-567-3131
Fax: 413-565-3131
Email: louis.robin@prodigy.net

back to top ^

Case Analysis

In re Bethea v Robert J. Adams & Associates, —F3d----, 2003 WL 22981377 (7 th Cir. Dec. 17 2003)

Case Analysis: In Bethea v Robert J. Adams & Associates, —F3d----, 2003 WL 22981377 (7 th Cir. Dec. 17 2003), the Seventh Circuit rules that chapter 7 debtors may discharge the unpaid legal fees owed to their attorneys along with their credit card debts and other bills.

Summary : In the Seventh Circuit strikes another blow to debtor's attorneys in the area of collecting legal fees in connection with representing chapter 7 debtors. Three chapter 7 debtors filed adversary proceedings against their former attorneys seeking to hold the lawyers in contempt for violating the discharge injunction by collecting the unpaid balance due for legal fees in installments after the debtors received their discharges. The Court reversed the bankruptcy court's ruling that the fees were reasonable and were not discharged under section 329(b). In holding the unpaid prepetition claim for legal fees was dischargeable, the Seventh Circuit created a conflict with the Ninth Circuit and ripened this issue for review by the Supreme Court.

Discussion: Three firms that handle a large volume of consumer chapter 7 cases were each sued by a former client for a practice that is common in the Circuit and probably across the country. Each client hired the lawyer before filing the chapter 7 petition. Each client agreed to pay a retainer for the preparation and completion of the chapter 7 case. The retainer was not paid in full before the petition was filed. The retainer was to be paid in installments and some of the installments would be paid after the petition was filed. The lawyers completed the chapter 7 cases, the clients received their discharges and the cases were closed by the court.

The lawyers continued to collect the installments of the unpaid attorneys fees from the debtors. The three debtors, with new counsel, commenced adversary proceedings to hold the lawyers in contempt for violating the discharge injunction.

Section 524(a)(2) provides that a discharge “operates as an injunction against the commencement or continuation of an action, the employment of process, or an act, to collect, recover or offset any such debt as a personal liability of the debtor, whether or not discharge of such debt is waived. The debtors sought return of the fees paid and other relief against the attorneys.

There was no question that the fees charged by the lawyers were reasonable and that the debtors received the legal services they paid for. The bankruptcy court analyzed the issues raised under section 329 of the Code which governs a debtor's transactions with an attorney. Section 329 requires that the attorney file a statement disclosing the amount of the compensation and grants the court authority to grant the debtor relief if the compensation exceeds the reasonable value of the services. The bankruptcy court found that section 329, which deals specifically with attorney compensation, supersedes the more general discharge provisions of section 727 of the Code. The bankruptcy court concluded that section 329 is the sole provision controlling debtor's legal fees; to find otherwise would render section 329 ineffectual. Since the fees were reasonable, the bankruptcy court dismissed the adversaries.

The Seventh Circuit rejected the bankruptcy court's analysis. The court treated the unpaid attorneys fees as any other debt or claim that arose before the petition was filed. The court found that section 727(b) which discharges a debtor from all debts that arose before the date of the order for relief was controlling. Section 523 of the Code, which lists the types of debts that are excepted from discharge, did not include attorneys fees. The retainers were pre-petition liquidated debts that were discharged.

The court specifically found that section 329 of the Code could not be treated as an implicit exception to the discharge provisions of section 727. The court indicated its express agreement with In re Biggar , 110 F.3d 685 (9 th Cir. 1997) a case in which the Ninth Circuit found prepetition legal fees were dischargeable. The Seventh Circuit also refused to be swayed by the concern that its decision could prevent the most destitute of debtors from obtaining legal counsel since they could not pay the attorney in advance and the fee could not be collected after the case was completed. The court stated: “The argument about what makes for good public policy should be directed to Congress”.

The Court then goes on to specifically reject a middle ground approach considered by the bankruptcy court and adopted by the Ninth Circuit in In re Hines, 147 F 3d 1185 (9 th Cir 1998). In that case, the Ninth Circuit decided that Congress failure to provide that the fees of debtors counsel would not be discharged was an oversight that compelled the court to invoke the doctrine of necessity. The court found that the postpetition services provided by the debtor's attorneys were not subject to the

automatic stay or the discharge provisions of the Code. The Seventh Circuit refused to follow the approach of rewriting the debtor's agreement with the attorneys into prepetition and postpetition segments. It also refused to rewrite the Code to treat the debtor's attorney differently from any other creditor. “Attorneys compete with other creditors, such as banks, credit card issuers, supermarkets . . . some of these have obtained protection under §523 and others have not”. The court found the debtors attorneys must repay any sums collected after the discharges were granted. The court also noted that its decision created a conflict with the Ninth Circuit's decision in Hines .

Comment : The first noteworthy aspect of this decision is the Seventh

Circuit suggests that debtors could rehire the attorney after the petition is filed and receive administrative priority. However, that very issue is presently before the United States Supreme Court in In re Equipment Services , 290 F3d 739 (4 th Cir. 2002) cert. granted Lamie v US Trustee, 123 S.Ct. 1480(2003). The Supreme Court will decide if the present version of section 330, which omits the words “debtors attorney” precludes the the debtor's attorney in a chapter 7 case from receiving any compensation from the estate. It is also significant that the Ninth Circuit decision in Hines was written by a district court judge from Illinois sitting by designation. This creates the likelihood that before the issue of the dischargeability of prepetition legal fees reaches the United States Supreme Court, the Ninth Circuit could overrule its Hines decision, adopt the Seventh's Circuit's analysis in Bethea v Adams and eliminate the split in the Circuits. This will remain an important issue to watch as it develops in the courts. These decisions which limit the ability of debtors attorney to be paid can have a long term effect on bankruptcy practice and the volume of bankruptcy cases filed. The need for Congress to act in the area of compensation for the chapter 7 debtor's attorney is apparent. However, until it does, if you represent chapter 7 debtors— get paid in full and up front.

Karen J. Porter
Law Office of Karen J. Porter, Ltd.
11 E. Adams Street, Suite 1100
Chicago , IL   60603-6303
Phone: 312-673-0333
Fax: 312-673-0334
Email: kjp@kjplaw.net

back to top ^

Case Law Update

Section 1123(a) “Notwithstanding” Clause Merely a Clarification. The court held that a reorganization plan proposed under § 1123(a)(5) expressly preempted otherwise applicable nonbankruptcy laws only to the extent that such laws were already preempted before the addition of the "notwithstanding" clause to § 1123(a) by amendment in 1984. The court found that the "notwithstanding" clause was merely a clarification and confirmation of the preemptive effect of a reorganization plan that already existed under the 1978 Bankruptcy Code. The “notwithstanding” clauses of §§ 1123(a)(5) and 1142(a) must be read together; the express preemption of § 1123(a)(5) is limited to otherwise applicable nonbankruptcy laws “relating to financial condition,” as specified in § 1142(a). Pac. Gas & Elect. Co. v. California , 2003 U.S. App. LEXIS 23567 (9th Cir. Nov. 19, 2003).

Bar Order Dates Must Adequately Notify Creditors. Those creditors not required by the Code or the Bankruptcy Rules to physically file a claim cannot be barred by a bar date order that “all creditors file a proof of claim by the bar date” unless they receive adequate notification that they are not able to rely on § 1111(a) or Bankruptcy Rule 3003. Court rejected any decision of whether a bankruptcy court can ever order proof of claims to be filed by creditors whose claims would be deemed filed under § 1111(a). Furthermore the court failed to find authority under § 105(a) to order that proof of claims must be filed by all creditors notwithstanding § 1111(a). ATD Corp. v. Advantage Packaging, Inc. ( In re ATD Corp.), 2003 U.S. App. 25412 (6th Cir. Dec. 17, 2003).

Pre-Petition Debts for Legal Fees Subject to Discharge Under § 727. Rejecting the bankruptcy and district court decisions, the court found pre-petition debts for legal fees are subject to discharge under § 727. Since grouping legal fees with other debts subject to discharge does not gut § 329(b) for chapter 7 cases, the structure of the Bankruptcy Code does not support treating § 329 as an implicit exception to § 727. The lawyers contended that reading 727 this way would force “the most destitute of debtors to forego legal assistance, because counsel neither could be paid in advance nor could collect after the case ends.” In response the court directed the attorneys to address Congress with their argument, since it is the judiciary's job to solely enforce the law Congress has enacted. Bethea v. Robert J. Adams & Assoc ., 2003 U.S. App. LEXIS 25417 (7th Cir. Dec. 17, 2003).

United States Trustee Has the Authority to Accept Voluntary Resignation of Trustee in a Pending Case. The law does not require the decision of whether a trustee may withdraw from a pending case to be submitted to the bankruptcy court for approval. “Whether viewed directly through 28 U.S.C. § 586(b) or the prism of the common law, the light of the law falls squarely upon a single conclusion: the authority to accept the voluntary resignation of a bankruptcy trustee is vested entirely within the purview of the United States Trustee's congressionally conferred authority.” Where a common law principle is well-established, the courts may take it as given that Congress has legislated with an expectation that the principle will apply except "when a statutory purpose to the contrary is evident.” No statutory purpose to the contrary exits as to the voluntary resignation of a trustee in a pending case. Thus, the bankruptcy court's ruling requiring a motion, evidentiary hearing, and a judicial determination to decide whether a bankruptcy trustee who wishes to resign voluntarily is justified in so doing is not supported by law. In re Brookover , 2003 U.S. App. LEXIS 25739 (6th Cir. Dec. 19, 2003).

Income Tax Forms Filed Years Late Do Not Constitute “Returns.” Delinquent personal income tax filings, submitted years after the IRS prepared its own assessments, do not constitute “returns” for purposes of the Bankruptcy Code. Thus, these personal income tax liabilities may not be discharged. However, the court refused to find that any post-assessment filing might never qualify as a return for purposes of 11 U.S.C. § 523(a)(1)(B)(i). Joining the Sixth and Ninth Circuits, the court held that in order for a document to be considered a "return," under either the bankruptcy or the tax laws, it must (1) purport to be a return; (2) be executed under penalty of perjury; (3) contain sufficient data to allow calculation of tax; and (4) represent an honest and reasonable attempt to satisfy the requirements of the tax laws. A "return" is not reasonably understood to mean any tax form - whatever its defects - submitted to the IRS, but rather a form that in good faith reports required information like income, deductions, exemptions, and taxes due. Delinquency, no less than fraud or willful evasion, can result in tax forms not naturally thought of as returns. Moroney v. United States ( In re Moroney), 2003 U.S. App. LEXIS 25790 (4th Cir. Dec. 19, 2003).

Absent a Showing of Undue Hardship under § 523(a)(8), Court Cannot Use 105(a) to Issue Moratorium. The plain language of § 523(a)(8) provides that discharge from a student loan, an otherwise nondischargeable debt, may be ordered only upon proof of undue hardship. “To permit enforcement of any type of discharge, such as the novel relief crafted by the bankruptcy court in this case, in the absence of proven undue hardship would chip away at § 523(a)(8); the collective force of such piecemeal exceptions ultimately would eviscerate the statute.” Because Appellee failed to prove undue hardship within § 523(a)(8) the bankruptcy court exceeded its equitable authority under § 105(a) in ordering the moratorium. United States Dept. of Education v. Blair ( In re Blair ), 301 B.R. 181 (D. Ma. Nov. 12, 2003).

Paige Barr
DePaul University J.D. Candidate
200 N. Dearborn St., Apt. 4101
Chicago, IL 60601
(312)782-4428
paigebarr@yahoo.com

back to top ^

Washington Hot News

December 29, 2003
Government Requests Public Comment On GLB Privacy Notices.

Eight federal regulatory agencies, the Board of Governors of the Federal Reserve System; Joint Release Commodity Futures Trading Commission; Federal Deposit Insurance Corp.; Federal Trade Commission; National Credit Union Administration; Office of the Comptroller of the Currency; Office of Thrift Supervision; and Securities and Exchange Commission, December 23rd, published in the Federal Register an advance notice of proposed rulemaking (ANPR) asking the public to comment on ways to improve the privacy notices financial institutions provide to consumers under the 1999 Gramm-Leach-Bliley Act.

The request describes various approaches that the agencies could pursue to allow or requires financial institutions to provide alternative types of privacy notices that would be more readable and useful to consumers. The ANPR also seeks comment on whether federal and state law differences pose any special issues for developing a short privacy notice.

Section 503 of GLB requires "financial institutions" (which has been interpreted broadly to include individuals providing certain types of financial planning advice) to provide a notice to each customer describing their policies/practices regarding third party disclosure of nonpublic personal information. In 2000, the aforementioned agencies published consistent implementing final regulations, including sample privacy notices (but they do not prescribe any specific format to standardized wording for privacy notices).

December 24, 2003
Few Legislative Days Expected for Senate In Election-Year, Bankruptcy does not appear to be a "priority".

On January 20th, after about 7 weeks away, the Senate returns to begin the 2nd session of the 108th Congress.

The anticipated election-year calendar (including significant "out of DC time") and the agenda could result in a difficult year for legislation which may run past the November elections, especially in light of Congresses inability to complete the annual appropriations bills on time. For anyone keeping score, "lame-duck" sessions (a legislative session conducted after election of new members but before they are installed) have occurred at the end of the 105th, 106th and 107th Congresses.

The first order of business for the Senate when it returns will be the 04 Omnibus Spending Bill ( HR 2673 ), which covers 7 agencies and is valued at $820 billion.

The Senate is targeting an "initial" adjournment date of October 1, while the House is hoping to leave October 4, giving each chamber about one month off to campaign before the November 2 election.

Currently, bankruptcy reform does not appear to be particularly high on any agendas in the Senate.

December 19, 2003
Federal Reserve, FTC Issue Interim Rules, Proposal on effective dates of Fair Credit Law.

On December 16th, the Federal Reserve Board and Federal Trade Commission announced effective dates for the Fair and Accurate Credit Transactions Act of 2003, signed by President Bush December 4th.

According to supporters, the new law makes permanent federal credit reporting rules that preempt state law, provided tools to combat identity theft, and introduced measures to increase accuracy of credit reports and promote consumers' access to their credit histories.

According to a December 16 draft Federal Register notice, the proposed interim final rules set December 31 as the effective date for provisions that determine the relationship between the Fair Credit Reporting Act and state laws and that authorize rulemakings and other implementation by federal agencies.

In joint notice of proposed rulemaking, the agencies proposed March 31, 2004, as the effective date for:

• Statutes of limitations,
• Liability and enforcement for furnishers of information, and
• Action on complaints.

For other parts of the law, requiring more substantial changes for businesses, the agencies proposed December 1, 2004 as the effective date. Those parts include:

• Fraud alerts and active duty alerts on credit files,
• Procedures to identify potential identify theft,
• Truncation of social Security numbers in consumer credit reports,
• Summaries of rights of identity theft victims,
• Blocking of information resulting from identity theft,
• Coordination of identity theft complaint investigations,
• Notice by debt collectors about fraudulent information,
• Free consumer credit reports,
• Enhanced disclosure of the means to opt out of prescreened records,
• Affiliate sharing rules,
• Disposal of consumer report information and records,
• Duties to give notice to consumers,
• Procedures to enhance accuracy and integrity of information furnished to consumer reporting agencies,
• Improved disclosure of reinvestigation results,
• Reconciling addresses, and
• The duty to conduct reasonable reinvestigations on consumer credit information.

Comments on the notices, which are expected to be published in the Federal Register soon, are expected to have a January 12, 2004 deadline.

December 11, 2003
Chapter 12.

The House apparently was unable to take up S.1920 while briefly in session this December ( S.1920 extended Chapter 12 for an additional 6 months). Thus, Chapter 12 will lapse on December 31.

On a related note, during its brief return, Sens. Grassley (R-Iowa) and Feingold (D-WI) introduced S.2004 , a bill to permanently reenact Chapter 12. The bill was referred to the Judiciary Committee.

back to top ^

Insol India

INSOL India and Business Recovery and Insolvency Professionals Association of Sri Lanka (BRIPASL) are jointly organising the Colombo Conclave - a mega event of insolvency experts and professionals in Colombo , Sri Lanka from 13 th to 15 th February 2004 . The Conclave is being designed as an international conference to deliberate upon issues, which concern the Asian countries at large, and the Indian sub continent countries in particular. The theme of the conference is Balancing Recovery, Restructuring and Liquidation- the emerging challenges in Asia .

With its beautiful landscape, coral beaches and plenty of history, the island is a popular destination for tourists. At the same time, with an Exclusive Economic Zone in the Indian Ocean of approximately 517,400 km where she can exercise exclusive rights in respect of all economic resources of the ocean water column, the underlying sea bed and sub soil, Sri Lanka has enormous potential for trade and other economic activity.

Experts and professionals from developed and developing insolvency regimes from across the world will assemble in Colombo to share their experience. We hope to have speakers from ministries of both the countries, legal and accountancy firms from across the world, representatives of international body of regulators, World Bank, Asian Development Bank, International Monitory Fund, INSOL International and other organisations.

The Conclave, which will be attended by about 250 delegates from all over the world.

As Technical Co Chairman, it is my pleasure to invite you to the Conclave. The Program brochure and registration details are available on our website www.insolindia.com

The closing date for registration has been extended to 31st January 2003. There will be tremendous opportunity for networking and marketing.

Questions can be directed to:  

Sumant Batra, Senior Partner
Kesar Dass B & Associates

15, Birbal Road , Jangpura Extension
New Delhi -110 014 India

Tel: 91-11-5182 3285 to 3289
Fax: 91-11-5182 3290,5182 3291
Email: sumant.batra@kesardass.org

back to top ^