I N S I G H T S
and Developments in the Law
FALL,
2009
Federal Stimulus Package Benefits Small Business Owners
by Cynthia Brooks
The American Recovery and Reinvestment Act of 2009 was
signed into law on February 17, 2009 and is commonly referred
to as the stimulus package. The Recovery Act contains several
provisions that are designed to assist small businesses. Some of
these provisions are only expected to be funded through the end
of 2009 or 2010, so the time to apply is now.
Under the Recovery Act, the SBA has temporarily eliminated
some borrower fees and temporarily increased guarantees up to
90% on the 7(a) program, the SBA’s most common loan
program. The fee elimination makes more capital available to
businesses at a lower cost. The SBA will refund qualified fees
that have already been paid on those loans to lenders, who will
then be required to reimburse the borrowers who paid the
qualified fees. Before the Recovery Act, a 7(a) loan of $300,000
carried a guarantee fee of between 2 and 3 percent. That same
loan today, with the new 90% guarantee and the temporary fee
elimination, would save a borrower about $8,100.
The Recovery Act recognizes that these economic times have
caused many small business owners to have difficulty repaying
debt they normally pay on time with relative ease. As a result,
the Act has implemented America’s Recovery Capital Loan
Program (“ARC”), which provides up to $35,000 in short-term
debt for viable small businesses that can show that they will
return to viability after receipt of one ARC loan. ARC loans are
interest free, carry a 100% guaranty from the SBA to the lender,
and require no fees paid to the SBA. ARC loan proceeds are
provided over a 6-month period and repayment of ARC
principal payments are deferred for 12 months after the final
disbursement of loan proceeds. Repayment of an ARC loan can
be made for up to 5 years. To qualify for an ARC loan, a small
business must have valid financial statements that show that it
reasonably project sufficient cash flow to meet current and
future loan payments over a two-year period from the
ARC loan approval date. Even existing SBA loans can be
repaid with an ARC loan.
The Certified Development Company (“CDC”) is a 504
SBA loan program that is a long-term financing tool that
supports economic development within certain
communities. Under the CDC/504 program, a growing
small business can obtain fixed-rate financing for purchasing, renovating or
expanding major fixed assets such as
land, buildings, machinery and equipment, but 504 loans are not made to
businesses engaged in real estate
investment. The Recovery Act allows 504 projects to include a limited amount of
debt refinancing if there is a
business expansion and the debt refinanced does not exceed 50% of the projected
cost of the expansion. “Expansion”
includes any project that involves the acquisition, construction or improvement
of land, buildings or equipment for
use by the small business. Under the program, a 504 loan is required to create
or retain a minimum number of jobs
within two years of the loan disbursement as a result of the project or to meet
other defined economic development
objectives. Some fees are also temporarily eliminated for both borrowers and
third-party lenders on CDC/504 loans.
For more information on SBA financing, please contact Cynthia Brooks at
cbrooks@hertenburstein.com.
November 30, 2009 Deadline for
Filing for Reimbursement of Non-
Residential Development Fees
The New Jersey Economic Stimulus Act, enacted July 27,
2009, gives relief from the payment of COAH 2.5%
Non-Residential Development Fees (NRDF) for some but
not all developers. Developers are encouraged to
investigate whether they are entitled to a credit for
already paid NRDFs. Municipalities, in reviewing
requests for reimbursement of already paid NRDFs are
advised to review when the subject project received its
approvals before reimbursing the developer.
The NRDF Claim Form with instructions is available on
COAH's website at www.nj.gov/dca/affiliates/coah
/regulations/nrdf. If you think you may be eligible for
reimbursement of part or all of the 2.5% NRDF fee you
previously paid, the NRDF Moratorium FAQ (frequently
asked questions) is a good reference. It can also be found
on COAH's website.
If you have further questions or require advice regarding Affordable Housing
regulations and law, contact Nilufer DeScherer at
ndescherer@hertenburstein.com.
Buying or Selling a Business:
Letters of Intent
By Gianfranco A. Pietrafesa
The first article in this series discussed non-disclosure or
confidentiality agreements. This article discusses letters
of intent and term sheets, which set forth the basic terms
of a deal. It is usually the second document signed by the
parties when selling or buying a business.
There are a number of reasons to use a letter of intent.
First, it allows the parties to summarize the key terms and
conditions of the transaction, which reduces or even
eliminates future misunderstandings during negotiations
of the contract documents. A letter of intent also identifies
problems (or deal-breakers) in the early stages of the
negotiations, before incurring the costs of negotiating and
preparing the contract documents and performing due
diligence on the seller.
Second, if the period of time between the signing of the
letter of intent and the closing of the transaction is
significant, the letter of intent can govern the parties’
relationship during this time period. The time period can
be significant depending on, for example, the scope of the
buyer’s due diligence on the seller, and the number of
consents or approvals that need to be obtained from third
parties, such as landlords.
Third, a buyer can use a letter of intent to obtain
financing from a lender. Fourth, a letter of intent can be
used to comply with certain regulatory requirements. For
example, the parties can use a letter of intent to satisfy
Hart-Scott-Rodino Antitrust Improvement Act filing
requirements, and perform due diligence and negotiate
the contract documents during the required waiting period
under the law.
Contents
A letter of intent should include the following provisions.
1. Structure – A description of the transaction; for
example, whether it will be a stock purchase or an asset
purchase.
2. Exclusions – A description of any assets or liabilities
that will be excluded from the transaction.
3. Price – The purchase price or the method for
determining the purchase price, and any adjustments to
the same.
4. Payment Terms – The payment terms, such as
whether the purchase price will be paid in cash, notes
and/or securities.
5. Indemnification/Escrow – A description of any
indemnification obligations of the seller and any amount
of the purchase price to be held in escrow.
6. Employment – Identification of any employment or
consulting agreements for the seller’s employees and
non-competition agreements for the selling shareholders.
7. Conditions – Any conditions that must occur before
closing; for example, financing to be obtained by the
buyer, satisfactory due diligence by the buyer, consents
to be obtained from third parties (such as landlords),
receipt of approvals from directors and shareholders, and
necessary approvals to be obtained from regulatory
agencies.
8. Due Diligence – The scope, time period and
procedures for the buyer’s due diligence of the seller’s
business.
9. Confidentiality – If the parties entered into a nonsmall
disclosure agreement, it should be referred to in the letter
of intent. If not, the letter of intent should address the
buyer’s obligation to maintain the confidentiality of any
confidential information provided by the seller.
10. Non-Solicitation – A buyer’s prohibition of soliciting
the seller’s employees for a certain period of time if the
deal does not close.
11. Representations and warranties – A description of
any specific representations and warranties that will be
required in the contract documents.
12. Ordinary Course – Obligation of the seller to
conduct its business in the ordinary course and to avoid
any extraordinary transactions between the time the letter
of intent is signed and the time of the closing of the
transaction.
13. Exclusivity – A buyer may want a provision requiring
the seller to deal exclusively with the buyer and not to
seek or entertain other offers.
14. Miscellaneous – Customary provisions such as
governing law and jurisdiction.
Binding vs. Non-Binding
Typically, the deal terms in a letter of intent, such as the
purchase price and payments terms, are non-binding. That
is, the parties do not intend to be legally bound to these
terms until they sign the final contract documents.
However, other terms in the letter of intent are intended to
be binding. For example, the obligation to maintain the
confidentiality of the seller’s confidential information and
prohibiting the buyer from soliciting the seller’s employees
are legally binding.
To minimize, and ideally to prevent, disputes about
whether a letter of intent is binding or non-binding, a letter
of intent is frequently divided into two distinct sections,
one containing the binding provisions and the other the
non-binding provisions.
A buyer and a seller must ask their attorneys to negotiate
and prepare a letter of intent to accurately summarize the
terms of a deal and to ensure that certain terms will be
binding and others non-binding.
For more information on letters of intent, or buying or selling a business,
please contact Gianfranco Pietrafesa at
gpietrafesa@hertenburstein.com.
NEWS FROM HERTEN BURSTEIN
Herten Burstein was profiled in the “New Jersey Legal Profiles”
section of Forbes magazine. An article, “New Jersey’s ‘Go-To,
Stay-With’ Business Law Firm,” appeared in the September 7
issue. A copy of the article is enclosed in this issue of Insights.
In the August 31, 2009 edition of NJ BIZ, Herten Burstein was
listed among the top 50 law firms in New Jersey; it was one of
only two law firms in Bergen County to make the list.
Founding and senior member Thomas Herten, relying on the
expertise of Labor and Employment member Steven Harz and
associate Daniel Ritson with respect to the New Jersey Law
Against Discrimination (“LAD”), recently prevailed in what will
serve as a precedential case for private golf and country clubs
operating in New Jersey, generally subject to the jurisdiction of
the New Jersey Division on Civil Rights. Mr. Herten and the
firm’s attorneys successfully defended a private golf facility
against a complaint alleging member discrimination. Contrary
to the complainant’s allegations, the Division ruled that the
facility was not a place of public accommodation and,
accordingly, was not subject to the LAD, and granted the firm’s
motion to dismiss the complaint. The matter was watched
closely by other private clubs in North Jersey and the decision
was lauded by them as well as by the client.
Litigation member Michael Lubin was recently appointed by
the Superior Court as a Special Master in a case involving the
Borough of Elmwood Park. In that case, a developer sued the
borough based upon its failure to comply with statutes and
regulations pertaining to the obligation of each municipality to
provide a designated fair share of affordable housing units for
low and moderate income persons. Michael’s assignment will
include: conferring with the parties and their representatives
toward the end of reaching a settlement on this issue and
reporting to the court on his efforts to obtain compliance. He
has had considerable experience in the field of land use law,
having served as a planning board attorney for over 25 years
and having lectured on the subject for Rutgers University, the
New Jersey Institute for Continuing Legal Education and the
National Business Institute. Michael has also been appointed
by the Superior Court in other matters and has previously
served in the capacities of Discovery Master, Special Fiscal
Agent, Receiver and Guardian.
An article by Real Estate Chair Arnold Litt, “Right of First
Refusal to Lease Additional Space Terminates Upon the
Expiration of the Lease Term,” was published in the October 16
issue of the New Jersey Law Journal.
On October 2, Herten Burstein joined with thousands of
companies around the country to support Lee National Denim
Day, one of the largest single-day fundraisers to battle breast
cancer. In 2008, approximately 800,000 individuals wore
denim on Lee National Denim Day. More than 85% of firm
personnel supported this worthy cause.
Dispute Resolution Clauses in Buy-Sell Agreements
By William H. Schmidt, Jr.
This is part of a series of articles on buy-sell agreements by members of the
firm’s Business Law group.
The purpose of this article is to briefly introduce and describe
some various methods of resolving voting deadlocks and
other disputes that arise between and among (a) members of
a limited liability company (“LLC”); and (b) stockholders of a
closely held corporation. Because dispute resolution clauses
are similar in either the LLC or the corporate context, for
purposes of this article, Members and Stockholders are
generically referred to as “Interest Holders” and the
Operating Agreement and the Stockholders’ Agreement are
generically referred to as an “Interest Holders’ Agreement.”
Carefully drafted Interest Holders’ Agreements detail the
procedure to be followed by the Interest Holders in the event
of any dispute arising between and among the Interest
Holders as to any matter or thing covered by the Interest
Holders’ Agreement or as to the meaning of the Interest
Holders’ Agreement. Many Interest Holders’ Agreements
provide (expressly or impliedly) that parties will settle their
disputes in the court system. These Interest Holders’
Agreements will indicate which specific State law is to apply
and will, oftentimes, obligate the parties to litigate in a
specified State court or the Federal District Court located in
a specified State.
There is a current view shared by a growing number of
attorneys that litigation as a dispute resolution method is too
expensive and time-consuming, and, often, adversely affects
the continuing viability of the business enterprise. Thus,
alternate dispute resolution methods have been crafted by
attorneys to lower the expense of dispute resolution and
generally reduce the time for such resolution. However, other
attorneys argue that litigation under most circumstances will
result in a fairer, less arbitrary resolution of disputes and
preserves the right to appeal.
The general categories of disputes that typically arise
involve (1) the breach of the terms of the Interest Holders’
Agreement by one or more of the Interest Holders; (2) the
interpretation of the terms of the Interest Holders’ Agreement;
and (3) a “deadlock.” A deadlock occurs when there are
neither sufficient votes of the Interest Holders (voting as
Directors or Members) to approve or disapprove a matter.
Following are examples of some methods of non-judicial
dispute resolution that can be agreed upon by the Interest
Holders and included in the Interest Holders’ Agreement:
1. Arbitration – An arbitration “procedure” can be agreed
upon by the Interest Holders and included in the Interest
Holders’ Agreement. Some arbitration clauses encourage
the Interest Holders to settle their disputes in good faith
before the intervention of an arbitrator or arbitrators by
prescribing “ratcheting-up” procedures. For example, the
Interest Holders’ Agreement may provide that prior to the
controversy being submitted to “binding” arbitration in
accordance with, for example, the Commercial Arbitration
Rules of the American Arbitration Association, the parties will
be required to attempt in good faith to resolve the disputed
issue or issues by participating in a formal “non-binding”
mediation. Another type of arbitration provision provides, for
example, that the disputed matter or matters be arbitrated
before a single arbitrator who is a former or retired judge
who will decide the dispute pursuant to, for example, the
rules of the American Arbitration Association or pursuant to
some other specified arbitration rules and procedures. An
arbitration provision “with teeth” may also be added that
provides the arbitrator with the authority to award all counsel
fees (or a percentage thereof) to the prevailing party – for
example, an arbitrator may conclude that one party prevailed
to 70% (either based on the number of claims or materiality
of the claims) based on the allegations originally asserted by
the complainant, and thereby, the arbitrator would order the
non-prevailing party to pay 70% of the prevailing party’s
counsel fees, costs and expenses. This “with teeth” counsel
fee provision acts to deter a party from bringing a claim in
bad faith and may reduce the time and expenses involved in
resolving the dispute.
2. Provisional Director Provision - Day-to-Day
Management Disputes – In the context of a corporation,
if a “deadlock” occurs between, for example, two directors of
the corporation on any issue involving the “day-to-day”
management of the Corporation (or specified “Major
Business Decisions” [i.e., important decisions out of the
ordinary course of business]), the directors may elect, by
unanimous written consent, a provisional director
(“Provisional Director”) to vote on the deadlocked issue or
issues with the outcome of such deadlocked issue or issues
being determined by the directors by majority vote. Another
provision in this clause would include the procedure to be
followed in the event that the two directors cannot agree on
the Provisional Director.
3. The “Russian Roulette” Buy-out Provision in Deadlock
Situations – As an alternative dispute resolution in a
deadlock situation, a “buy-out” may be considered. This type
of provision usually deals with a deadlock of the Interest
Holders concerning a Major Business Decision. A deadlock
over a Major Business Decision may indicate that the Interest
Holders may have irreconcilable differences as to how the
enterprise is to be conducted and/or in what direction the
enterprise should proceed. Consider the following: Typically,
in a two-“Interest Holder” venture, a “Russian Roulette”
provision may be utilized, whereby either one of the Interest
Holders may begin a process which results in all of the
interests in the company being owned by only one of the
Interest Holders. The party initiating the process does not
know whether he or she will be the buyer or the seller. Other
provisions to this clause might provide that the buy-out
purchase price is fair market value.
For more information on buy-sell agreements, please contact
Bill Schmidt at
wschmidt@hertenburstein.com.
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