Bond Issue Planned for Tobacco Fees

Daniel Wise   

New York Law Journal   
April 22, 1999


   A group of 15 plaintiffs' attorneys for states involved   in the nationwide tobacco settlement are
exploring   floating a bond issue that would enable them to receive billions of dollars
immediately rather than   waiting 16 years or longer to receive the full   amount of their fees.

  The group has asked about 10 New York-based   investment banking firms to submit proposals
for   the issuance of bonds that would be backed by the   income stream generated by the fee
awards, confirmed Robert Lieff, one of the lawyers involved   in the effort.

  Legal experts said yesterday that they had never   heard of the use of bonds to telescope the
payment of lawyers' fees. Charles Wolfram, an   ethics professor at
Cornell Law School, said the
use of such an approach is "absolutely   unprecedented."

  Although no one has definitely committed to the   idea of securitizing the fee payments, there is
"wide interest" among plaintiffs' tobacco lawyers in the approach, said Mr. Lieff, of Lieff,
CabraserHeimann & Bernstein in
San Francisco.

  About 10 of the 15 lawyers actively pursuing the   bond approach were involved in the three
states --   Mississippi, Texas and Florida -- that settled   before last November's historic $206
billion   settlement with 46 states and five territories. The   settlement represented reimbursement
to the   states for the costs of treating Medicaid patients   for smoking-related illnesses. The 30
law firms that   represented those three states were collectively   awarded $8.2 billion in fees in
an arbitration that   was concluded in December.

  Lawyers from many other states that have yet to   go to arbitration are also interested in the
securitization approach, and the total amount   floated as a bond issue could swell to more than
double the $8.2 million awarded to date.

  The next state set to go to arbitration is   Massachusetts on June 16. Another 10 to 12   states
could receive arbitrated awards within the   next year, said Mr. Lieff, whose firm expects to be
involved in arbitrations in
Massachusetts,   Louisiana, California and Illinois.

   NEW YORK APPEAL   None of the three New York firms that represented   New York state
are involved in the bond effort   because the tobacco litigation here remains mired   in an appeal.
At issue in the appeal, to be heard in   the Appellate Division,
First Department, New York   City
is contending it was shortchanged by $2.3   billion in the projected distribution of
New York
state's $25 billion share of the settlement. Under   the November accord, law firms cannot
arbitrate   their claims until the settlement has been finalized   in their states.

  Two of the firms that have spearheaded the   litigation nationwide have been active in exploring
 the bond approach: Ness Motley Loadholt   Richardson & Poole, whose main office is in
Charleston, S.C., and Scruggs, Millette, Bozeman   & Dent of Pascagoula, Miss.

  Joseph Rice, of Ness Motley, said that after the   April 27 deadline for the investment banks to
submit their proposals, the firms will "consider   whether it is in our best interest to securtitize
any   or all of the attorneys fee awards."

  Not until specific proposals are submitted will the   lawyers know how steep a discount the
banks will   demand to allow the attorneys to receive their fee   awards up front, Mr. Lieff said.

   ADVANTAGES LISTED   In addition to accelerated payment, the bond issue   would also
permit the attorneys to avoid the risk   that any of the four tobacco companies signing the
agreement might file a bankruptcy petition and   become unable to honor the fee commitments.
The   four signatories are Phillip Morris, Lorillard   Tobacco, Brown & Williamson and R.J.
Reynolds.

  The use of bonds also offers a tax advantage.   Since the fee payments from the tobacco
companies will be used to pay off the bonds,   instead of compensating the attorneys directly,
they will not be taxed entirely as income. Instead,   in the early years, nearly all of the payments
will   be allocated to interest, rather than principal, and   not subject to income tax, Mr. Lieff
explained.

  Under the terms of the settlement, fee payments in   any one year by the four tobacco companies
is
   capped at $500 million. With $8.2 billion in fees   already committed, it will take the
companies at   least 16 years to pay off their current obligation.   Ultimately, it is considered
likely that the total   amount of fees approved by the arbitration panel   will exceed $15 billion,
leading to a payout period   of 30 years or more.

  Within the next month, Mr. Lieff said, interested   firms will set up a governance process for
deciding   whether to go ahead with a bond issue, and if so,   choose the banks that will handle it.

  Proposals have been solicited from at least 10   banks: Bear Sterns, Credit Suisse First Boston,
Goldman Sachs, Lazard Freres, Lehman Brothers,   Merrill Lynch, Morgan Stanley,
PaineWebber,   Salomon Smith Barney and Warburg Dillon Read.

  Because the total amount of fees that will be   allocated to a bond issue is uncertain, Mr. Lieff
said, the banks were asked to make proposals for   funding at various set levels so that their
approaches could be measured against each   other.

  Though the approach is novel, Professor Steven   Gillers, who teaches ethics at New York
University   School of Law, said he could see no legal   problems with it. "I don't see why [the
legal fees]   aren't a piece of property that can't be syndicated   like any other piece of property."

  See related article 



Cashing in on Tobacco

  N.Y.'s experiment with municipal   securitization piquing interest

  Torri Still    The Recorder/Cal Law    April 22, 1999

   Cities and counties across the country are eyeing   New York City's experiment with
securitizing its   share of the $206 billion nationwide tobacco   settlement as a potential model for
their own   settlement proceeds.

  The $625 million in bonds New York will sell over   the next four years will be backed by
tobacco   money it otherwise would be receiving over the   next 25 years. Securitizing the money
-- borrowing   against future cash flows -- allows the city to use   the proceeds much sooner.

  The move is being watched closely by other   municipalities -- some of which are already
securitizing other revenue sources to raise cash.   And to the handful of law firms that specialize
in   the complex deals, the increase in municipal   securitization is proving a boon.

  New York City has tapped two firms at the forefront   of the municipal securitization movement
to handle   its deal. Brown & Wood and Orrick, Herrington &   Sutcliffe will serve as
transactional counsel and   underwriters' counsel, respectively.

  In San Francisco, officials have not made a   decision about whether to securitize the estimated
$539 million their city will receive over the next 25   years as part of the tobacco settlement.

  "Tobacco money is such a new product for the   bond market that it's too risky for us to make
the   decision to securitize at this point," Deputy City   Attorney Marc Slavin said.

  "We're very interested in what happens with New   York City," Slavin added, "but that's not the
only   factor in our decision. The primary consideration is   minimizing the taxpayer burden."

  San Francisco has backed off using tobacco funds   to pay all of the cost of replacing Laguna
Honda   Hospital. Now, tobacco money will cover only a   portion of it, the city announced
Tuesday. Instead,   a $437 million bond measure to cover the   remainder will be put to voters in
November.

  In the meantime, city officials will ponder municipal   securitization, which is an offshoot of a
technique   long used by corporations to finance mortgages   and credit card receivables: selling
the revenue   streams to entities that assume the risk of the   potential bankruptcy of the revenue
source.

  The technique enables corporations to attain a   higher credit rating and lower their interest costs
--   not to mention avail themselves now of future   revenue.

  Securitizing tobacco settlements is appealing for   municipalities that want to avoid the 25-year
wait to   collect all of their money. Securitization also   mitigates the risk that, over the course of
25 years,   tobacco companies might go bankrupt and be   unable to pay up.

  On the other hand, the fact that municipalities   often have better bond ratings than tobacco
companies may discourage them from issuing   bonds backed by tobacco settlement money,
which would entail higher interest payments.

  "It becomes a question of what revenues the city or   county needs," San Francisco-based
partner Eric   Tashman, head of Brown & Wood's West Coast   finance group, explained. "Many
states will elect   not to securitize and instead use the money   coming in on an annual basis."

  Orrick and New York-based Brown & Wood are   among the few law firms that handle
municipal   securitization.

  "We're one of the few firms in the country that has   municipal and corporate finance expertise,
plus   expertise in securitization and tax law," Tashman   said. "You need an assortment of skills
under one   roof."

  Roger Davis, firmwide head of Orrick's public   finance department, agrees.

  "We're two major bond firms which coincidentally   have both public finance and structured
finance   departments," he said.

  As Davis, Tashman and other local attorneys await   California municipalities' decisions about
securitizing tobacco revenue, they are busy   working on other municipal securitization deals.
The practice of securitizing tax liens, i.e., selling   rights to the penalties accrued on delinquent
property tax payments, is a technique on the rise   among
California counties, Davis reports.
Orrick's  
California offices have been working on behalf of   Orange, Riverside and San Diego
counties on   delinquent tax lien deals.

  Brown & Wood has handled all of California's $6.2   billion of stranded cost bonds, which were
issued   to help utilities pay for costs that, following   deregulation, were unrecoverable. "Our
stranded   cost efforts have largely been based [in]
California,   and the first stranded cost
financing was done   here," Tashman explained. "We've since expanded   to other states."

  While the concept of municipal securitization is   "relatively new," Davis said, "municipalities
have   just scratched the surface. There is a lot they can   do in structuring their revenue and debt
operations   by borrowing this securitization concept and   securitizing various revenue streams."