In 2022 Schoenherr advised on two green bonds for financing
renewable energy projects in Bulgaria with foreign lenders
structured as alternative investment funds who may not extend
classic loans but may invest in corporate bonds. Apart from being a
suitable alternative to lenders who do not hold a banking licence,
these bonds represented a legal novelty in two respects.
Bonds drafting is cheaper compared to classic LMA credit
agreements
First, they were documented under Bulgarian law agreements that
were purportedly the first to fully follow the LMA model
Subscription Agreement for use in pan-European private placements
(LMA model). There are many domestic bonds formalities that need to
be reflected, but they do not change the LMA model's business
logic, as its main commercial terms may still be incorporated by
adopting a slightly different structure and wording.