As you know and have written on extensively, the ELA debt for IBRC was administered in 3 contractual arrangements between IBRC and Central Bank of Ireland, the Master Loan Repurchase Agreement (MLRA), Special Master Loan Repurchase Agreement (SMRA) and the Facility Deed (FD).
The organization is battling persistent, if thus far unsuccessful, legal attacks on the Master Settlement Agreement by smaller tobacco companies, who say it is an anticompetitive scheme that allowed the big manufacturers to raise prices indiscriminately.
The Master Settlement Agreement is a masterpiece of lawyerly tinkering with market economics, giving tobacco giants like Philip Morris protection from competition by requiring smaller companies to maintain their market share or face oppressive increases in their payments to the states.