Full opinion text
KING, Circuit Judge: Consolidated before us are three cases relating to the Mexican reorganization proceeding of Vitro S.A.B. de C.V., a corporation organized under the laws of Mexico. The Ad Hoc Group of Vitro Noteholders, a group of creditors holding a substantial amount of Vitro’s debt, appeal from the district court’s decision affirming the bankruptcy court’s recognition of the Mexican reorganization proceeding and Vitro’s appointed foreign representatives under Chapter 15 of the Bankruptcy Code. Vitro and one of its largest third-party creditors, Fintech Investments, Ltd., each appeals directly to this court the bankruptcy court’s decision denying enforcement of the Mexican reorganization plan because the plan would extinguish the obligations of non-debtor guarantors. For the following reasons, we affirm the district court’s judgment recognizing the Mexican reorganization proceeding and the appointment of the foreign representatives. We also affirm the bankruptcy court’s order denying enforcement of the Mexican reorganization plan. I. FACTUAL AND PROCEDURAL BACKGROUND A. Vitro S.A.B. de C.V. and the 2008 Financial Crisis Vitro S.A.B. de C.V. (“Vitro”) is a holding company that, together with its subsidiaries, constitutes the largest glass manufacturer in Mexico. Originally incorporated in 1909, Vitro operates manufacturing facilities in seven countries, as well as distribution centers throughout the Americas and Europe, and exports its products to more than 50 countries worldwide. Vitro employs approximately 17,000 workers, the majority of whom work in Mexico. Between February 2003 and February 2007, Vitro borrowed a total of approximately $1.216 billion, predominately from United States investors. Vitro’s indebtedness is evidenced by three series of unsecured notes. The first series was issued on October 22, 2003 and consisted of $225 million aggregate principal amount of 11.75% notes due 2013; the second and third series were issued on February 1, 2007, and consisted of $300 million of 8.625% notes due 2012 and $700 million of 9.125% notes due 2017 (collectively the “Old Notes”). Payment in full of the Old Notes was guaranteed by substantially all of Vitro’s subsidiaries (the “Guarantors”). The guaranties provide that the obligations of the Guarantors will not be released, discharged, or otherwise affected by any settlement or release as a result of any insolvency, reorganization, or bankruptcy proceeding affecting Vitro. The guaranties further provide that they are to be governed and construed under New York law and include the Guarantors’ consent to litigate any disputes in New York state courts. The guaranties state that “any rights and privileges that [Guarantors] might otherwise have under the laws of Mexico shall not be applicable to th[e] Guarantees].” In the latter half of 2008, Vitro’s fortunes took a turn for the worse when the global financial crisis significantly reduced demand for its products. Vitro’s operating income declined by 36.8% from 2007 to 2008, and an additional 22.3% from 2008 to 2009, In February of 2009, Vitro announced its intention to restructure its debt and stopped making scheduled interest payments on the Old Notes. B. Vitro Restructures Its Obligations After Vitro stopped making payments on the Old Notes, it entered into a series of transactions restructuring its debt obligations. On December 15, 2009, Vitro entered into a sale leaseback transaction with Fintech Investments Ltd. (“Fintech”), one of its largest third-party creditors, holding approximately $600 million in claims (including $400 million in Old Notes). Under the terms of this agreement, Fintech paid $75 million in exchange for the creation, in its favor, of a Mexican trust composed of real estate contributed by Vitro’s subsidiaries. This real estate was then leased to one of Vitro’s subsidiaries to continue normal operations. The agreement also gave Fintech the right to acquire 24% of Vitro’s outstanding capital or shares of a sub-holding company owned by Vitro in exchange for transferring Fintech’s interest in the trust back to Vitro or its subsidiaries. Partly as a result of these transactions, Vitro generated a large quantity of inter-company debt. Previously, certain of Vitro’s operating subsidiaries directly and indirectly owed Vitro an aggregate of approximately $1.2 billion in intercompany debt. As a result of a series of financial transactions in December of 2009, that debt was wiped out and, in a reversal of roles, Vitro’s subsidiaries became creditors to which Vitro owed an aggregate of approximately $1.5 billion in intercompany debt. Despite requests by holders of Old Notes, Vitro did not disclose these transactions. In August of 2010, Fintech purchased claims by five banks holding claims against Vitro and its subsidiaries and extended the maturity of various promissory notes issued by Vitro’s subsidiaries. Pursuant to a “Lock-up Agreement” completed between Fintech and Vitro, Fintech also agreed not to transfer any debt it held in Vitro unless such transfer was in line with the terms of that agreement. Only in October of 2010, approximately 300 days after completing the transactions with its subsidiaries, did Vitro disclose the existence of the subsidiary creditors. This took the transactions outside Mexico’s 270-day “suspicion period,” during which such transactions would be subject to additional scrutiny before a business enters bankruptcy. C. Vitro Commences a Concurso Proceeding in Mexican Court Between August 2009 and July 2010, Vitro engaged in negotiations with its creditors and submitted three proposals for reorganization. Each was rejected by creditors. After the last proposal, the Ad Hoc Group of Vitro Noteholders (the “Noteholders”), a group of creditors holding approximately 60% of the Old Notes, issued a press release “strongly recommending]” that all holders of the Old Notes deny consent to any reorganization plan that the Noteholders had not approved. On November 1, 2010, Vitro disclosed its intention to commence a voluntary reorganization proceeding in Mexico, together with a pre-packaged plan of reorganization. On December 13, 2010, Vitro initiated in a Mexican court a concurso proceeding under the Mexican Business Reorganization Act, or Ley de Concursos Mercantiles (“LCM”). The Mexican court initially rejected Vitro’s filing on January 7, 2011, because Vitro could not reach the 40% creditor approval threshold necessary to file a concurso petition without relying on intercompany claims held by its subsidiaries. On April 8, 2011, that decision was overruled on appeal and Vitro was then declared to be in bankruptcy, or concurso mercantil. Pursuant to Mexican law, Javier Luis Navarro Velasco was appointed as conciliador. The conciliador was tasked with filing an initial list of recognized claims and mediating the creation of a reorganization plan. The conciliador did so, and on August 5, 2011, filed a proposed final list of recognized creditors, which included those subsidiaries holding intercompany debt. The conciliador then negotiated terms of a reorganization plan between Vitro and the recognized creditors to submit to the Mexican court for approval. Throughout this process, the parties were apparently in frequent contact with the Mexican court on an ex parte basis. 1. Terms of the Concurso Plan On December 5, 2011 the conciliador submitted to the Mexican court a proposed restructuring plan (the “Concurso plan” or “Plan”) substantially identical to the one Vitro had originally proposed. Under the terms of the Plan, the Old Notes would be extinguished and the obligations owed by the Guarantors would be discharged. Specifically, the Plan provides that: [0]nce this Agreement is approved by the Court ... this Agreement ... will substitute, pay, replace and terminate the above obligations, instruments, securities, agreements and warranties in which were agreed upon Approved Credits and, therefore ... will terminate personal guarantees granted a third and/or direct and indirect subsidiaries [sic] of Vitro with regards to the obligations, instruments, securities and agreements that gave rise to the Approved Credits. The Plan further provides that Vitro would issue new notes payable in 2019 (the “New 2019 Notes”), with a total principal amount of $814,650,000. The New 2019 Notes would be issued to Vitro’s third-party creditors (not including those subsidiaries holding intercompany debt, who would forgo their pro rata share of the Plan’s consideration and instead receive other promissory notes). The New 2019 Notes would bear a fixed annual interest rate of 8.0%, but would “not have ... payments of principal during the first 4 (years) years [sic] ... and from the fifth year of operation and until the seventh year ... will have repayments or payments of [a] total principal amount of $23,960,000.00 USD ... payable semiannually on June 30 and December 31 of each year and the remaining balance upon due date.” The New 2019 Notes would also “be unconditionally and supportively guaranteed for each of the Guarantors.” Payment under the New 2019 Notes would go into a third-party payment trust, which would deliver payment to those creditors who had consented to the Plan. A second trust would be created to pay non-consenting creditors upon their written agreement to the terms of the Plan. In addition to the New 2019 Notes, Vitro would also provide to the holders of the Old Notes $95,840,000 aggregate principal amount of new mandatory convertible debt obligations (“MCDs”) due in 2015 with an interest rate of 12%, convertible into 20% equity in Vitro if not paid at full maturity. Finally, the Plan also provided cash consideration of approximately $50 per $1000 of principal of Old Notes. 2. The Concurso Plan is Approved Under Mexican law, approval of a reorganization plan requires votes by creditors holding at least 50% in aggregate principal amount of unsecured debt. As distinguished from United States law, Mexico does not divide unsecured creditors into interest-aligned classes, but instead counts the votes of all unsecured creditors, including insiders, as a single class. As a result, although creditors holding 74.67% in aggregate principal amount of recognized claims voted in favor of the plan, over 50% of all voting claims were held by Vitro’s subsidiaries in the form of intercompany debt. The 50% approval threshold could not have been met without the subsidiaries’ votes. After the initial approval, the LCM provides a period during which objecting creditors can veto the plan. A veto requires agreement by recognized creditors holding a minimum of 50% in aggregate principal amount of debt or by recognized creditors numbering at least 50% of all unsecured creditors. As only 26 of the 886 recognized creditors sought to veto the Concurso plan, and as those creditors held less than 50% of the aggregate recognized debt, the veto failed. The Mexican court approved the Concurso plan on February 3, 2012. On February 23, 2012, the Plan went into effect, and Vitro issued New 2019 Notes and MCDs and paid restructuring cash into two third-party payment trusts, one for consenting creditors and the other for non-consenting creditors. The Concurso plan approval order has been appealed, and such appeal has been accepted by, and is currently pending in, the Mexican judicial appellate system; no stay of effectiveness of the Concurso plan was entered. D. Objecting Creditors Resist Enforcement While objecting to the concurso proceeding in Mexico, creditors dissatisfied with Vitro’s reorganization efforts attempted to collect on the Old Notes and guaranties in a variety of ways. By April 2010, Vitro had received acceleration notices for all the Old Notes. On November 17, 2010, involuntary Chapter 11 petitions were filed against fifteen Guarantors domiciled in the United States. Various holders of Old Notes also commenced two substantially identical lawsuits in New York state court against Vitro and 49 Guarantors, resulting in orders of attachment with respect to any property located in New York. Parallel to the concurso proceeding, in August 2011, Wilmington Trust, National Association (“Wilmington”), the indenture trastee for the Old Notes due in 2012 and 2017, filed suit in New York state court against various of the Guarantors, seeking a declaratory judgment confirming the Guarantors’. obligations under the related indentures. The state court granted partial summary judgment in Wilmington’s favor on December 5, 2011. The court held that New York law applied to the dispute and that under the unambiguous terms of the relevant Old Notes, “any non-consensual release, discharge or modification of the obligations of the Guarantors ... is prohibited.” Wilmington Trust v. Vitro Automotriz, S.A. De C.V., 33 Misc.3d 1231, 943 N.Y.S.2d 795 (table), 2011 WL 6141025, at *6 (N.Y.Sup.Ct. Dec. 5, 2011). The court went on to find, however, that “whether such prohibitive provisions may be modified or eliminated by applicable Mexican laws is not at issue here.” Id. at *5. A separate suit brought by U.S. Bank National Association (“U.S. Bank”), the indenture trustee for the Old Notes due in 2013, achieved the same outcome. E. Vitro Commences a Chapter 15 Proceeding in the United States On October 29, 2010, Vitro’s Board of Directors appointed Alejandro SanchezMujica to act as Vitro’s foreign representative. On April 14, 2011, Sanchez-Mujica commenced a Chapter 15 proceeding in United States bankruptcy court by filing a petition for recognition of the Mexican concurso proceeding. The petition was originally filed in the United States Bankruptcy Court for the Southern District of New York, but, on May 13, 2011, by motion of objecting creditors, venue was transferred to the United States Bankruptcy Court for the Northern District of Texas. Because Sanchez-Mujica could not leave Mexico — a result of certain travel restrictions imposed by the Mexican court because of his role in Vitro’s restructuring — Vitro filed a supplemental petition to recognize Javier Arechavaleta-Santos, another appointee of Vitro’s Board of Directors, as “co-foreign representative.” The bankruptcy court, over objections, held that the Mexican reorganization proceeding was a “foreign main proceeding” and approved the petition confirming Sanchez-Mujica and Arechavaleta-Santos as foreign representatives pursuant to 11 U.S.C. § 1515 and § 1517. The United States District Court for the Northern District of Texas affirmed the bankruptcy court’s order. In re Vitro, S.A.B. de C.V., 470 B.R. 408 (N.D.Tex.2012) (Vitro I). That decision has been appealed, Case No. 12-10542, and is one of the cases consolidated in this appeal. On March 2, 2012, Vitro’s foreign representatives filed a motion in bankruptcy court entitled “Motion of Foreign Representatives of Vitro S.A.B. de C.V. for an Order Pursuant to 11 U.S.C. §§ 105(a), 1507 and 1521 to (I) Enforce the Mexican Plan of Reorganization of Vitro S.A.B. de C.V., (II) Grant a Permanent Injunction, and (III) Grant Related Relief’ (the “Enforcement Motion”). The Noteholders, Wilmington, and U.S. Bank (collectively, the “Objecting Creditors”) objected, and the matter proceeded to trial on June 4, 2012. Following a four-day trial, in which hundreds of exhibits were presented and several witnesses testified, the bankruptcy court denied the Enforcement Motion. In re Vitro, S.A.B. de C.V., 473 B.R. 117 (Bankr.N.D.Tex.2012) (Vitro II). As part of that ruling, the court also denied Vitro’s motion to enjoin the Objecting Creditors from initiating litigation against the Guarantors. To permit Vitro time to appeal, the bankruptcy court did, however, extend a previously issued temporary restraining order. Vitro and Fintech have appealed the bankruptcy court’s decision, which has been certified for direct appeal, and Case Nos. 12-10689 (Vitro’s appeal) and 12-10750 (Fintech’s appeal) were subsequently consolidated with the other case before us. Vitro subsequently sought, and was granted on June 28, 2012, an order by this court staying the expiration of the bankruptcy court’s temporary restraining order. II. STANDARD OF REVIEW We review a district court’s affirmance of a bankruptcy court’s decision by applying the same standard of review that the district court applied. In re Martinez, 564 F.3d 719, 725-26 (5th Cir.2009). Accordingly, questions of fact are reviewed for clear error and conclusions of law are reviewed de novo. Id. at 726. Mixed questions of law and fact are reviewed de novo. In re McLain, 516 F.3d 301, 307 (5th Cir.2008). We review a bankruptcy court’s decision on direct appeal under the same standards. By contrast, “[w]e review a denial of declaratory or injunctive relief for abuse of discretion.” In re Schimmelpenninck, 183 F.3d 347, 353 (5th Cir.1999). A court’s decision to grant comity is also reviewed for abuse of discretion. Int’l Transactions, Ltd. v. Embotelladora Agral Regiomontana, SA de CV, 347 F.3d 589, 593 (5th Cir.2003) (applying abuse of discretion standard to review district court’s grant of comity to Mexican bankruptcy court’s ex parte order); see also In re Qimonda AG Bankr. Litig., 433 B.R. 547, 556 (E.D.Va.2010). III. CHAPTER 15 The dispute before us arises under Chapter 15 of the Bankruptcy Code and broadly involves two issues: recognition of the foreign representatives and enforcement of the Concurso plan. As to the first, on April 14, 2011, Sanchez-Mujica and Arechavaleta-Santos, as co-foreign representatives, filed a petition seeking recognition of the concurso proceeding under Chapter 15. The Noteholders objected that Sanchez-Mujica and ArechavaletaSantos were not properly appointed as foreign representatives because they were not appointed by the Mexican court and because Vitro did not have the powers of a debtor in possession. The bankruptcy court granted recognition of the concurso proceeding as a foreign main proceeding under 11 U.S.C. § 1517. On appeal, the district court affirmed, holding that it was sufficient that Sanchez-Mujica and Arechavaleta-Santos were authorized as co-foreign representatives in the context of a foreign' bankruptcy proceeding and that Vitro retained sufficient control over its business to be á debtor in possession. The Noteholders appeal, raising substantially the same arguments before us that they raised in the lower courts. Because recognition of a proceeding under) Chapter 15 is a precondition for the more substantive relief Vitro seeks in the Enforcement Motion, we will resolve the recognition issue first. We hold that the bankruptcy court and the district court correctly interpreted Chapter 15 as not requiring official court appointment. We further find that the term “foreign representatives” was intended to include debtors in possession, including those that may not meet Chapter ll’s definition of debtors in possession, and that Vitro retained enough authority over its affairs to be a debtor in possession and could thus appoint Sanchez-Mujica and ArechavaletaSantos as foreign representatives. Accordingly, we affirm the district court’s ruling affirming the bankruptcy court’s order. We then address the Enforcement Motion. On March 2, 2012, Vitro’s co-foreign representatives filed a motion seeking “to 1) give full force and effect in the United States to the Concurso Approval Order, 2) grant a permanent injunction prohibiting certain actions in the United States against Vitro SAB, as well as its non-debtor subsidiaries, and 3) grant certain related relief.” Vitro II, 473 B.R. at 120-21 (quotation marks omitted). The bankruptcy court denied relief under 11 U.S.C. §§ 1507, 1521, and 1506 because approval of the Plan would extinguish claims held by the Objecting Creditors against the subsidiaries. Id. at 131. Vitro and Fin-tech appeal this decision solely on the issue of whether the bankruptcy court erred as a matter of law in refusing to enforce the Concurso plan because the Plan novated guaranty obligations of non-debtor parties. While the relief available under Chapter 15 may, in exceptional circumstances, include enforcing a foreign court’s order extinguishing the obligations of non-debtor guarantors, Vitro has failed to demonstrate that comparable circumstances were present here. Because Vitro has not done so, we affirm the bankruptcy court’s decision denying the Enforcement Motion. A. Chapter 15 of the United States Bankruptcy Code This case concerns a foreign bankruptcy proceeding for which recognition and enforcement are sought under Chapter 15 of the United States Bankruptcy Code. Chapter 15 was enacted in 2005 to implement the Model Law on Cross-Border Insolvency (“Model Law”) formulated by the United Nations Commission on International Trade Law (“UNCITRAL”), and replaced former 11 U.S.C. § 304. See In re Ran, 607 F.3d at 1020; In re Iida, 377 B.R. 243, 256 (B.A.P. 9th Cir.2007). It was intended “to provide effective mechanisms for dealing with cases of cross-border insolvency,” 11 U.S.C. § 1501(a), as well as to be “the exclusive door to ancillary assistance to foreign proceedings,” thus “concentrating] control of these questions in one court.” H.R.Rep. No. 109-31, pt. 1, at 110 (2005), reprinted in 2005 U.S.C.C.A.N. 88, 178. It was also intended to increase legal certainty, promote fairness and efficiency, protect and maximize value, and facilitate the rescue of financially troubled businesses. 11 U.S.C. § 1501(a). Central to Chapter 15 is comity. Comity is the “recognition which one nation allows within its territory to the legislative, executive or judicial acts of another nation, having due regard both to international duty and convenience, and to the rights of its own citizens, or of other persons who are under the protections of its laws.” Hilton v. Guyot, 159 U.S. 113, 164, 16 S.Ct. 139, 40 L.Ed. 95 (1895). “It is not a rule of law, but one of practice, convenience, and expediency.” Overseas Inns S.A. P.A. v. United States, 911 F.2d 1146, 1148 (5th Cir.1990) (quotation marks and citation omitted). Within the context of Chapter 15, however, it is raised to a principal objective. Section 1501(a) begins by listing, as one of Chapter 15’s goals, the furtherance of cooperation between domestic and foreign courts in cross-border insolvency cases. Section 1508 goes on to provide that Chapter 15’s provisions shall be interpreted.by considering “its international origin, and the need to promote an application of this chapter that is consistent with the application of similar statutes adopted by foreign jurisdictions.” 11 U.S.C. § 1508. Comity considerations are explicitly included in the introduction to § 1507, and § 1509(b)(3) further provides that our courts “shall grant comity or cooperation to the foreign representative” of a foreign proceeding. Such a foreign representative must first petition a United States bankruptcy court for recognition of a foreign proceeding. 11 U.S.C. §§ 1504, 1515. Chapter 15 defines such a foreign proceeding as: [A] collective judicial or administrative proceeding in a foreign country, including an interim proceeding, under a law relating to insolvency or adjustment of debt in which proceeding the assets and affairs of the debtor are subject to control or supervision by a foreign court, for the purpose of reorganization or liquidation. 11 U.S.C. § 101(23). Only after a United States court recognizes a proceeding can “the foreign representative ... apply directly to a court in the United States for appropriate relief in that court.” 11 U.S.C. § 1509(b)(2); see also United States v. J.A. Jones Constr. Grp., LLC, 333 B.R. 637, 638 (E.D.N.Y.2005). Chapter 15 provides for a broad range of relief. This includes the ability to sue and be sued in United States courts, to apply directly to a United States court for relief, to commence a non-Chapter 15 case, and to intervene in any United States case to which the debtor is a party. In re Condor Ins. Ltd., 601 F.3d 319, 324 (5th Cir.2010). Section 1520 also provides for certain automatic relief upon recognition of a foreign main proceeding, like the one here, including an automatic stay and the power to prevent transfers of the debtor’s property. A bankruptcy court is also empowered under § 1521(a) to “grant any appropriate relief’ necessary to “effectuate the purpose of this chapter and to protect the assets of the debtor or the interests of the creditors.” Finally, § 1507(a) gives a court authority to provide “additional assistance,” subject to certain restrictions imposed by Chapter 15 and § 1507(b). In considering whether to grant relief, it is not necessary that the result achieved in the foreign bankruptcy proceeding be identical to that which would be had in the United States. It is sufficient if the result is “comparable.” In re Schimmelpenninck, 183 F.3d at 364; Overseas Inns, 911 F.2d at 1149; see also In re Sivec SRL, 476 B.R. 310, 324 (Bankr.E.D.Okla.2012) (“The fact that priority rules and treatment of claims may not be identical is insufficient to deny a request for comity.”); In re Qimonda AG, 462 B.R. 165, 184 n. 17 (Bankr.E.D.Va.2011); In re Petition of Garcia Avila, 296 B.R. 95, 112 (Bankr.S.D.N.Y.2003). “[T]he foreign laws need not be identical to their counterparts under the laws of the United States; they merely must not be repugnant to our laws and policies.” In re Schimmelpenninck, 183 F.3d at 365. But as discussed, whether any relief under Chapter 15 will be granted is a separate question from whether a foreign proceeding will be recognized by a United States bankruptcy court. The consolidated cases before us arise from decisions addressing each of these issues. We first turn to whether Vitro’s co-foreign representatives were properly recognized. B. Recognition of Foreign Representatives After initiation of a foreign bankruptcy proceeding, a “foreign representative” may petition a United States court to recognize the proceeding under Chapter 15. Chapter 15 defines a “foreign representative” as “a person or body, including a person or body appointed on an interim basis, authorized in a foreign proceeding to administer the reorganization or the liquidation of the debtor’s assets or affairs or to act as a representative of such foreign proceeding.” 11 U.S.C. § 101(24). “A federal court’s recognition of representatives appointed in the course of a foreign bankruptcy or liquidation proceeding is a matter of comity — it is an acknowledgment of the validity of the foreign proceeding.” Reserve Int’l Liquidity Fund, Ltd. v. Caxton Int’l Ltd., No. 09 Civ. 9021(PGG), 2010 WL 1779282, at *5 (S.D.N.Y. Apr. 29, 2010) (citing Finanz AG Zurich v. Banco Economico S.A., 192 F.3d 240, 246 (2d Cir.1999)). A duly recognized foreign representative has the capacity to sue and be sued in the United States and to apply directly to a United States court for relief, and a foreign representative is entitled to the comity and cooperation of all United States courts. 11 U.S.C. § 1509. Three requirements, contained in § 1517, must be met before a foreign proceeding will be recognized: (a)Subject to section 1506, after notice and a hearing, an order recognizing a foreign proceeding shall be entered if— (1) such foreign proceeding for which recognition is sought is a foreign main proceeding or foreign nonmain proceeding within the meaning of section 1502; (2) the foreign representative applying for recognition is a person or body; and (3) the petition meets the requirements of section 1515. 11 U.S.C. § 1517. Section 1515, in turn, provides the following procedural requirements: (a) A foreign representative applies to the court for recognition of a foreign proceeding in which the foreign representative has been appointed by filing a petition for recognition. (b) A petition for recognition shall be accompanied by— (1) a certified copy of the decision commencing such foreign proceeding and appointing the foreign representative; (2) a certificate from the foreign court affirming the existence of such foreign proceeding and of the appointment of the foreign representative; or (3) in the absence of evidence referred to in paragraphs (1) and (2), any other evidence acceptable to the court of the existence of such foreign proceeding and of the appointment of the foreign representative. (c) A petition for recognition shall also be accompanied by a statement identifying all foreign proceedings with respect to the debtor that are known to the foreign representative. (d) The documents referred to in paragraphs (1) and (2) of subsection (b) shall be translated into English. The court may require a translation into English of additional documents. 11 U.S.C. § 1515. These requirements are to be strictly construed in line with our holding that the requisite analysis is not a “rubber stamp exercise,” and that “[e]ven in the absence of an objection, courts must undertake their own jurisdictional analysis and grant or deny recognition under Chapter 15 as the facts of each case warrant.” In re Ran, 607 F.3d at 1021. Neither Sanchez-Mujica nor Arechavaleta-Santos, the recognized foreign representatives in this case, was appointed by a foreign court or tribunal. Both were voted into them positions by Vitro’s Board of Directors. The bankruptcy court recognized the concurso proceeding under Chapter 15 and the district court affirmed, holding that whether a given individual could act as a foreign representative was a matter of United States law, and that it was unnecessary for a foreign representative to be appointed by a court. The court’s holding rested on its analysis of § 101(24)’s language and cases applying that subsection, which showed that it was sufficient for a foreign representative to be authorized in the context of a foreign bankruptcy proceeding. Vitro I, 470 B.R. at 411-13. The district court further determined that Vitro was the Mexican equivalent of a “debtor in possession,” able to administer its own reorganization, and was thus able to appoint a foreign representative under Chapter 15. Id. at 412. On appeal, the Noteholders argue that the individuals appointed here do not satisfy Chapter 15’s definition of “foreign representatives” for two reasons. First, neither was “authorized in a foreign proceeding,” because neither was appointed by a foreign court or administrative tribunal. 11 U.S.C. § 101(24). In support, the Noteholders rely on § 101(23)’s definition of “foreign proceeding,” as well as 11 U.S.C. §§ 1515(a), 1515(b)(l)-(2), and 1509(b)(2). Second, the Noteholders argue that even if Chapter 15 did not require such an appointment, the foreign representatives still did not qualify for their positions because they did not have the authority “to administer the reorganization or the liquidation of the debtor’s assets or affairs or to act as a representative of such foreign proceeding.” 11 U.S.C. § 101(24). Vitro responds that the plain language of § 101(24) does not require court appointment and that this conclusion is support by both Chapter 15’s legislative history and UNCITRAL’s Model Law. Vitro further argues that § 101(24) was intended to apply to a “debtor in possession,” like Vitro, and thus it had the power to appoint individuals as foreign representatives of the concurso proceeding. Because the district court correctly interpreted § 101(24), defining foreign representatives as having been appointed in the context of a foreign proceeding, and because Vitro, as a debtor in possession, met the requirements of that subsection, we affirm the district court’s decision. We address each of these points in turn. 1. Authorized in a Foreign Proceeding The Noteholders point to numerous parts of Chapter 15 that allegedly show that a foreign court must explicitly authorize individuals or bodies to act as representatives. Contrary to the Note-holders’ interpretation, we do not find that any of Chapter 15’s provisions requires action by a foreign tribunal. We interpret statutes according to their plain meaning. Gaddis v. United States, 381 F.3d 444, 472 (5th Cir.2004). Section 101(24) — defining the term “foreign representative” — is wholly devoid of any statement that a foreign representative must be judicially appointed. The definition’s requirement that a representative be “authorized in a foreign proceeding” is certainly compatible with appointment by a foreign court, but it is hardly necessary. As the district court observed, it would be equally compatible with a requirement that an individual be appointed “in the context of’ a foreign proceeding. Vitro I, 470 B.R. at 411. It could also mean during, or in the course of, a foreign proceeding. The other provisions the Noteholders identify suffer from the same defect. Section 1515(a) provides that “[a] foreign representative applies to the court for recognition of a foreign proceeding in which the foreign representative has been appointed” and requires that a petition for recognition be accompanied by either, 1) “a certified copy of the decision commencing such foreign proceeding and appointing the foreign representative,” 2) “a certificate from the foreign court affirming the existence of such foreign proceeding and of the appointment of the foreign representative,” or 3) other evidence “of such foreign proceeding and of the appointment of the foreign representative.” 11 U.S.C. § 1515. None of these provisions states who has the official authority to appoint a foreign representative. At best, they provide the context in which a foreign representative should be appointed. By comparison, § 1509(b)(2) states that if a court grants recognition to a foreign proceeding, it shall grant “comity or cooperation” to the foreign representative. Although use of the word “comity” connotes recognition of another judicial proceeding, the word “cooperation” suggests a much broader meaning. Caselaw supports our interpretation. To be sure, foreign representatives have been appointed by foreign tribunals in many cases. One such ease was In re Grand Prix Associates, Inc., where the court specifically held that § 1517(a) was satisfied where the purported foreign representative was able to present an order by the foreign court appointing it as the foreign representative of the business entities in question. No. 09-16545(DHS), 2009 WL 1410519, at *5 (Bankr.D.NJ. May 18, 2009); see also In re Innua Canada Ltd., No. 09-16362(DHS), 2009 WL 1025090, at *4-5 (Bankr.D.N.J. Apr. 15, 2009) (receivership order entered by Canadian court stated foreign representative had capacity to commence Chapter 15 proceeding); In re Oversight, 385 B.R. at 534 (Spanish insolvency court had power to appoint foreign representative for Chapter 15 purposes); In re Basis Yield Alpha Fund (Master), 381 B.R. 37, 46 n. 30 (Bankr.S.D.N.Y.2008); In re Tri-Cont’l Exch. Ltd., 349 B.R. 627, 632 (Bankr.E.D.Cal.2006). But the district court identified numerous cases cited by the bankruptcy court that, although not binding, demonstrate that recognition is routinely granted to petitioners appointed by Mexican debtors to serve as foreign representatives. Vitro I, 470 B.R. at 412 (listing cases). The Mexican court’s actions make it equally apparent that Sanchez-Mujica and Arechavaleta-Santos were properly appointed. It is undisputed that the Mexican court had the power to enjoin SanchezMujica and Arechavaleta-Santos from acting as foreign representatives. Yet, when presented with a motion requesting such an order, the Mexican court denied it in full. The Mexican court also refused to declare the conciliador to be the only person authorized to act as foreign representative. In deciding not to enjoin the foreign representatives’ conduct, the Mexican court gave the representatives its tacit approval. Finally, our decision is informed by consideration of the Model Law, and reports by the UNCITRAL Working Group on Insolvency Law (“Working Group”). 11 U.S.C. § 1501(a) (purpose of Chapter 15 is to incorporate the Model Law); see also In re Tri-Cont’l Exch. Ltd., 349 B.R. at 633 (treating as persuasive authority the Guide to Enactment of the UNCITRAL Model Law on Cross-Border Insolvency); In re Condor, 601 F.3d at 326-27 & nn. 37-40 (discussing and citing Working Group). The definition of foreign representatives in § 101(24) closely follows the language of Model Law Article 2(d). In drafting this definition, the Working Group expressly rejected the requirement that a foreign representative be “[specifically] authorized by statute or other order of court (administrative body) to act in connection with a foreign proceeding.” UNCITRAL Rep. of the Working Group on Insolvency Law on the Work of the Eighteenth Session, ¶ 111, U.N. Doc. A/CN.9/419 (Dec. 1, 1995), available at http://www.uncitral.org/ uncitral/en/commission/working_groups/5 Insolvency.html (Dec. 1995 Rep.) (alteration in original). That definition was rejected because of concerns that “the expressions would be unfamiliar and might have the unintended effect of being unduly restrictive, since the list would inevitably be incomplete.” Id. ¶ 112. The Working Group also declined to include the word “specifically” because “it would be unusual for a State to appoint an insolvency representative specifically to act abroad.” Id. ¶ 113. This supports our conclusion that the Noteholders’ proposed interpretation — -which would require exactly such an appointment — is wrong. Accordingly, we conclude that SanchezMujica and Arechavaleta-Santos are not disqualified from serving as foreign representatives merely because they were not the subject of an official court appointment. 2. Power to Administer the Reorganization or Liquidation of a Debt- or’s Assets or Affairs Having determined that Chapter 15 does not require a foreign representative to be appointed by court order, we still must address whether Sanchez-Mujica’s and Arechavaleta-Santos’ appointments comport with the remainder of § 101(24). In particular, § 101(24) requires that a foreign representative have the authority “to administer the reorganization or the liquidation of .the debtor’s assets or affairs or to act as a representative of such foreign proceeding.” 11 U.S.C. § 101(24). Vitro does not argue that Sanchez-Mujica and ArechavaletaSantos have the authority to represent the concurso proceeding, and we therefore do not address that prong of § 101(24). The only remaining question is whether they had administrative power over the reorganization of Vitro’s business. The district court held that Vitro could appoint its own foreign representatives because, under Mexican law, a debtor continues to manage its business during a concurso proceeding, making it akin to a “debtor in possession.” Vitro I, 470 B.R. at 412. The Working Group clearly intended to include foreign representatives of proceedings in which a debtor in possession remains in control of its assets. Dec. 1995 Rep. ¶ 115. The National Bankruptcy Review Commission, created by Congress in 1994 to make recommendations on improving bankruptcy law and procedure, in its review of the Model Law, reached the same conclusion. Nat’l Bankr.Rev. Comm’n, Bankruptcy: The Next Twenty Years, Nat’l Bankr. Rev. Comm’n Final Rep., (1997), available at http://govinfo. library.unt.edu/nbrc/reportcont.html (Nat’l Bankr. Comm’n). The Noteholders, however, challenge whether Vitro can be classified as a debtor in possession, and argue that such power is reserved for the conciliador in a concurso proceeding. The Noteholders also point out that under Chapter 11, a debtor in possession has the rights, powers, and duties of a Chapter 11 trustee, which include the right to negotiate, file, and seek confirmation of a plan of reorganization, and that Vitro lacked this authority. The Noteholders’ argument fails for relying exclusively on Chapter ll’s definition of a debtor in possession. The Working Group’s decision to include debtors in possession was not made on the basis of how United States law defined the term. Rather, the Working Group understood debtors in possession to include those cases “in which the debtor remained in control of its assets and could technically be regarded as exercising administration type of functions, although under the supervision of a judicial or administrative authority.” Dec. 1995 Rep. ¶ 115. The UNCITRAL Practice Guide on Cross-Border Insolvency Cooperation similarly defines debtor in possession to mean “a debtor in reorganization proceedings, which retains full control over the business, with the consequence that the court does not appoint an insolvency representative.” UNCITRAL, Practice Guide on Cross-Border Insolvency Cooperation 5 (July 1, 2009), available at http://www. uncitral.org/pdf/english/texts/insolven/ Practice_Guide_Ebook_eng.pdf. At least one court has understood foreign representatives to include debtors in possession, including those in “debtor-in-possession reorganization proceedings in Latin American countries.” In re Cenargo Int’l, PLC, 294 B.R. 571, 598 n. 31 (Bankr.S.D.N.Y.2003) (internal quotation marks and citation omitted). We likewise hold that under Chapter 15 the correct analogy is not to whether a debtor meets Chapter ll’s definition of a “debtor in possession,” but whether it meets that definition originally envisioned by the drafters of the Model Law and incorporated into § 101(24). See 11 U.S.C. § 1508 (Chapter 15 to be interpreted by consideration of its international origin, and consistent with application of similar foreign statutes); Nat’l Bankr. Comm’n, supra, at 357 (definitions in Model Law are “carefully constructed to include the United States Chapter 11 proceeding (and similar debtor in possession reorganization proceedings in Latin America and elsewhere)”). Here, there is little doubt that Vitro met that definition. Vitro has presented extensive evidence that it retained broad control over its affairs, pursuant to various provisions of the LCM. See Ley de Concursos Mercantiles [LCM] [Bankruptcy Law], Diario Oficial de la Federación [DO], as amended, 12 de mayo de 2000, art. 74 (debtor will be entrusted with enterprise’s management throughout conciliation stage unless court grants conciliador’s request to remove debtor to protect the estate); id. art. 84 (debtor retains ability to litigate pending claims under conciliador’s supervision). Commentary on the LCM agrees that a board of directors generally remains in control and possession of its business during a concurso proceeding. See Jonathan Graham-Canedo, Comparative Analysis of Bankruptcy Legal Provisions from Mexico and the United States: Which Legal System is More Attractive?, 6 DePaul Bus. & Com. L.J. 19, 27 (Fall 2007). We further observe that if Vitro were not permitted to proceed as a debtor in possession, with the power to appoint foreign representatives, it is unclear who would. Any other potential candidate would be susceptible to the same attacks raised by the Noteholders. For example, in a concurso proceeding the conciliador acts as mediator between the debtor and creditors. A visitador only inspects the debtor’s accounting books and records and determines whether the .debtor meets the LCM’s liquidity standard. The sindico is a receiver charged with liquidating the business and selling its assets if a plan is not reached within a specific period of time. None of these individuals possesses the full authority the Noteholders argue is required under § 101(24). Accordingly, we conclude that Vitro had the powers of a debtor in possession for purposes of § 101(24)'and affirm the district court’s decision affirming the bankruptcy court’s order that Sanchez-Mujica and Arechavaleta-Santos are properly appointed foreign representatives under Chapter 15. C. Enforcement of the Plan 1. Vitro’s Request for Relief In the Enforcement Motion, Vitro sought broad relief pursuant to 11 U.S.C. §§ 105(a), 1507, and 1521. Specifically, Vitro sought an order giving full force and effect in the United States to the Mexican court’s order approving the Concurso plan. Vitro further sought a permanent injunction prohibiting certain actions in the United States against itself and its non-debtor subsidiaries, specifically: [A] permanent injunction enjoining all persons from initiating or continuing any suit, action, extra-judicial proceeding or other proceeding (including [already commenced actions in New York state court]) or any enforcement or collection process (including pursuant to any judgment, notices of attachment or [levies, restraining notices, or similar documentation]) in any jurisdiction within the United States or its territories ... against Vitro SAB and/or the Old Guarantors ... or their Property ... except as permitted under the Concurso Plan or the Concurso Approval Order ..... If Vitro were to succeed in obtaining all the relief that it requested, actions, executions, attachments, or other collection or enforcement processes currently pending against Vitro or its subsidiaries would be “permanently stayed, suspended, discharged, and dismissed.” Judgments already rendered against it or its subsidiaries would be declared “null and void and of no further force or effect.” Moreover, any entity having withheld payment to Vitro or its subsidiaries as a result of Vitro’s default would immediately remit such payments to the applicable party. Finally, Vitro and its subsidiaries would be released from all liabilities with respect to any claims discharged under the Concurso plan. Of course, the bankruptcy court could grant some, but not all, of the relief requested. The bankruptcy court held that the Concurso plan “which extinguishes the guarantee claims of the Objecting Creditors that were given under an indenture issued in the United States against non-debtor entities that are subsidiaries of Vitro, should not be accorded comity to the extent it provides for the extinguishment of the non-debtor guarantees of the indentures.” Vitro II, 473 B.R. at 132. The bankruptcy court specifically denied enforcement under §§ 1507, 1521, and 1506. It denied relief under § 1507 because the Mexican court’s approval order did “not provide for the distribution of proceeds of the debtor’s property substantially in accordance with the order prescribed by Title 11 [of the Bankruptcy Code].” Id, “The Concurso plan provides drastically different treatment in that the noteholders receive a fraction of the amounts owed under the indentures from Vitro SAB and their rights against the other obligors are cut off.” Id. Relief under § 1521 was inappropriate because the Mexican court’s approval order “neither sufficiently protects the interests of creditors in the United States, nor does it provide an appropriate balance between the interests of creditors and Vitro SAB and its non-debtor subsidiaries.” Id. Finally, the relief sought would not be allowed under Chapter 15 because “the protection of third party claims in a bankruptcy case is a fundamental policy of the United States” and “the Concurso plan does not recognize and protect such rights.” Id. The circumstances under which the Plan was approved and the treatment creditors received raise many questions that are not before us about whether such a plan could be enforced under Chapter 15. The bankruptcy court explicitly dealt with some of these questions, while flagging others for our consideration without itself reaching them. Thus, for example, the bankruptcy court considered whether, as alleged by the Objecting Creditors, the Mexican judicial system and the concurso proceeding were corrupt, and should not be granted comity for this reason. Addressing the Objecting Creditors’ expert — Dr. Stephen D. Morris — who testified to a series of “suspicious circumstances” and “red flags” in the concurso proceeding, the bankruptcy court held that, although the witness was knowledgeable and qualified to speak on corruption in Mexico generally, his analysis of what impact such corruption had on this proceeding was unpersuasive. The 'bankruptcy court therefore concluded that it “ha[d] not seen evidence that the Mexican Proceeding [was] the product of corruption, or that the LCM itself is a corrupt process,” and rejected the Objecting Creditors’ argument. Id. at 130. .The bankruptcy court reached a similar conclusion as to whether, as argued by the Objecting Creditors, enforcement would have an adverse impact on credit markets. The court ultimately concluded that, while testimony by Dr. Elaine Buckberg, a former economist at the International Monetary Fund, was credible, her testimony did not quantify the negative effects of enforcing the Plan, and thus the court could not conclude that enforcement would adversely affect credit markets. Id. The bankruptcy court also considered, but rejected, the argument that relief should not be granted because the Mexican proceeding was “unfair.” Id. at 130-31. The bankruptcy court observed that although there had been ex parte meetings, such meetings were had by both sides and were, in fact, common in Mexico. Id. at 131. Responding to the Objecting Creditors’ allegations that they were not permitted to raise certain arguments in the Mexican court and that the conciliador was biased, the bankruptcy court held that such arguments were better left for the Mexican court system. Id. The bankruptcy court did not reach two other - arguments it described as “[p]ossiblfy] [m]eritorious [objections.” Id. at 132. These were that insiders were allowed to vote in favor of the Plan, and that the Concurso plan violates the absolute priority rule. Other arguments the bankruptcy court did not explicitly address, but which might be subsumed under its other holdings, are that the Concurso plan imposed a kind of “death trap” provision that precluded non-consenting creditors from recovering anything. Another such argument is that Mexico’s single-class voting made no distinctions between creditors with adverse interests. Finally, a third such argument challenges the propriety of Vitro’s orchestrating a balance transfer of several billion dollars between itself and its subsidiaries, turning those subsidiaries into creditors, prior to entering into the concurso proceeding and failing promptly to disclose the existence of these newly minted insider creditors. We need not concern ourselves with the vast majority of these issues, as Vitro and Fintech have framed their appeal in terms of only one: Whether the Bankruptcy Court erred as a matter of law when, after it concluded that the Concurso Approval Order was the product of a process that was not corrupt or unfair to the Appellees, it refused to enforce the Concurso Approval Order solely because the Concurso plan novated guarantee obligations of non-debtor parties and. replaced them with new obligations of substantially the same parties? The issue Vitro and Fintech identify underpins the bankruptcy court’s entire opinion. As that court summarized, “the Concurso plan approved in this instance ... extinguishes the guarantee claims of the Objecting Creditors that were given under an indenture issued in the United States against non-debtor entities that are subsidiaries of Vitro____ Such order manifestly contravenes the public policy of the United States and is also precluded from enforcement under §§ 1507, 1521 and 1522 of the Bankruptcy Code,” and would not be accorded comity. Id. at 133. 2. Chapter 15’s Framework for Granting Relief As already discussed, “[a] central tenet of Chapter 15 is the importance of comity in cross-border insolvency proceedings.” In re Cozumel Caribe, S.A. de C.V., 482 B.R. 96 (Bankr.S.D.N.Y.2012). “The extent to which the law of one nation, as put in force within its territory, whether by executive order, by legislative act, or by judicial decree, shall be allowed to operate within the dominion of another nation, depends upon what our greatest jurists have been-content to call the comity of nations.” Hilton, 159 U.S. at 164, 16 S.Ct. 139. In applying the principles of comity, we “take[] into account the interests of the United States, the interests of the foreign state or states involved, and the mutual interests of the family of nations in just and efficiently functioning rules of international law.” In re Artimm, S.r.L., 335 B.R. 149, 161 (Bankr.C.D.Cal.2005). Accordingly, Chapter 15 provides courts with broad, flexible rules to fashion relief appropriate for effectuating its objectives in accordance with comity. See In re Bear Stearns High-Grade Structured Credit Strategies Master Fund, Ltd., 389 B.R. 325, 333-34 (S.D.N.Y.2008); In re SPhinX, Ltd., 351 B.R. 103, 112 (Bankr.S.D.N.Y.2006) (“[Cjhapter 15 maintains — and in some respects enhances — the 'maximum flexibility,’ that section 304 provided bankruptcy courts ... in light of principles of international comity and respect for the laws and judgments of other nations.” (citation omitted)). Given Chapter 15’s heavy emphasis on comity, it is not necessary, nor to be expected, that the relief requested by a foreign representative be identical to, or available under, United States law. In re Metcalfe & Mansfield Alternative Investments, 421 B.R. 685, 697 (Bankr.S.D.N.Y.2010) (“The relief granted in the foreign proceeding and the relief available in a U.S. proceeding need not be identical.”); see also Artimm, 335 B.R. at 160 n. 11. We have previously cautioned that the mere fact that a foreign representative requests relief that would be available under the law of the foreign proceeding, but not in the United States, is not grounds for denying comity. See In re Condor, 601 F.3d at 327. Nevertheless, Chapter 15 does impose certain requirements and considerations that act as a brake or limitation on comity, and preclude granting the relief requested by a foreign representative. In this case, the bankruptcy court rested on three of Chapter 15’s sections, §§ 1521, 1507, and 1506, each of which it found precluded the relief Vitro sought. Vitro II, 473 B.R. at 133. Vitro’s appeal predominantly rests on finding relief under § 1507 and, only in the alternative, under § 1521. Vitro argues that it would be inappropriate to deny its request for comity under § 1507, simply because the relief might not meet the requirements of § 1521. The Objecting Creditors, in turn, argue extensively that the relief Vitro requests, to the extent it is available at all, must fall under § 1521(a)(1) and (b), and that the bankruptcy court was correct to deny enforcement because of the limitations imposed by § 1522. Thus, while comity should be an important factor in determining whether relief will be granted, we are compelled by the bankruptcy court’s decision and the parties’ arguments to get into the weeds of Chapter 15 to determine whether a foreign representative may independently seek relief under either § 1521 or § 1507, and whether a court may itself determine under which of Chapter 15’s provision such relief would fall. Both appear to be questions of first impression. We conclude that a court confronted by this situation should first consider the specific relief enumerated under § 1521(a) and (b). If the relief is not explicitly provided for there, a court should then consider whether the requested relief falls more generally under § 1521’s grant of any appropriate relief. We understand “appropriate relief’ to be relief previously available under Chapter 15’s predecessor, § 304. Only if a court determines that the requested relief was not formerly available under § 304 should a court consider whether relief would be appropriate as “additional assistance” under § 1507. We start by acknowledging that “[t]he relationship between § 1507 and § 1521 is not entirely clear.” In re Toft, 453 B.R. at 190; see also In re Atlas Shipping A/S, 404 B.R. at 741. This leaves litigants uncertain as to which provision they should rely on for relief. Indeed, Vitro itself acknowledges that its decision to seek relief under § 1507 and, only in the alternative, § 1521 was motivated, in part, by the fact that every other foreign representative requesting enforcement of a concurso plan under Chapter 15 has cited both § 1507 and § 1521. Section 1521(a) empowers a court to “grant any appropriate relief’ at the request of the foreign representative when necessary to “effectuate the purpose of [Chapter 15] and to protect the assets of the debtor or the interests of the creditors.” 11 U.S.C. § 1521(a). In addition, § 1521 lists a series of non-exclusive forms of relief. These include: (1) staying the commencement or continuation of an individual action or proceeding concerning the debtor’s assets, rights, obligations or liabilities to the extent they have not been stayed under section 1520(a); (2) staying execution against the debt- or’s assets to the extent it has not been stayed under section 1520(a); (3) suspending the right to transfer, encumber or otherwise dispose of any assets of the debtor to the extent this right has not been suspended under section 1520(a); (4) providing for the examination of witnesses, the taking of evidence or the delivery of information concerning the debtor’s assets, affairs, rights, obligations or liabilities; (5) entrusting the administration or realization of all or part of the debtor’s assets within the territorial jurisdiction of the United States to the foreign representative or another person, including an examiner, authorized by the court; (6) extending relief granted under section 1519(a); and (7) granting any additional relief that may be available to a trustee, except for relief available under sections 522, 544, 545, 547, 548, 550, and 724(a). 11 U.S.C. § 1521(a). Additionally, under § 1521(b), “the court may, at the request of the foreign representative, entrust the distribution of all or part of the debtor’s assets located in the United States to the foreign representative ... provided that the court is satisfied that the interests of creditors in the United States are sufficiently protected.” Section 1522 provides an important limiting factor: relief under § 1521 may be granted “only if the interests of the creditors and other interested entities, including the debtor, are sufficiently protected,” and a court may impose appropriate conditions on relief. 11 U.S.C. § 1522(a)-(b). Unlike § 1521’s “any appropriate relief’ language, § 1507 gives courts the authority to provide “additional assistance.” Section 1507 “was added to the Bankruptcy Code because Congress recognized that Chapter 15 may not anticipate all of the types of relief that a foreign representative may require and which would otherwise be available to such foreign representative.” 8 Collier on Bankruptcy ¶ 1507.01 (Alan N. Resnick & Henry J. Sommer eds., 16th ed. 2012) (Collier). A court determining whether to provide additional assistance under § 1507 considers the factors listed under subsection (b), which provides that: (b) In determining whether to provide additional assistance under this title or under other laws of the United States, the court shall consider whether such additional assistance, consistent with principles of comity, will reasonably assure 1) just treatment of all holders of claims against or interests in the debtor’s property; 2) protection of claim holders in the United States against prejudice and inconvenience in the processing of claims in such foreign proceeding; 3) prevention of preferential or fraudulent dispositions of property of the debtor; 4) distribution of proceeds of the debtor’s property substantially in accordance with the order prescribed by this title; and 5) if appropriate, the provision of an ■ opportunity for a fresh start for the individual that such foreign proceeding concerns. 11 U.S.C. § 1507(b). We are thus faced with two statutory provisions that each provide expansive relief, but under different standards. To clarify our resolution of requests for relief under Chapter 15 we adopt the following framework for analyzing such requests. First, because § 1521