The 11th Circuit Court of Appeals has held that subchapter V of the Bankruptcy Code, as adopted by the Small Business Reorganization Act of 2019, may be utilized by a nonprofit homeowners’ association to provide a reorganization plan even though the debtor is not organized or operated for profit. The issue arose in connection with the bankruptcy filing of the Ellingsworth Residential Community Association, a Florida nonprofit homeowners’ association. The Association filed for bankruptcy after a resident was awarded $500,000 in recovery of legal fees from litigation over her obligations to maintain her property and the resident filed for more than $1 million in additional damages in state...