The Lifecycle of Nonrecourse Liability: Drafting, Negotiation, and Enforcement

Alonso Cisneros, Shareholder | Selzer Gurvitch

Alonso J. Cisneros is a Shareholder specializing in Real Estate and Real Estate Finance at Selzer Gurvitch, where he advises commercial real estate clients on complex loan transactions across all asset classes. He represents developers, borrowers, and a diverse range of financial institutions — including commercial and investment banks, regional and local banks, and other lending entities — across permanent, bridge, mezzanine, preferred equity, construction, and split loan structures. Throughout his career, Alonso has closed billions of dollars in real estate financing nationwide.

Education & Credentials

• Alonso holds a J.D. from The George Washington University School of Law, where he was a Dean’s Fellow, and a B.S. in Mathematics from the University of Florida. He is admitted to the District of Columbia Bar, the Virginia Bar, and the U.S. District Court for the Eastern District of Virginia. Earlier in his career, he served as a law clerk for The Honorable Gerald Bruce Lee in the U.S. District Court for the Eastern District of Virginia. Alonso is also a U.S. Marine Corps veteran, having attained the rank of Major and served as assistant training and operations officer and civil affairs officer with the Fourth Civil Affairs Group.

Recognition & Leadership

• Alonso has been recognized in The Best Lawyers in America® for Real Estate Law in the 2026 edition and is a member of the Mortgage Bankers Association.

Professional Involvement

• Alonso is an active thought leader in commercial real estate finance, having authored and presented on distressed loan topics for the Washington Business Journal, including “Bad-Boy Guaranties: What You Do Not Know Could Cost You Personally” in 2025 and “Navigating CRE Asset Distress, Under-performing Loans and Workouts” in 2024. Before joining Selzer Gurvitch, he was a partner in the real estate finance group at a prominent international law firm.

Experience

• Alonso’s practice spans the full lifecycle of commercial real estate transactions, from acquisition, development, and construction to disposition and workout. He has particular expertise in agency lending, with extensive experience under the Fannie Mae Delegated Underwriting and Servicing (DUS) program and the Freddie Mac Optigo Seller/Servicer program, across a broad spectrum of loan products including senior housing, affordable housing, Shari’ah-compliant structures, manufactured housing, student housing, and green financing. He also advises on loan servicing, asset management, and workouts, providing comprehensive support to lenders and servicers throughout the life cycle of their loan portfolios.

Massimo F. D’Angelo, Partner | Blank Rome LLP

Massimo F. D’Angelo is a nationally recognized real estate attorney and commercial litigator at Blank Rome LLP, where he represents a broad range of clients in complex real estate disputes, high-stakes civil litigation, and related corporate matters. He counsels owners, developers, corporations, condominium and cooperative boards, and other entities on intricate legal issues involving real property, commercial disputes, governance, and transactional risk. Massimo’s trial experience spans state and federal courts throughout the United States and internationally, and he regularly argues appeals and contributes to shaping litigation strategy in cutting-edge cases.

Education & Credentials

• Massimo earned his J.D. from Thomas M. Cooley Law School and his B.A. from the University of Massachusetts, Amherst. He is admitted to practice in New York and New Jersey, as well as multiple U.S. District Courts. He currently serves as Co-Chair of the Real Estate Industry Team at Blank Rome LLP.

Recognition & Leadership

• Massimo has been recognized as one of the “Top 500 Leading Litigators in America” by Lawdragon (2026) and has been consistently named a “Super Lawyer” in Real Estate: Business (2023–2025), following earlier recognition as a “Rising Star” (2014–2022). He is a frequent media contributor, having been featured on CNN and CBS News and quoted in leading publications including The Wall Street Journal, Financial Times, Politico, Forbes, and Law360.

Professional Involvement

• Massimo is actively involved in legal and international business communities. He serves as Chairman of the Board of Trustees for La Scuola d’Italia Guglielmo Marconi and is a member of the Italy America Chamber of Commerce. His additional affiliations include the New York State Bar Association, New Jersey State Bar Association, International Bar Association (Real Estate Section), and the New York City Bar Association. He also contributes to legal education and thought leadership through writing, speaking engagements, and industry programming.

Experience

• Massimo’s practice encompasses complex commercial litigation, real estate disputes, securities litigation, and white-collar matters. He has led precedent-setting cases involving real estate transactions, lease disputes, guaranty enforcement, and corporate liability, shaping legal standards in areas such as fee recovery, Statute of Frauds exceptions, and COVID-19-related lease defenses. He regularly advises clients through all stages of disputes—from pre-litigation strategy to trial and appeal—providing practical, business-focused guidance in high-stakes matters.

SESSION 1 – Nonrecourse Loans and the Evolution of Bad-Boy Guaranties | 1:00pm – 1:30pm

Establish the foundational framework of nonrecourse lending, tracing how bad-boy guaranties evolved in commercial real estate and where the market stands today, including key carveout structures, SPE covenants, and current market trends.

SESSION 2 – Drafting and Negotiating Nonrecourse Carveouts | 1:30pm – 2:00pm

Develop best practices for structuring and negotiating carveout provisions that clearly allocate risk, covering enforceable guaranty drafting, liability caps, cure rights, materiality thresholds, and market standards across structured financing, bank, construction, and mezzanine loans.

BREAK | 2:00pm – 2:10pm

SESSION 3 – Litigation and Enforcement of Bad-Boy Guaranties | 2:10pm – 2:40pm

Analyze how courts interpret nonrecourse carveouts and the strategies lenders and guarantors deploy when litigating enforcement disputes, including borrower defenses, establishing damages, and drafting guaranties designed to withstand litigation challenges.

SESSION 4 – Bankruptcy, Workouts, and Emerging Risk Areas | 2:40pm – 3:10pm

Explore how financial distress, restructuring efforts, and bankruptcy filings affect nonrecourse loans and guarantor liability, covering SPE covenant violations, workout strategy, cash management risks, unauthorized transfers, and emerging litigation trends affecting guarantor exposure.