Archive for the ‘Chapter 7’ Category

Who Really Files Bankruptcy?

What leads a person to the steps of the bankruptcy court seeking relief from debt? That is not an easy question to answer – although there are some out there who may think they know the answer. But as I was digesting a recent opinion out of the Bankruptcy Court in the Northern District of Texas, I read the following:

Anecdotally, this court notes that it sees all sorts of consumer debtors come through the bankruptcy system. At one end of the spectrum, there are individuals who have been plagued with many bad circumstances that have led to their financial demise-such as health problems, injuries, medical bills, job loss or instability, divorce, or death of a bread winner. At the other end of the spectrum, there are individuals who have been blessed with good health and adequate jobs and resources, and yet have somehow created a mountain of consumer debt that they (and probably their creditors) should have known could never be repaid. Some of these latter individuals have even engaged in some sort of fraud along the way-perhaps in a loan application at some point, or with intentional avoidance and nonpayment of taxes, or by hiding assets before entering into bankruptcy.

But the vast majority of debtors this court sees fall somewhere between the two extremes. They are individuals who probably cannot honestly blame “bad luck” as the cause of all of their woes. And many of them have made more poor choices than wise ones, and such choices have finally caught up with them.

So what does this mean, and why am I sharing it with you?  The easiest answer is that it is my experience that the court is right. However, there’s a rather significant “but…”

Unless we’re talking about a nefarious character with no sense of right and wrong, most people do not cheerfully enter the bankruptcy process. By the time they enter bankruptcy, or are at least considering it, they regret decisions they made. They know some of their choices were unwise. However, that does not mean that a debtor is not deserving of a chance to start over.

As I continued to read the Texas decision, I learned that the debtors had inconsistent income, high expenses, and some peculiar explanations for their debt.  Also, the facts seemed to indicate a bit of ambivalence as to how they came into the financial predicament they were in, and why they sought bankruptcy relief. T heir case was dismissed because the court deemed it to be an abuse of Chapter 7. I did not summarize the case because I do not want people to read more into the facts but also because I want to assure readers who are facing bankruptcy that there’s something far more important in this case than the kind of car the debtor was driving or when they bought it.  What’s more important is that they have a sense of who files bankruptcy and who is entitled to the relief afforded by the code.

Far too many talking heads (and readers know who they are) characterize people who file bankruptcy as buffoons with entitlement complexes. Making bad decisions is not evidence of an entitlement complex. Making bad decisions, standing alone, is also not evidence of fraud or other unscrupulous activity.  Making bad decisions is evidence of being human (which by all appearances, some of those talking heads might be similarly viewed as such…although I often wonder).

Of course, whether a decision is so bad that it would effectively rule out bankruptcy as an option can only be determined after a careful review of the facts by someone who knows the law. As this court decision points out, there is no one cause that pushes people into bankruptcy and there is no bright line profile of a person who files bankruptcy. Those that attempt to convince the masses otherwise only breed prejudice and fear where it need not exist.

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A Holiday Shopping Tip (or Warning)

With Black Friday soon upon us, and the holiday shopping season, I want to get a message out to those folks who are struggling. Perhaps there are folks who know they are going to lose their jobs after the New Year. Perhaps there are folks who have been using credit to get by and now see a bankruptcy petition on the horizon. Perhaps these folks are figuring that they will have one last holiday with really great gifts courtesy of their credit card companies. If you’re reading this, and you’re thinking “wow, he’s totally speaking to me (or about my friend or relative)!” please keep reading.

One thing many consumers do not know is that when you buy “large-ticket” item, it may also come with it a security interest. In other words, that purchase may be a gift, but it may also be collateral. The lender (the store, or the bank that finances the store’s credit cards or credit lines) assumes a security interest. This is something to think about as you’re eyeing that appliance or jewelry. Will it prevent you from filing bankruptcy? Probably not. Will it complicate things? It just might. You may have to pay the debt even if you file bankruptcy or you may have to surrender the collateral. Or you might hear from the creditor months or years after the bankruptcy is over.

Last minute purchases can also get you into hot water. Using a credit card when you have no intention of paying the debt back can be considered fraud. Debts incurred through fraud cannot be discharged. In addition, such actions could be considered bad faith, and might lead to a dismissal or a denial of discharge, depending on the circumstances. What does any of this mean? The short answer is more attorney fees, more anxiety and the possibility that the bankruptcy case will not go as smooth as it otherwise could.

If you’re contemplating bankruptcy, don’t use credit cards for holiday shopping. Speak with an attorney. The last thing any debtor needs is to make a tough situation even worse.

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Why Bankruptcy Lawyers Require Fees Before Filing

There really is a good reason. And to help prove my point, I turn to an October 2008 decision out of the US Bankruptcy Court for the Eastern District of Pennsylvania: In re Mansfield. In that case, the court was called upon to ask what it viewed as a “deceptively simple question:” may an attorney who charges a “flat fee” for services pursue the uncollected balance due?

In this case, the attorney charged a flat fee for preparing the necessary documents and schedules, but also for attending the first meeting of creditors (which occurs after the case is filed). The fee was paid in one large installment, with the remaining balance divided into smaller installments which were paid or due after the case was filed.

The US Trustee sought a review of the fee practice as well as disgorgement of the fees collected after the case was collected. The attorney claimed there was no authority supporting the relief sought by the US Trustee, and he was entitled to collect at least the value of the services he rendered.

The court did not agree. Under Section 727(b) of the Bankruptcy Code, a “debtor’s obligation under a fee agreement to pay a fixed or flat fee to his attorney for legal services rendered pre- and postpetition in a Chapter 7 case, regardless of how the fee is scheduled to be paid, is a prepetition debt that is dischargeable. The attorney avoided having to return the fees paid because there is a difference of opinion among Bankruptcy Courts throughout the country as to whether the practice of collecting fees post-petition is permissible….and if permissible, the circumstances they are permissible.

In flat fee cases (and it is fair to say most, if not all consumer Chapter 7 cases are flat fee), the court found that the “division of a flat fee arrangement into prepetition and postpetition parts to be conceptually inconsistent and therefore untenable. The Court therefore joins those other courts which hold what when a flat or fixed prepetition agreement is at issue, the fee must be paid in full prior to the commencement of the debtor’s case or the fee is discharged under Section 727(b).”

So in reality, when an attorney requires fees and costs prior to the filing of the petition, it’s because they need to get paid…unlike creditors in a Chapter 7 who in many cases do not get paid at all. There’s case law all over the country that supports it, and other case law that suggests that it can be done. While the current code and the case law leave room for creative argument, debtor’s attorneys can be expected to be wise and take the path of least resistance: earn the fee and serve the client. Certainly, there are bigger battles for debtor’s attorneys to engage in for their clients other than fighting for a fee for postpetition services.

In re Mansfield, US Bankruptcy Court, Eastern District of Pennsylvania, No. 08-11648 SR (Ocobter 2, 2008)

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Debtor Can’t Reopen Case to Enforce Discharge. Yet.

In an October 3 decision, a Massachusetts Bankruptcy Court ruled that a debtor could not reopen her chapter 7 bankruptcy to commence an adversary proceeding to enforce the discharge.

The debtor was involved in an auto accident in 2003 which resulted in the death of another person. Later in the year, the Administrator of the Estate accepted $100,000 from the debtor’s insurance company and signed a release. In December 2004, the debtor filed her chapter 7 bankruptcy petition and received a discharge in April 2005. In the petition, she did not list the Estate as a creditor. There were no assets to distribute to creditors.

Then, in January 2006 the debtor heard from the “successor” Administrator of the Estate.

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WhatsaMatta with WaMu?

So yesterday I received this letter from WaMu:

Dear William McLoud [sic]:

Our customer (my client) informed us of his/her intent to file (chapter 7) bankruptcy. We realize this decision was not an easy one. We would like to resolve this matter and offer an alternative that may minimize the negative impact that filing for bankruptcy can have on your client’s credit and employment opportunities.

As of today, the balance on the (credit card) account referenced above is [$2,500]. However, you may elect to settle the balance for 60%, or [$1,500], and your client will be under no further obligation. Simply alert us of your acceptance and remit the settlement payment.

If your client is unable to pay this amount in full, or if you have any further questions, please contact our Bankruptcy Department…

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Late Filing of Documents = Dismissal

One of the goals of BAPCPA (the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005) was to prevent abuse by debtors. One of those abuses targeted were “repeat filers” and another was the failure to file documents. If schedules and other documents are not timely filed, the court is obligated to dismiss the bankruptcy case. A debtor out of the Northern District of Alabama recently learned what happens when you do not adhere to the requirements of the code.

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Storm Preparation: Over Withholding

Many people over withhold taxes on their paychecks. In other words, they have more taken out so that come April 15, they will expect a nice refund rather than having to pay more to Uncle Sam. But over withholding can make preparing for a bankruptcy filing a little difficult. First, over withholding is not a good idea to begin with. And secondly, the money you’re withholding (and will ultimately get back) must be considered as part of your monthly income.

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“Stated Income” Loan Discharged Despite False Representations on Application

One of the focuses of my bankruptcy practice is litigating Adversary Proceedings. I came across a case out of the Northern District of California. The first sentence under the heading of “Summary of Facts” read: “[t]his adversary proceeding is a poster child for some of the practices that have left to the current crisis in our housing market.” Clearly, this was something I had to read – and share with you.

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Rumor Control: TheStreet.com gets it wrong.

With the limited exception of realizing while in court that I have worn two different colored socks and I am convinced that everyone can tell, there’s nothing that drives me more nuts than exaggerated and half-baked claims about bankruptcy. A recent article on TheStreet.com proves my point. Lauren Tara LaCapra writes in “Bankruptcy Can Hurt For Decades”:

Rules enacted in 2005 made it harder and more costly for Americans to file for Chapter 7, in which assets are liquidated and given to creditors, or Chapter 13, which structures a repayment plan for certain debts over a term up to five years. (Debts outside of the plan would not have to be repaid.)

Harder, no. Costlier, yes. It’s hard to really chide the writer for this lack of understanding because I know many people have it. But, there is also this: “Debtors outside of the plan would not have to be repaid.”

Um….No. If debts are not in the plan, they need to be paid. A best example I can give is with a car loan. If the debtor wants to keep the car, the loan needs to be paid. That loan is paid outside the plan. If it doesn’t get paid, the car gets repossessed. I could (and perhaps will at some point) get into some long analysis as to whether a deficiency must be paid through the plan and why. I could (and perhaps will at some point) blog about what happens when debtors attempt to pay only certain creditors through a plan, while paying others on the side. Suffice it to say, the claim that debts not included in the plan need not be repaid is flat out wrong. (I could reasonably infer that the term “Debts” might really mean “Regular monthly expenses” such as the electric bill and the phone bill. Those do get paid outside the plan…but they are not debts. They are expenses.)

Then, the article refers to an Ohio State University study:

…it can take over 20 years for bankruptcy filers to reach the same financial status as those with similar social and economic backgrounds who did not file for bankruptcy. It took more than a decade for a bankruptcy filer to catch up to peers in terms of savings, income and home ownership, according to the study. It took more than a quarter of a century to reach the same level of net worth.

Translated: people who file bankruptcy will not be in the same financial station in life as their peers who do not file bankruptcy. I imagine that most people facing bankruptcy know this…I also imagine that if they are in so much debt that they probably already know this. I also imagine that some of “their peers” are also quietly suffering with a boat-load of debt while all the while trying to put a good face forward to as not to lead anyone to suspect otherwise.

Jay Zagorsky, co-author of the study and a research scientist at Ohio State, notes that high prices for gas, food and housing, combined with crushing debt, can make bankruptcy seem like an easy way out with a clean slate.

“But,” he adds, “to experience what people may heard of as a ‘fresh start,’ that may take longer than they expect or would like.”

True. But it’s going to be easier to pay the higher costs for food, gas and home heating oil if the other debt is dealt with in bankruptcy. As far as getting credit again, it can happen. I have had clients who have been in bankruptcy (chapter 13) and gotten credit cards (without my knowledge and without court permission…which is actually not a smart thing to do at all). I have had clients who have received their chapter 7 discharge and within weeks were receiving credit card offers (and in some cases, receiving cards). Of course, in those days, if you had a pulse, an address you could get a credit card.

Today, it’s not so easy. We are in a credit crunch. Underwriting standards are changing, and some merchants are rethinking whether they will accept credit cards. Just this week, I received a letter from Filene’s Basement telling me that they were discontinuing their credit card after September 1. They were also kind enough to send me a coupon for 15% off of one-item. But I digress…

Gas and food costs are going to make it difficult for people. Actually, it is making things difficult for people…which includes people like me. Then, the article offers this not-particularly-sage advice:

Those grappling with high costs and excessive debt should seek out other options first — whether restructuring or consolidating debt, negotiating a payment plan or lower interest rates with creditors, selling off assets or simply cutting back on costs — before putting a 20-year “scarlet letter” on their credit scores.

You cannot restructure your mortgage if your lender will not return your calls. You cannot consolidate your debt if you cannot qualify for a consolidation loan. You shouldn’t consider repaying debt with credit counseling without exploring whether chapter 13 is actually a better and more cost effective route. Selling assets: sure. So long as it’s not a house you need to sell anytime soon, and so long as you’re not selling something to a buddy because you’re concerned about losing it in a later bankruptcy filing. And as for cutting back on costs, some cannot cut back anymore.

Finally, the bankruptcy filing does not stay on the credit report for 20 years. It’s on the credit report for 10. It’s also not a Scarlett Letter…harkening back to that Nathaniel Hawthorne novel about an adulterous Demi Moore who is forced to wear an “A” so as to let the world know how sinful she is.

For the overwhelming number of people who walk through my office door, that bankruptcy filing is exactly what they need to move on. The bankruptcy is exactly what it will take to get things back on track and to help them face the new economic challenges that face us all. While I encourage debate with others with different points of view, I urge anyone who is “knee-deep in debt” to get the facts. It’s a shame that this article is short on them.

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“I Need to Get Through the Winter”

For weeks I have wondered what impact the high price of home heating oil was going to have on people who need it. Would it push them into bankruptcy (or worse)? Since it is usually an accumulation of things that leads one to file bankruptcy, there is no clear way I can predict that the price of oil is going to push people over the financial edge. But last week, I spoke with a client who found himself standing on the proverbial financial precipice, and it was that realization that lead them to think about filing bankruptcy.

The client recently ended a long term relationship. As many of us know, it is far cheaper for two people to live under the same roof than it is for one. The household income had dropped, and every day expenses increased. There was also some debt that continued to linger such as credit cards and consolidation loans. While he was paying a modest rent (less than $1,000 per month), it did not include the price of home heating oil.

To meet his obligations, the client did what many people do: he decreased expenses. However, he did so to the detriment of his health. A few years ago, he underwent a gastric by-pass. Instead of buying the protein and vegetables that his doctor expected him to eat (and that frankly, we all need to eat), he was instead eating the less expensive pasta and starch that he should not be eating.

Since it’s July, his oil use in the summer is limited to heating the hot water, and just ½ tank (100 gallons) can get him through most of the summer. But from December through April, it is not uncommon for his tank to be filled at least once per month. What prompted him to call me was that when he got his summer oil delivery last month, that 100 gallons cost him $429.

Making things more difficult: many (if not all) oil companies are refusing to lock in prices or offer budget plans.

The client realizes that unless the other debt is somehow compromised, he either will not be able to heat his apartment, or his other creditors will not get paid. In other words, he sees that at some point, a choice will need to be made. Without the debt, the client could get through the winter assuming that that there are no dramatic increases in the prices. And it is this scenario that causes me to ponder this: “how many other people are wondering how they are going to do it?”

It’s not an easy question I can answer. However, for this client, who is struggling with the increasing prices on consumer goods and debt, and facing a cold and expensive winter, he has answered that question by considering bankruptcy. For him, it might be the only way to get through the winter.

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