Posts Tagged ‘Chapter 13’

Before Foreclosure Rescue Scammers Start Knocking…

I came across an interesting story (and video) over at CNBC.com: Fraud at your Front Door which discusses foreclosure rescue scam artists who are knocking at the front door of homeowners facing foreclosure. I have met clients who have told me they have been approached by individuals how have been at their doors offering assistance. But there’s no rescue. They’s only a rip-off.

Not only do the homeowners lose money, they lose time to productively work with their lender. I heard a lender attorney recently say that homeowners have told them that “…we paid this person to help us.” But the person is not helping them, and as this CNBC story points out, in many cases, the “helper” doesn’t even contact the lender. In addition to losing valuable time and money, the homeowner may also lose credibility with the lender.

The story recommends that if your lender is unwilling to relax the payments to help you, seek a qualified real estate attorney or non-profit credit counselor. But there are also local mortgage counselors who will help you with a modification request (click here for ESAC located in Boston). And I also think you should not rule out speaking to a bankruptcy attorney so you can discuss your options. Or, I encourage you to contact us if your lender is unwilling to work with you.

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2009: Perchance to Dream

New Years is a time when many make resolutions. Some resolve to quit smoking. Some resolve to lose weight. The list of resolutions is endless. Personally, I think many resolutions are pretty useless. I didn’t stop smoking because of a resolution (but I did quit… a few Novembers ago), and I have not exactly kept up with resolution diets. I’ve been racking my brain trying to come up with something appropriate to write about for New Years. The last thing I want to do, especially today, is sound trite. It’s not like you can simply “resolve” to get out of bad mortgage or you can “resolve” to get a better job when companies are laying off. But then yesterday, I had a surprise visit from an old client who helped my thought process move along.

My client went through a long chapter 13. At times, it was not particularly pleasant. But all plan payments were paid and the discharge was received a few years ago. Now, she’s dedicated to her business and determined to keep make it grow in a difficult economy.

During our brief meeting, I noticed something different. Was it the hair color, I thought? No. Did she have her teeth done? No, not that. Then it dawned on me. It was something more.

She was happy. She was smiling. While she was not a particularly unhappy person while the case was open, I think it’s fair to say the chapter 13 was not a particularly happy period in her life. But now, the chapter 13 case is behind her and yesterday she sat before me smiling, happy, and talking about the future.

As an attorney, while I try to get my client’s perspective, I really can only get so much. I can only put myself so far into a client’s shoes. So I asked her, now that her case is behind her, now that she is moving forward with her life in new directions, what were her feelings about the bankruptcy process now that she was “on the other side of it.”

She didn’t hesitate with her response. (I can’t quote, but I did take a few notes.) She told me that going through that difficult process allowed her to dream again. That now she could dream and that making those dreams a reality again seemed possible. Her dreams were no longer mired down in a chaos created by debt that had spiraled out of control. She told me that she felt freer than she had felt in a very long time.

The minute these words flowed, I could feel a smile growing on my face….and a bit of a lump in my throat. And then, it dawned on me: ‘this is what I’ve been itching to write about for the New Year.’

Many are looking at 2009 with a sense of foreboding and trepidation. World events are not exactly fueling optimism about the future. Perhaps 2009 will not be a year when dreams will come true. Perhaps things may get worse.

Or perhaps in spite of that, you can find a way to knuckle down, stand straight, bite your lower lip, bide your time, and get through a journey that brings you to the other side of it: a side where you can dream once again. I know it may all sound silly, but I know this place exists. Yesterday, I was fortunate to be reminded that for my clients in or facing bankruptcy, there can be a life afterwards. And that life can be wonderous. The only assurance I can give you is that the big smile on my client’s face proves that anything is possible.

With that, I wish you all a very Happy New Year.

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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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Changing Chapter 13: Some Facts on the “Pandora’s Box”

There’s been some press about a proposed change to chapter 13 that would permit debtors to modify the mortgages on their primary residence. Yesterday, I attended the briefing at the State House given by Rep. William Delahunt where the need for the legislation was discussed. He has co-sponsored a bill that would modify the anti-modification restrictions imposed by Section 1322(b)(2). Among the presenters were Massachusetts Attorney General Martha Coakley, Secretary of State William Galvin, and Harvard Law Professor Elizabeth Warren.

Currently, a chapter 13 debtor cannot modify the mortgage on their home if the note is secured by the debtor’s primary residence. This does not apply if the debtor has a multi-family dwelling, such as a two-family. This does not apply if the note is secured by the house and other property (although this may vary from state to state). This also does not apply if a debtor has a vacation home or other investment property. It applies only to those chapter 13 debtors who reside in single family homes and who have a mortgage that is secured by that single family home that they use as a primary residence.

Notwithstanding those restrictions, a chapter 13 debtor may “strip off” a second mortgage (or in some cases, a third), if the mortgage is “wholly unsecured.” A simple illustration: if the value of the property is so low that if the property were sold, there would not be funds to pay the second or third mortgage. However, if that second or third mortgage is secured by even a penny, it cannot be stripped off.

The Boston Herald quoted Kevin Cuff, Executive Director of the Massachusetts Mortgage Banks Association:

You’re opening up a Pandora’s box, a precedent to haul every mortgage back into court…Many people who got these loans should not have received them in the first place. Now you go to the courts to modify the sacred contract between homeowner and lender? It’s socialized housing.

I might agree with that position if chapter 13 debtors could not modify their vacation homes or investment properties. I might agree with that if city dwellers who reside in a unit in their multi-family home could not modify their vacation homes. But that’s not the case. The current system has a disparate impact on those chapter 13 debtors who reside in single family homes, and those who do not, and for many, those who do not reside in non-urban/rural areas. It also has a disparate impact on those middle-class debtors who do not have vacation homes or investment properties.

In addition, the legislation is being proposed because voluntary modifications are not happening. It is argued that if there is a “threat” of filing bankruptcy and modifying a mortgage in chapter 13, the lender may be more apt to modify the loan voluntarily so that the homeowner does not need to file chapter 13. It sounds like a good argument, but I honestly cannot say one way or another whether that would be the case. Of course, if the law were passed, then it would be really up to the lender to decide if they wanted to be hauled into court to be forced into a modification. The only way I think any of us can know for sure is if we give it a try. But before anyone makes a decision one way or another on this proposal, I think it’s important to know what the law currently provides, and why I do not think it is necessarily a “Pandora’s box” or “socialized housing.”

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Good Faith and Bad Art

In bankruptcy, good faith is a lot like good art. It is difficult to describe, but you know it when you see it. The same can be said with bad faith. A recent chapter 13 case out of the 9th Circuit illustrates that point.

The debtor filed a chapter 13 case in August 2004. Since chapter 13 is a voluntary proceeding, a debtor has the option of voluntarily dismissing their case at any time. Also, in chapter 13, the debtor is typically in control of assets of the estate. In this debtor’s case, one of the assets was claim that was being arbitrated against an LLC.

The debtor’s plan was met with objections from the trustee as well as creditors. The debtor assured the court that he would use funds obtained in the arbitration to fund the plan. In July 2005, the debtor was awarded approximately $185,000 in the arbitration. That month, the court ordered him to pay that sum to the chapter 13 trustee.

In August, the debtor’s attorney sought permission to withdraw from the case citing a breakdown in the attorney client relationship. At the hearing, the court learned that the debtor had not complied with the prior order from the court by turning the money over to the trustee. The court gave the debtor one hour to deliver the money, or the court was going to convert the case to chapter 7. The debtor did not deliver the money, and on that same day, the debtor filed a “Notice of Dismissal.”

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10th Circuit: Legal Interest Acquired Post-petition is Property of the Estate

When someone files bankruptcy, an estate is created. The property in the estate is defined in the Code, and it is the property in the estate that is used to pay creditors. But how do you value property of the estate if the nature of the interest held in the real estate changes after the petition date? On Friday, the 7th Circuit Court of Appeals answered that question.

In January 2004, the debtors filed for chapter 13 relief and sought to avoid a judgment lien (valued at about $8,200) on their residence. The lien arose from a deficiency judgment following an automobile repossession. Debtor’s estimated their interest in the residence to be valued at $65,000, subject to a mortgage of about $58,000. Their interest in the residence reflected an encumbrance of a life estate interest held by a relative. Under Indiana law, the homestead exemption at the time was $15,000 ($7,500 per debtor).

Two years later, after the plan was confirmed, the debtor’s filed a motion seeking to avoid the lien on the property. A month prior to the filing of the motion, the mother released her life estate interest by a quit claim deed, thus conveying the property to the debtors a fee simple interest. The value of that interest was determined to be $95,000. However, when the debtors sought to avoid the lien on the property, they used the prior valuation of $65,000.

The creditor argued that the valuation that should be used is the new one of $95,000. After an unsuccessful appeal to the District Court, the Court of Appeals was called upon to answer one question: for the purposes of avoiding a lien under Section 522, when should the debtors’ interest in the real estate be determined?

The Court looked to Section 1306 and what constitutes property of the estate:

Property of the estate includes, in addition to the property specified in section 541…. all property…that the debtor acquires after the commencement of the case but before the case is closed.

Section 541(a)(1) identifies property in the estate as including “all legal or equitable interests of the debtor in property at the commencement of the case.” And Section 541(a)(7) lists property of the estate as including “[a]ny interest in property that the estate acquires after the commencement of the case.” Based on that, the Court held that the value of the real estate should be determined at the fair market value at the time it was recorded in December 2005. The lien could not be avoided.

To get access to the opinion, and to hear the oral arguments of the case, Click Here.

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The Easy Life of a Consumer Bankruptcy Attorney

Every now and then, I get a call from someone who already has a bankruptcy case pending. Sometimes, they do not like how things are going with their attorney. Other times, they don’t have one at all and find that they are in over their head. And sometimes, by the time they are calling me, they find themselves in what can best be described as a world of hurt. Today, I received such a call.

The debtor’s chapter 13 case was filed almost two months ago. There is still no plan filed. No post-petition mortgage payments have been made. The debtor just got served with a summons and complaint because not all creditors were properly listed on the schedules (and I’m not sure the matrix was done right). The IRS has filed a notice that prepetition tax returns have not been filed. There are motions for relief from stay from secured creditors, and from the tone of them, they seem frustrated. No plan payments have been made, and the creditors meeting is soon. I am also assuming that no tax returns or payments advices have been sent over the chapter 13 trustee. In addition, by looking over the schedules, it appears that the debt is too high for chapter 13 eligibility. After I got all that from reviewing PACER, I decided to ask an easy question first:

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Equal and Monthly Payments: The Voyage of the Balloon

May a debtor propose a chapter 13 plan that provides for the payment of mortgage arrears with regular monthly payments followed by a balloon payment at the end of the plan?

So far, the answer is still no (although the issue is still working its way through the courts).

In the recent case of In re Carman out of the Massachusetts Bankruptcy Court in Worcester, the court found that a debtor could not propose a plan that paid the mortgagee interest only payments throughout the plan period, followed by a final balloon payment. “Such a modification is impermissible in that ‘once periodic payments to that creditor commence, a subsequent balloon payment would be unequal to those that preceded it.’”

Until we get word from the appeals courts, this issue will remain a potential road block for debtors who hope to fund their plan with a sale or refinancing (or other source of funds that they do not have access to now). When I say “road block”, I mean “road block to getting a chapter 13 plan confirmed.” And until this issue is resolved by the appeals courts, it should also be read to mean “a potential road block to keeping your house.”

In re Carman, 07-44271, US Bankruptcy Court, District of Massachusetts at Worcester, July 25, 2008

You may have missed:
Did Congress Pop the Balloon?

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A Shakedown Backfires

This week’s Newsweek has a great article on the abusive tactics debt collectors are increasingly using. The article is called “A New Shakedown” and it’s worth the read – especially in light of the shakedown a creditor recently pulled in a Nebraska bankruptcy case. The collector ended up violating the stay.

The debtors’ chapter 13 bankruptcy case was filed on February 13, 2008 and listed Geneva Roth Companies as a claim in the amount of $170. On May 21, a collector working on behalf of the creditor GRC (Sherman and Roman) called one of the debtors and started “to verbally abuse the debtor and coerced a payment from the debtor threatening criminal sanctions.”

According to a signed statement, despite being informed of the bankruptcy filing and the pending bankruptcy case the collector told the debtor that she “was a key element in an investigation of fraud and bank theft….that they will be forced to have me identified as a felon. [The debtor went on to tell her that [she] was not going to talk to her about this at work and that I would call her back. [It] was then I had to call her back within minutes or my husband and I would be identified at our work by cops if I didn’t and it would be embarrassing.” The debtor was ultimately compelled to use a debit card to pay $300. She was left shaken.

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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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