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§ 524(m)

Fields, In re

Ruling
Reaffirmation agreement disapproved due to presumption of undue hardship. (Bankr. E.D.Wis.)
Issue(s)
Effect of Discharge; Presumption of Undue Hardship; Duration, Review and Rebuttal.

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Consumer opinion summary, case decided on March 02, 2022 , LexisNexis #0422-087

Anzaldo, In re

Ruling
Reaffirmation agreement was unenforceable where presumption of undue hardship was notrebutted. (Bankr. S.D. Cal.)
Issue(s)
Effect of Discharge; Presumption of Undue Hardship.

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Consumer opinion summary, case decided on January 07, 2020 , LexisNexis #0220-063

In re Armstrong

Ruling
Reaffirmation agreement could not be approved where it would impose undue hardship on debtor.
Issue(s)
Should reaffirmation agreement covering prepetition cash advances be approved?

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Consumer opinion summary, case decided on November 07, 2014 , LexisNexis #1214-055

In re Caldwell

Ruling
Amended reaffirmation agreement could not be approved due to failure to rebut presumption of undue hardship.
Procedural posture

A chapter 7 debtor sought approval of an amended reaffirmation agreement between the debtor and a bank. Pursuant to 11 U.S.C.S. § 524(c), the debtor sought to reaffirm a debt secured by a manufactured home (the property).

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Consumer opinion summary, case decided on January 30, 2012 , LexisNexis #0212-087

In re Duffy

Ruling
Permission to reaffirm debt denied due to presumption of undue hardship.
Procedural posture

Debtors filed a petition under Chapter 7 of the Bankruptcy Code and sought permission under 11 U.S.C.S. § 524(c) to reaffirm a debt they owed to a trust company that was secured by a pickup truck they owned. The court held a hearing on the debtors' request.

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Consumer opinion summary, case decided on September 15, 2011 , LexisNexis #1011-051

In re Mowrey

Ruling
Reaffirmation agreement not approved due to debtor's failure to rebut presumption of undue hardship.
Procedural posture

Debtor filed a petition under chapter 7 of the Bankruptcy Code, and he asked the court to approve three reaffirmation agreements he negotiated with a credit union, pursuant to 11 U.S.C.S. § 524. The court held a hearing on the debtor's motions.

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Consumer opinion summary, case decided on January 21, 2010 , LexisNexis #0310-047

Ford Motor Credit Co. LLC v. Morton (In re Morton)

Ruling
Best interests of debtor were not proper sole consideration for disapproving attorney certified reaffirmation agreement.
Procedural posture

Appellant creditor sought reversal of an order entered sua sponte by the U.S. Bankruptcy Court for the Southern District of Ohio disapproving an attorney certified reaffirmation agreement entered into by the creditor and debtor.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 09, 2009 , LexisNexis #1009-015

In re Reed

Ruling
Reaffirmation of real estate loan with substantial balloon payment would impose undue hardship on debtor.
Procedural posture

The debtors sought approval of a reaffirmation agreement under which they wanted to reaffirm both an automobile loan and a real estate loan. The real estate loan had a substantial balloon payment.

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Consumer opinion summary, case decided on April 01, 2009 , LexisNexis #0609-057

In re Hart

Ruling
Reaffirmation agreement disapproved due to failure to rebut presumption of undue hardship.
Procedural posture

The debtors and their mortgage lender creditor submitted a reaffirmation agreement for the court's approval. The creditor held a security interest in the debtors' poultry farm, related farm equipment, and the proceeds of the poultry business. The total outstanding balance on three loans was $ 921,100.36. The total monthly payment due on the loans under the reaffirmation agreement was $ 13,853.58, which exceeded their net income.

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Consumer opinion summary, case decided on March 10, 2009 , LexisNexis #0409-080

In re Sawyer

Ruling
Reaffirmation agreement that constituted an undue financial hardship on debtor could not be approved.
Procedural posture

A debtor filed a motion, pursuant to 11 U.S.C.S. § 524(m)(1), to approve a reaffirmation with a creditor covering the debtor's motor vehicle.

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Consumer opinion summary, case decided on February 24, 2009 , LexisNexis #0509-085