| July 2006 issue: Washington Hot News Association of Credit and Collection Professionals Writes Letter to Senate in Response to H.R. 5576 (July 18) The Association of Credit and Collection Professionals wrote a letter to the Senate July 14th opposing amendments that would prevent the IRS from using its fiscal year 2007 funds to hire private debt collectors. The letter was in response to H.R. 5576, which was passed by the House and contains a rider that prohibits the IRS from funding the program for the fiscal year 2007. Bankruptcy Rises Bankruptcy filings have declined from about 35,000 per week in 2005 to approximately 10,000 per week this year. However, the number of monthly filings has been slowly increasing this year from 34,411 in January to 43,780 in May. New Credit and Bankruptcy Blog "Credit Slips," a credit and bankruptcy blog, was launched this week. Your Name Here! The Bankruptcy Section is looking for volunteers to write a Case Analysis for an upcoming addition. The Case Analysis is typically based on Court of Appeals or Supreme Court decisions, although you can use your discretion to discuss relevant BAP, District Court and Bankruptcy Court decisions -- especially those interpreting BAPCPA's amendments to the Code. If you are interested or would like to learn more, please send an email to the Managing Editor. You can view the archive here. Your subscription You have been subscribed to this list as part of your membership in the Bankruptcy Section of the Commercial Law League of America. CLLA 205 N. Michigan, Suite 2212, Phone: 312-240-1400 Newsletter design by: |
Sua SponteCathy Pike, Chair What’s Cooking? As I attempt to gather my thoughts on the events which have occurred during my tenure as Chair of the Executive Council of the Bankruptcy Section, I never cease to be amazed at all that has transpired. Case AnalysesFrancis X. Buckley Jr. Don’t Wait Until It’s Too Late.
Faye B. Feinstein, Esq. States: 1 – Feds: 1 In the continuing turf war between the state and federal courts, the California Court of Appeal for the Second Appellate District has thumbed its nose at the 9th Circuit Court of Appeals in upholding its state laws governing assignments for the benefit of creditors. Case Law UpdatePaula Lucas Probate exception is not a bankruptcy court limitation. The court found the jurisdiction of the bankruptcy court to be proper where judgment for claim of tortious interference with intent to make a gift was to be entered against beneficiary. Marshall v. Marshall, ___ U.S. ___, 126 S. Ct. 1735, 164 L. Ed. 2d 480 (2006). Don’t Forget to Register for CLLA’s NCBJ Breakfast and Education ProgramFor over a decade, the CLLA has produced two of the most highly regarded programs at the annual National Conference of Bankruptcy Judges. The CLLA educational program is entitled "The Honorable Frank W. Koger Memorial Current Development in Hot & Emerging Areas of Bankruptcy." This program--unequaled in the industry--puts together top-ranked speakers in the field and superior educational materials in order to educate attendees on the latest issues facing bankruptcy professionals. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Sua SponteWhat’s Cooking? As I attempt to gather my thoughts on the events which have occurred during my tenure as Chair of the Executive Council of the Bankruptcy Section, I never cease to be amazed at all that has transpired. This past year has been an especially busy one for the Bankruptcy Section. With the passage of BAPCPA, bankruptcy practitioners have experienced the most sweeping changes in the bankruptcy law in decades. The focus of the Legislative Committee has shifted to providing technical comments on the new law and Interim Rules, which are in their infancy stages. The Section has submitted amicus briefs, numerous Position Papers, has lent support to the National Association of Credit Managers, and has supported the National Association of Bankruptcy Trustees in its efforts at increasing compensation for panel trustees. Despite the drastic changes which have occurred in all of our practices, our members have nevertheless devoted the time required to provide some of the best educational programs which are available anywhere. Telephone seminars were produced to educate our members, as well as potential members, on the new law. Attendance at the DePaul Symposium was at the highest level we have experienced thus far. The educational programs at our meetings were superlative. The Section is moving ahead technologically as well. An online directory for the Section is in the works, and should be a very helpful marketing tool for all of us. The dedication and enthusiasm of many of our members has been overwhelming. To those of you who have done so much to advance the goals of the Section, thank you from the bottom of my heart. I truly appreciate the support and advice which you have provided to me. Last, but certainly not least, I want to thank Erica Henry for stepping up to the plate to provide support to the Council after Sarah Jolie’s departure. Erica has done an outstanding job in helping the Section move forward to set and accomplish many of its goals. The Section has all the ingredients necessary for success—talented and dedicated members, an excellent support system, and a hunger to excel in the bankruptcy field. As I turn the Chair position over to Ivan Reich, I feel confident that he will add just the right spices to the dishes which are currently cooking in order to serve up a smorgasbord feast to satisfy all of our Section members’ appetites. Cathy Pike, Chair Case AnalysesDon’t Wait Until It’s Too Late Children are taught that procrastination is not virtuous and should be avoided because of the potential for adverse consequences. A recent case from the Eighth Circuit Bankruptcy Appellate Panel illustrates how, in the context of consumer bankruptcy relief under the BAPCPA, a failure to act promptly can have harsh legal consequences. In Dixon v. LaBarge (In re Dixon), 338 B.R. 383 (B.A.P. 8th Cir. 2006), the BAP refused to overturn the bankruptcy court’s determination that a debtor was ineligible for bankruptcy relief because he did not receive “briefing” or prebankruptcy counseling prior to his filing a Chapter 13 petition. More specifically, the BAP upheld the bankruptcy court’s order dismissing the debtor’s Chapter 13 bankruptcy case filed on the same day of a scheduled residential mortgage foreclosure sale because the debtor did not satisfy the eligibility requirements under 11 U.S.C. § 109(h), even though he filed a certificate for waiver based on perceived exigent circumstances. One of the sweeping changes brought about by the BAPCPA is a new eligibility requirement that generally requires all individual debtors to receive prebankruptcy counseling during the 180-day period prior to filing. Section 521(b)(1) requires that the debtor file a certificate from a credit counseling agency describing the services provided together with the bankruptcy petition. However, the eligibility provisions of Section 109(h) state two exceptions to this general rule. The first exception serves to excuse debtors from the statutory eligibility prescriptions if the Office of the United States Trustee certifies that there are no approved agencies available to provide adequate services. The second exception, which is the crux of the Dixon case, excepts a debtor from the prebankruptcy counseling eligibility requirements where a certificate is submitted to the Court that In Dixon the bankruptcy court determined that the debtor’s certificate did not warrant a waiver of the prebankruptcy counseling requirements. Mr. Dixon’s certificate detailed factual circumstances he believed were exigent that centered on the impending foreclosure sale of his residence scheduled on the day he filed his petition and his unsuccessful attempt to obtain and complete counseling in the time necessary to file a petition to halt the foreclosure sale proceedings. Unfortunately for Mr. Dixon, he first sought legal advice relative to the foreclosure sale the night before the scheduled sale, leaving him a little less than 18 hours to spare. Following the advice of his newly found legal counsel, Mr. Dixon consulted with a counseling agency about the availability of service, but the agency informed him that it would be two weeks before phone counseling could be provided and 24 hours before internet counseling could be provided. Mr. Dixon’s certificate also stated that he did not have a computer and he had no access to the internet. The critical, undisputed countervailing fact in Dixon was that the debtor had 20 days advance notice of the foreclosure sale, which is mandated by the prevailing Missouri state foreclosure law. The BAP concluded that Congress intended that bankruptcy courts have discretion in determining whether exigent circumstances exist warranting a waiver of the prebankruptcy counseling requirements. The Dixon BAP interpreted Section 109(h) as requiring that a waiver certificate must set forth factual circumstances of an exigent nature in a manner satisfactory to the bankruptcy court and, absent an abuse of discretion, the reviewing court may not disturb a bankruptcy court’s determination of whether circumstances are sufficient to qualify as exigent under the statute. In Dixon, the BAP looked at the debtor’s failure to take appropriate steps to seek relief in the face of the 20-day advance notice of the foreclosure sale and concluded that the pre-filing actions taken by the debtor detailed in his waiver certificate were too little, too late. The inability of the debtor in Dixon to qualify for a waiver of the prebankruptcy counseling requirements occasioned a particularly harsh result because the bankruptcy court determined that the appropriate consequence in such circumstances is for a debtor’s bankruptcy case to be dismissed. The Dixon BAP noted that two courts, In re Childs, 335 B.R. 623 (Bankr. D. Md. 2005) and In re Valdez, 335 B.R. 801 (Bankr. S.D. Fla., 2005), determined that dismissal of the petition was more appropriate than dismissal of the case, and a third case, In re Rios, 336 B.R. 177 (Bankr. S.D.N.Y. 2005), determined that striking the petition was the most appropriate disposition. The immediate consequence of either a case dismissal or a dismissal or striking of the petition is that the automatic stay is not effective. In Dixon, the absence of the stay meant that the debtor’s residential foreclosure sale was permitted to proceed. In addition to rendering the automatic stay immediately ineffective, however, the dismissal of a bankruptcy case also now results in significant limitations on the scope and duration of the automatic stay applicable in the event that the individual debtor attempts to refile bankruptcy within the following year (e.g., after he has obtained the required debt counseling). See 11 U.S.C. § 362(c) (3). By contrast, if the bankruptcy petition is stricken or dismissed, the individual debtor will arguably not be subject to such limitations in the event he subsequently files for bankruptcy relief. Dixon stands for the proposition that exigent circumstances are not created by a debtor’s mere failure to take appropriate, timely action. A debtor must submit a certificate for waiver demonstrating exigent circumstances to the satisfaction of the bankruptcy court to truly justify a deviation from the normal eligibility requirements, which mandate that the debtor receive prebankruptcy counseling. In Dixon, if the debtor had sought advice (and had taken action) promptly after receiving the foreclosure sale notice, the result would probably have been much different, either through satisfaction of the prerequisite prebankruptcy counseling requirements or, if these services were unavailable for some reason, providing a satisfactory basis to substantiate an exigent circumstance waiver request to submit to the bankruptcy court under 11 U.S.C. § 109(h). Francis X. Buckley Jr.
States: 1 – Feds: 1 In the continuing turf war between the state and federal courts, the California Court of Appeal for the Second Appellate District has thumbed its nose at the 9th Circuit Court of Appeals in upholding its state laws governing assignments for the benefit of creditors. Finding that decisions of the lower federal courts on federal questions are persuasive but not binding on state courts, the California Appellate Court in Haberbush v. Charles and Dorothy Cummins Family Limited Partnership, Case No. B175947, disagreed with the decision of the 9th Circuit Court of Appeals in Sherwood Partners v. Lycos, 394 F.3d 1198 (9th Cir. 2005), and ruled that the Bankruptcy Code does not preempt the state law allowing assignees to recover preferential transfers. Sherwood held that the exercise of the preference power by an assignee for the benefit of creditors pursuant to the authority of California Civil Code section 1800 was "inconsistent with the enactment and operation of the federal bankruptcy system and is therefore preempted". The court reasoned that (i) a bankruptcy trustee is appointed by the United States Trustee or elected by creditors, not hand-picked by the debtor, and the avoidance power is exercised under the supervision of the federal courts, all of which protects creditors from the Trustee's conflicts of interest and self dealing; (ii) if an assignee recovers preferences and the case ends up in bankruptcy, the Trustee will then be precluded from recovering the same amounts; and (iii) an assignee's ability to recover preferential transfers goes beyond the powers which can be exercised by individual creditors, and the right to exercise such powers "will affect the incentives of various parties as to whether they wish to avail themselves of federal bankruptcy law". Creditors whose transfers are sought to be avoided will have the incentive to file an involuntary bankruptcy, while others may not wish to invoke the more expensive and time consuming bankruptcy alternative. Taking a stand directly contrary to that of the 9th Circuit, the court in Haberbush found it "impossible to conclude that Code of Civil Procedure section 1800 is inconsistent with 'the essential goals and purposes of federal bankruptcy law…'". The court determined that it is "undisputed" that Congress intended generally to permit the laws governing assignments for the benefit of creditors to coexist with the Bankruptcy Code, and that Code section 544 expressly authorizes a trustee to invoke such state laws governing avoidable transfers. The court went on to find that "the mere fact that a state law 'implicate[s]' the Bankruptcy Code's goal of equitable distribution is not sufficient to justify the conclusion that the state law 'stands as an obstacle' to that goal". Agreeing with the dissent in Sherwood, the court noted that (i) by definition, state assignment laws provide more power to an assignee than can be exercised by creditors individually, and that the Sherwood opinion would then cast doubt on the validity all assignment statutes - a notion which has been rejected by the Supreme Court. See Pobreslo v. Joseph M. Boyd Co., 287 U.S. 518 (1933); Stellwagen v. Clum, 245 U.S. 605 (1918); (ii) it is therefore "illogical that state laws that provide a forum for the equitable distribution of …property should be preempted by federal bankruptcy law"; (iii) if the same transfers can be avoided under both state law and the Bankruptcy Code, how can the state system be deemed to interfere with bankruptcy's goal of equality of distribution; and (iv) "federal regulation should not be deemed preemptive of state regulatory power absent "'persuasive reasons - either that the nature of the regulated subject matter permits no other conclusion, or that Congress has unmistakably so ordained'"". Since Congress has not indicated that state assignment laws, including the right to recover preferences, are specifically preempted, there is no reason to conclude that "California's 'less stigmatic and less costly, voluntary assignment scheme' - which like the federal bankruptcy system, serves to ensure equality of distribution of a debtor's assets - 'stands as an obstacle to the accomplishment…of the full purposes and objectives' of the federal bankruptcy system". Practice Point So what approach do you take when you represent a defendant in a state court preference action? It seems that, as the defendant did in Sherwood, your first approach would be to consider removing the action to federal court, assuming you can establish jurisdiction. In Sherwood, removal was based upon diversity jurisdiction. Query whether the issue of Bankruptcy Code preemption would be sufficient to establish federal question jurisdiction. Moreover, regardless of whether the adversary action is heard in state or federal court, outside the Ninth Circuit, Sherwood is merely persuasive - not binding precedent. In any event, Sherwood would be persuasive in arguing preemption in other jurisdictions, and, at a minimum, in securing negotiating leverage. Of course, the threat of instituting an involuntary bankruptcy can aide in negotiating, but filing the involuntary may only change the forum, and not the result. Clearly, we are a long way from having the Supreme Court or Congress resolve this dispute; for now, the score is tied between the California federal and state courts. Faye B. Feinstein, Esq. Case Law UpdateProbate exception is not a bankruptcy court limitation. The court found the jurisdiction of the bankruptcy court to be proper where judgment for claim of tortious interference with intent to make a gift was to be entered against beneficiary. Marshall v. Marshall, ___ U.S. ___, 126 S. Ct. 1735, 164 L. Ed. 2d 480 (2006). Bankruptcy does not abate insurance policy claim. Plaintiffs initiated action seeking to recover additional money under the insurance policy for property damage and business income losses allegedly sustained as a result of fire. Plaintiff debtors claimed money was property of the estate, requiring the trustees to have filed extensions until the bankruptcy case was heard. Court found there to have been no abatement or injunction against plaintiffs’ rights to initiate suit against defendant, as plaintiffs institution of bankruptcy proceedings did not enjoin or abate action on the policy. Dimaio Family Pizza & Luncheonette, Inv. v. The Charter Oak Fire Ins. Co., 2006 U.S. App. LEXIS 13327 (1st Cir. May 30, 2006) Claim of negligence cannot sustain “deepening insolvency” cause of action. Chapter 7 trustee sued accountant for debtor, which was involved in a Ponzi scheme. District court entered summary judgment in favor of defendants on malpractice and deepening insolvency claims. Affirming, the Court of Appeals concluded that circuit precedent, Official Committee of Unsecured Creditors v. R.F. Lafferty & Co., 267 F.3d 340 (3d Cir. 2001), limited application of deepening insolvency as a cause of action to conduct that is fraudulent and saw “no reason to extend the scope of deepening insolvency beyond Lafferty’s limited holding.” Seitz v. Detweiler, Hershey & Assocs., P.C. (In re CitX Corp.), 2006 U.S. App. LEXIS 13141 (3d Cir. May 26, 2006). No priority for claims against deferred compensation plan. Court properly dismissed participants’ complaint seeking secured, priority status for benefits owed to them under debtors’ deferred compensation plan. Plan was exempt from ERISA’s substantive provisions because it was an unfunded top hat plan. Accardi v. IT Litig. Trust (In re IT Group, Inc.), 2006 U.S. App. LEXIS 13004 (3d Cir. May 25, 2006). State wrongful death judgment not identical to willful and malicious injury. Summary judgment on § 523(a)(6) claim in favor of creditor who obtained pre-petition judgment against debtor in wrongful death action was not proper because issues litigated in state court were not identical to Geiger standard for willful and malicious injury. Duncan v. Duncan (In re Duncan), 2006 U.S. App. LEXIS 12818 (4th Cir. May 24, 2006). PBGC not compelled to correct errors. Errors alleged in estimation of pension benefits due retirees under retirement income plan and ERISA are not grounds to compel the Pension Benefit Guaranty Corporation to make corrections where the claimant pilots failed to utilize administrative remedies available prior to filing suit against bankrupt airline. Boivin v. U.S. Airways, Inc., 2006 U.S. App. LEXIS 10875 (D.C. Cir. May 2, 2006). Valuation for § 722 redemption. New § 506(a)(2), applicable in cases under chapter 7 and 13, effectively overrules cases holding that a liquidation standard was proper valuation standard for redemption under § 722. Thus, prevailing chapter 13 standard for vehicle, starting at NADA value less ten percent, would be applied to determine redemption value in chapter 7 case. In re Mayland, 2006 Bankr. LEXIS 967 (Bankr. M.D.N.C. May 26, 2006). Federal exemptions may fill residency gap. Where debtor was not yet eligible to claim exemption in her current state because of federal 730-day residency requirement and was statutory precluded from claiming exemptions under law of former state of residency, debtor could invoke the federal exemption scheme. In re Underwood, 2006 Bankr. LEXIS 892 (Bankr. N.D. Fla. May 24, 2006). Paula Lucas Don’t Forget to Register for CLLA’s NCBJ Breakfast and Education ProgramFor over a decade, the CLLA has produced two of the most highly regarded programs at the annual National Conference of Bankruptcy Judges. The CLLA educational program is entitled "The Honorable Frank W. Koger Memorial Current Development in Hot & Emerging Areas of Bankruptcy." This program--unequaled in the industry--puts together top-ranked speakers in the field and superior educational materials in order to educate attendees on the latest issues facing bankruptcy professionals. In addition to this program, the Annual CLLA Breakfast is a must-attend during the conference. Number one bestselling author Dr. Michael F. Roizen, well-known founder of the Scientific Advisory Board of RealAge, Inc. and often featured on The Oprah Winfrey Show for his age-defying wisdom, will be the keynote speaker at the 18th Annual Commercial Law League of America Breakfast to be held on November 2, 2006. Are you interested in learning your RealAge? Visit Oprah’s website at the following link, where Dr. Roizen’s RealAge test is featured: http://www.oprah.com/health/lifestages/realage/health_real_main.jhtml Additionally, click here for more information on the CLLA NCBJ programs. Washington Hot NewsAssociation of Credit and Collection Professionals Writes Letter to Senate in Response to H.R. 5576 (July 18) The Association of Credit and Collection Professionals wrote a letter to the Senate July 14th opposing amendments that would prevent the IRS from using its fiscal year 2007 funds to hire private debt collectors. The letter was in response to H.R. 5576, which was passed by the House and contains a rider that prohibits the IRS from funding the program for the fiscal year 2007. The National Treasury Employees Union supported H.R. 5576 because they said the use of private debt collection agencies might put taxpayer privacy at risk. The IRS Commissioner said that using private collection agencies would bring in extra money and help reduce the deficit. As reported previously, Rep. Steven Rothman (D-NJ) asked the Internal Revenue Service on June 19th to stop its private debt collection program until Congress reviews it. H.R. 5576, which passed on June 14th, contains a provision that prevents the IRS from suing appropriated funds to hire private debt collectors. The Internal Revenue Service has said that it must outsource the work due to "budget scoring rules for the agency and because of the inadequate funding from Congress." The IRS projects that private collection would bring in $54 million in fiscal year 2007 in conjunction with IRS collectors. "I simply cannot understand why the IRS would negotiate 22 to 24 percent commission... when this same work done by IRS' own employees costs only 3 percent," Rothman said. NACBA and CFA Collaborate to Oppose Legislation to Raise Bankruptcy Filing Fees (July 14) The National Association of Consumer Bankruptcy Attorneys (NACBA) and the Consumer Federation of America (CFA) collaborated on July 13th to oppose a pending legislative proposal that would raise bankruptcy filing fees for the fourth time in less than one year. H.R. 5585 was approved by the House Financial Services Committee on June 12th and would more than double the fees imposed on bankruptcy filers in order to raise the compensation level for Chapter 7 trustees. "If Congress hikes filing fees yet again, it will likely make a fresh start in bankruptcy unaffordable for some Americans who have experienced genuine financial misfortune," said CFA's Legislative Director. CLLA Comments on Bankruptcy Trustee Fee Legislation (June 30) The CLLA continues to be involved in bankruptcy issues. Recently, the CLLA has provided commentary on legislation to increase the fees for Chapter 7 bankruptcy trustees, also known as "panel" trustees, who play a role in the operation of the bankruptcy system. The current level of compensation for panel trustees is considered low and has not been increased since 1994. Specifically, on June 12th, HR 5585, the Financial Netting Improvements Act of 2006 was introduced (the primary purpose of the bill is to ease systems for mortgages and credit unions). The bill also contains language in Section 7 to increase trustee fees to $100. The bill, as primarily a banking type bill, was referred to BOTH the Financial Services Committee and the Judiciary Committee. Upon introduction, the opinion of the CLLA, along with other bankruptcy organizations, was sought by the House Financial Services and Judiciary Committees. The bill was marked-up (and passed out of) the Financial Services Committee June 14th. There is some question, currently, as to how the House Judiciary Committee plans to deal with the legislation. Ideally, this could land on the House floor in the next month (most likely as part of a bigger Financial Services or Judiciary Committee package). Then it would go to the Senate. IRS Outlines Steps for Prompt Determination of Bankruptcy Estate's Unpaid Tax Liability (June 15) On May 30th, the IRS published in Internal Revenue Bulletin No. 2006-22, Revenue Procedure 2006-24 which provides steps a bankruptcy trustee or a debtor in possession must follow to obtain a prompt determination of any unpaid tax liability of the estate. A prompt determination of any unpaid liability of the estate is requested by filing a signed written request, in duplicate, with the Centralized Insolvency Operation, P.O. Box 21126, Philadelphia, Pa. 19114; the request must be marked "Request for Prompt Determination," and must be accompanied by an exact copy of the return (or returns) for a completed taxable period filed by the trustee with the service. The request must also contain the following information: Within 60 days of receipt of the request, IRS will notify the trustee whether the return filed by the trustee is being selected for examination or is being accepted as filed. House Bill to Increase Judges’ Salaries (June 9) Prior to the Memorial Day recess, House Judiciary Committee Chairman Sensenbrenner (R-WI) introduced H.R. 5454, a bill to authorize salary adjustments for justices and judges of the United States for fiscal 2007. GAO Report Encourages Regulation of Online Sale of SSNs (June 7) According to a recent GAO report, Congress should enact truncating rules for internet resellers of services related to Social Security Numbers to eliminate a potential source of identity theft. In a letter accompanying the report, Social Security Administration Commissioner Jo Anne Barnhart, said, "without a standard truncating method that is widely adhered to, it would be possible for an individual to obtain entire SSNs by purchasing truncated information from one organization that uses the 'first five digit' method and purchasing information concerning the same individual from a second organization that uses the "last four digit' method.” The GAO was able to purchase Social Security numbers from resellers that advertised personal information from drivers' licenses and birth dates to telephone numbers. Bankruptcy RisesBankruptcy filings have declined from about 35,000 per week in 2005 to approximately 10,000 per week this year. However, the number of monthly filings has been slowly increasing this year from 34,411 in January to 43,780 in May. In the first five months of this year a little more than 200,000 filings have been made compared to nearly 700,000 for the same period one-year ago. The 2005 drop-off was due to the full implementation of the "Bankruptcy Abuse Prevention and Consumer Protection Act of 2005" which took effect on October 17th. Bankruptcy filings nose-dived in the first quarter, falling 73% compared to one-year ago and down six-fold sequentially. The number of filings in the first quarter is the lowest number of quarterly filings in the last 20 years. According to CA-based Lundquist Consulting 1Q/06 Chapter 7 consumer filings are 80% lower 1Q/05. According to the Administrative Office of the U.S. Courts, consumer and business bankruptcy filings hit a record 667,431 petitions in the fourth quarter. For monthly figures on bankruptcy filings visit CardData (www.carddata.com). New Credit and Bankruptcy Blog"Credit Slips," a credit and bankruptcy blog, was launched this week. Available at http://www.creditslips.org. blog contributors include Professor Robert Lawless (UIUC), Melissa Jacoby (North Carolina), Angie Littwin (Harvard), Katie Porter (Iowa), John Pottow (Michigan), Debb Thorne (Ohio), and Elizabeth Warren (Harvard). The intended audience includes anyone interested in the laws and policies related to credit and bankruptcy.
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