Friday, July 3, 2020

FYI: 7th Cir Holds No FDCPA Violation When Amount of Debt Was Disputed, and Letters Were Sent to Debtors' Counsel

The U.S. Court of Appeals for the Seventh Circuit recently held that a debt collection verification letter that sought to collect interest on a credit card debt for months after the time when the bank that issued the card did not send monthly statements was not false, and would not have misled their attorney, in violation of the federal Fair Debt Collection Practices Act ("FDCPA").

 

A copy of the opinion is available at:  Link to Opinion

 

The consumers defaulted on their credit card debt.  The Bank that issued the card determined that collection was unlikely and stopped sending monthly statements to the consumers, but never told them that "that they no longer owed the money."

 

The Bank sold the debt to a debt collector.  In January 2013, the debt collector sent a letter to the consumers seeking to collect almost $5,800.  The amount sought included about $1,600 in interest for months after the Bank stopped sending monthly statements to the consumers. In March 2013, the debt collector sent a second letter to the consumers demanding $6,200.

 

The consumers hired a lawyer to represent them with respect to the debt. The lawyer asked the debt collector to verify the debt.  In March 2014, the debt collector sent a response to the lawyer verifying the debt stating that $6,320.13 was the balance currently due. 

 

Although the letter did not break out the amount of interest owed, "since the original unpaid debt was only $3,226.35, the letter effectively claimed an entitlement to more than $3,000 in interest, including the $1,600" in interest that the debt collector claimed accrued before it purchased the debt.

 

Eight months after receiving the March 2014 response to their verification request, the consumers filed suit alleging that by demanding interest during the months when the Bank did not send monthly statements, "the debt collector violated 15 U.S.C. section 1692e, which prohibits "any false, deceptive, or misleading representation … in connection with the collection of any debt," including any "false representation of … the character, amount, or legal status of any debt".

 

The trial court found that the first two letters were untimely because they were sent more than a year before the borrower filed suit, and the FDCPA limitation period is one year. 15 U.S.C. §1692k(d). The debt collector sent the third verification letter within a year of the borrower filing suit, but the trial court found that this letter did not violate section 1692e because it was "factual and unproblematic." 

 

Thus, the trial court entered a judgment in the debt collector's favor, and this appeal followed.

 

On appeal, the consumers argued that the letter was "false" or "misleading" because it sought to collect amounts greater than what the debt collector was entitled to collect.  The Seventh Circuit disagreed. 

 

Instead, the Seventh Circuit held that the consumers promised to pay interest on their credit card, and there is no evidence that the debt collector used the incorrect interest rate. The credit card agreement expressly "provided that the Bank's inaction or silence would not waive any of its rights."  Thus, the claim that the debt collector pursued "is not one that any careful debt collector would know to be unenforceable."

 

Whether failing to send monthly statements together with 12 C.F.R. §1026.5(b)(2)'s requirement to mail or deliver a periodic statement for each billing cycle prevents collecting interest for the months before the Bank sold the debt is an unresolved "topic for litigation."  However, a demand for payment is not "false" simply because a court may letter disagree with a debt collector's calculation of the amount owed. Instead a "statement is false, or not, when made; there is no falsity by hindsight."

 

The Seventh Circuit held that the letter also did not violate section 1692e because the debt collector sent it to the consumers' lawyer.  Under Bravo v. Midland Credit Management, Inc., 812 F.3d 599, 603 (7th Cir. 2016), the test under section 1692e "for a letter to counsel is whether it would deceive or mislead a competent attorney." 

 

Here, if the consumer's counsel disagreed with the amount claimed in the verification letter, then he could have followed up with the debt collector or told his clients not to pay the disputed amount. The Seventh Circuit noted that the debt collector "did not need to explain to a lawyer something that the first two letters revealed, and it certainly did not need to provide a disquisition on the non-waiver clause in the contract or [its] take on 12 C.F.R. §1026.5(b)(2)."  This is because verifying a debt should "be a simple process, not an occasion for a legal brief."

 

The Seventh Circuit acknowledged a circuit split on this issue. The Second, Eight, and Tenth Circuit agree with the Seventh Circuit regarding the standard for evaluating correspondence sent to counsel. See, e.g., Kropelnicki v. Siegel, 290 F.3d 118, 128 (2d Cir. 2002); Powers v. Credit Management Services, Inc., 776 F.3d 567, 573–75 (8th Cir. 2015); Dikeman v. National Educators, Inc., 81 F.3d 949, 953–54 (10th Cir. 1996). The Third and Eleventh Circuits disagree. See, e.g., Simon v. FIA Card Services, N.A., 732 F.3d 259, 269–70 (3d Cir. 2013); Bishop v. Ross Earle & Bonan, P.A., 817 F.3d 1268, 1277 (11th Cir. 2016).

 

However, the Seventh Circuit saw no reason to abandon the standard it set it Bravo.

 

Here, the verification letter could not have misled a competent lawyer because a competent lawyer "would not deem false a demand by a potential opponent in litigation just because counsel believes that his client may be able to persuade a judge that there is a defense."

 

Thus, the Seventh Circuit affirmed the trial court's judgment order dismissing the suit.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Thursday, July 2, 2020

FYI: 7th Cir Holds FCRA Requires Furnishers to Correctly Report Liability, But Not CRAs

Agreeing with similar rulings in the First, Ninth, and Tenth Circuits, the U.S. Court of Appeals for the Seventh Circuit recently held that the FCRA does not require consumer reporting agencies to determine the legal validity of disputed debts.

 

A copy of the opinion is available at:  Link to Opinion

 

Two borrowers obtained loans from online payday lenders affiliated with Native American tribes. The loans charged interest in excess of 300% and the terms were subject to and governed by tribal law and not the law of the borrower's resident state.

 

After the borrowers stopped making the monthly payments, the lenders reported the delinquent amounts to a credit reporting agency. One of the borrowers contacted the credit reporting agency and disputed the accuracy of his credit reports because the loan was "illegally issued" such that "there was no legal obligation for [him] to repay." The credit reporting agency investigated the dispute and verified the accuracy of the information provided by the lender. The other borrower never contacted the credit reporting agency.

 

The borrowers brought a putative class action against the credit reporting agency, alleging it violated two FCRA provisions: 15 U.S.C. § 1681e(b) -- which requires consumer reporting agencies "to assure maximum possible accuracy of the information" contained in credit reports = and 15 U.S.C § 1681i(a) -- which requires consumer reporting agencies to reinvestigate disputed items.

 

The plaintiffs' claims under each provision presumed that the credit reporting agency transmitted "inaccurate" credit reports.  The borrowers did not claim that the credit reports were factually inaccurate and they did not contest the debt amounts or payment history. Instead, the borrowers claimed the credit reports contained "legally inaccurate" information because the loans were void ab initio under New Jersey and Florida usury laws and therefore "legally invalid debts."

 

For their § 1681e(b) claim, the borrowers contended the credit reporting agency "knew or recklessly ignored" that loans made by lenders were unenforceable, because (1) credit reporting agency's lender screening procedures showed that the lenders lacked licenses to lend outside of Native American tribal reservations, (2) the same screening procedures showed that the lenders had histories of charging loan interest rates in excess of rates permitted in New Jersey and Florida, and (3) the credit reporting agency allegedly ignored government investigations and enforcement actions in several states — though none of them were in New Jersey or Florida — from which the borrowers alleged "[the credit reporting agency] easily could and should have discovered" that the lenders made illegal loans.

 

For their § 1681i(a) claim, the borrower who disputed the debt contended the credit reporting agency "failed to use reasonable reinvestigation practices for ascertaining the accuracy of information" contained in his credit report after he disputed the debt.

 

The credit reporting agency moved for judgment on the pleadings, arguing that §§ 1681e(b) and 1681i(a) impose a duty to transmit factually accurate credit information, not to adjudicate the validity of disputed debts.

 

The trial court granted the credit reporting agency's motion, concluding that "[u]ntil a formal adjudication invalidates the plaintiffs' loans … they cannot allege factual inaccuracies in their credit reports."

 

The borrowers appealed.

 

The Seventh Circuit first analyzed § 1681e(b), which requires that "[w]henever a consumer reporting agency prepares a consumer report it shall follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates." 15 U.S.C. § 1681e(b). The statute requires a plaintiff to show that a consumer reporting agency prepared a report containing "inaccurate" information. See Walton v. BMO Harris Bank N.A., 761 F. App'x 589, 591 (7th Cir. 2019) (holding a consumer reporting agency "cannot be liable as a threshold matter [under § 1681e(b)] if it did not report inaccurate information").

 

The borrowers argued that § 1681e(b) requires consumer reporting agencies to verify the factual and legal accuracy of information contained in credit reports, requiring the consumer reporting agencies to look beyond the data furnished and determine the legality of borrower's loans.

 

The Seventh Circuit noted the FCRA does not require unfailing accuracy from consumer reporting agencies. Instead, it requires a consumer reporting agency to follow "reasonable procedures to assure maximum possible accuracy" when it prepares a credit report. 15 U.S.C. § 1681e(b); see also Henson v. CSC Credit Servs., 29 F.3d 280, 284 (7th Cir. 1994) ("A credit reporting agency is not liable under the FCRA if it followed 'reasonable procedures to assure maximum possible accuracy,' but nonetheless reported inaccurate information in the consumer's credit report.").

 

The Court noted that is a different "accuracy" measure than furnishers are required to adhere. "Accuracy," for furnishers means information that "correctly [r]eflects … liability for the account." 12 C.F.R. § 1022.41(a). Neither the FCRA nor its implementing regulations impose a comparable duty upon consumer reporting agencies, much less a duty to determine the legality of a disputed debt.

 

The Seventh Circuit held that what the borrowers called "legally inaccurate" and "legally incorrect" information amounted to nonadjudicated legal defenses to their debts and only a court can fully and finally resolve the legal question of a loan's validity. See DeAndrade v. Trans Union LLC, 523 F.3d 61, 68 (1st Cir. 2008) (holding the question of whether a consumer is entitled to stop making debt payments "can only be resolved by a court of law" and is "a legal issue that a credit agency such as Trans Union is neither qualified nor obligated to resolve under the FCRA").

 

The Seventh Circuit joined the First, Ninth, and Tenth Circuits in holding that a consumer's defense to a debt "is a question for a court to resolve in a suit against the [creditor,] not a job imposed upon consumer reporting agencies by the FCRA." Carvalho, 629 F.3d at 892 (quoting DeAndrade, 523 F.3d at 68); accord Wright v. Experian Info. Sols., Inc., 805 F.3d 1232, 1244 (10th Cir. 2015) (citing Carvalho, 629 F.3d at 892) ("The FCRA expects consumers to dispute the validity of a debt with the furnisher of the information or append a note to their credit report to show the claim is disputed.").

 

Therefore, because no formal adjudication discharged the borrowers' debts, the Court held that no reasonable procedures could have uncovered an inaccuracy in borrower's credit reports.

 

The Seventh Circuit concluded the borrowers' § 1681i claim ran into the same problems.

 

The court held that, when a consumer disputes the "accuracy of any item of information" contained in a credit report, § 1681i requires consumer reporting agencies to "conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate." 15 U.S.C. § 1681i(a)(1)(A). Like § 1681e(b), § 1681i requires the "accuracy" of information but does not differentiate between factual and legal accuracy. Yet "one of the most basic rules of statutory interpretation" is that "identical words used in different parts of the same act are intended to have the same meaning." OrtizSantiago v. Barr, 924 F.3d 956, 962 (7th Cir. 2019) (quoting Sorenson v. Sec'y of Treasury, 475 U.S. 851, 860 (1986)).

 

Accordingly, as with borrower's § 1681e(b) claim, the Seventh Circuit interpreted inaccurate information under § 1681i to mean factually inaccurate information, as consumer reporting agencies are neither qualified nor obligated to resolve legal issues.

 

As a result, the trial court's entry of judgment on the pleadings was affirmed.

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Tuesday, June 30, 2020

FYI: SCOTUS Holds CFPB Unconstitutionally Structured, But May Continue to Operate

The Supreme Court of the United States recently vacated the judgment of the U.S. Court of Appeals for the Ninth Circuit that rejected constitutional challenges to the design and structure of the Consumer Financial Protection Bureau (CFPB).

 

By a 5-4 majority vote, the SCOTUS concluded that protections afforded to the CFPB's single director as removable by the President only "for cause" -- that is, for "inefficiency, neglect of duty, or malfeasance in office" -- violated the separation of powers under the United States Constitution.  However, a 7-2 majority concluded that the director's "for cause" removal protection was severable from the remainder of the Dodd-Frank Act that created the CFPB, allowing the CFPB to continue to operate.

 

Therefore, in the words of the Court, the CFPB may "continue to operate, but its Director, ... must be removable by the President at will."

 

A copy of the opinion is available at:  Link to Opinion

 

A law firm that provides debt-related legal services (Law Firm) was subjected to a 2017 civil investigative demand (CID).  The Law Firm filed suit in federal court asserting that the CFPB's structure violates the U.S. Constitution's separation of powers doctrine, and lacked statutory authority to issue the CID. 

 

After the CFPB prevailed in the trial court and the Law Firm was ordered to respond to the CID, the Ninth Circuit upheld the CFPB's structure on appeal.  Consumer Fin. Prot. Bureau v. Seila Law LLC, 923 F.3d 680 (9th Cir. 2019). 

 

The Supreme Court of the United States granted certiorari to address the Law Firm's assertions. 

 

The two questions before the SCOTUS were: (i) whether the provision in Title X of the Dodd-Frank Act restricting the President's removal of the CFPB director only "for cause" violates the Constitution's separation of powers, and; (ii) if the provision is unconstitutional, whether the CFPB director's removal protection is severable from the other statutory provisions bearing on the CFPBs authority.

 

Reviewing the structure of the CFPB established by Title X of the Dodd-Frank Act, the Supreme Court noted that Congress' design of the CFPB elected to place the CFPB under the leadership of a single director appointed by the President with the advice and consent of the Senate, in contrast to a traditional independent agency headed by a multimember board or commission.  12 U. S. C. §§ 5491(b)(1)-(2).  Further, the CFPB's Director serves a five-year term, during which the President may remove the Director from office only for "inefficiency, neglect of duty, or malfeasance in office." §§ 5491(c)(1), (3).

 

The SCOTUS first considered the arguments raised by the amicus curiae, appointed by the Court to defend the Bureau's constitutionality because the Department of Justice chose not to do so.  The amicus argued (i) that the CID is not "traceable" to the alleged constitutional defect because two of the three Directors who have in turn played a role in enforcing the demand were (or now consider themselves to be) removable by the President at will;  (ii) that the proper context for assessing the constitutionality of an officer's removal restriction is a contested removal, and; (iii) that the case should be dismissed for lack of "adverseness" because the primary parties agreed on the merits of the constitutional question. 

 

Finding none of these arguments persuasive, the Court turned to the merits of the petitioner Law Firm's constitutional challenge.

 

The SCOTUS initially noted the long history and precedent confirming the President's removal power afforded under Article II of the Constitution which "grants to the President" the "general administrative control of those executing the laws, including the power of appointment and removal of executive officers."  Myers v. United States, 272 U. S. 52, 163-164 (1926).  More recently, the President's general removal power was reiterated in Free Enterprise Fund v. Public Company Accounting Oversight Bd., 561 U. S. 477 (2010). 

 

In Free Enterprise Fund, the Supreme Court recognized that it had previously upheld certain congressional limits on the President's removal power, but declined to extend those limits to "a new situation not yet encountered by the Court."  561 U. S., at 483.

 

Free Enterprise Fund left in place only two exceptions to the President's unrestricted removal power: (i) permitting Congress to give for-cause removal protection to a multi-member body of experts balanced along partisan lines, appointed to staggered terms, and performing only "quasi-legislative" and "quasi-judicial functions (Humphrey's Executor v. United States, 295 U. S. 602 (1935)) and; (ii) for-cause removal protection for an independent counsel with limited duties and no policymaking or administrative authority (Morrison v. Olson, 487 U. S. 654 (1988)).

 

Notably, Humphrey's Executor and Morrison were the opinions the Ninth Circuit deemed "controlling" in its opinion, in which the Ninth Circuit agreed with the D.C. Circuit's ruling upholding of the constitutionality of the CFPB in PHH Corp. v. CFPB, 881 F. 3d 75 (2018), which in turn had rejected a challenge similar to the one presented here. 

 

However, the SCOTUS found these cases were distinguishable and did not resolve whether the CFPB Director's insulation from removal was unconstitutional.

 

The Supreme Court declined to extend these exceptions to the "new situation" at issue here.  The Court noted that Congress provided removal protection to principal officers who alone wield power in only four isolated incidences which do not involve regulatory or enforcement authority comparable to that exercised by the CFPB.  The Court also noted that the single-director configuration is also incompatible with the structure of the Constitution, which "with the sole exception of the Presidency" scrupulously avoids concentrating power in the hands of any single individual. 

 

Accordingly, the Court concluded that the CFPB's leadership by a single independent Director violates the Constitution's separation of powers.

 

Having reached this conclusion, the Supreme Court was left to decide whether the Director's removal protection was severable from the other provisions of the Dodd-Frank Act that establish the CFPB.  The SCOTUS concluded that the CFPB could continue to exist and operate notwithstanding Congress' unconstitutional attempt to insulate the agency's Director from removal by the President.

 

The Court recited long-settled precedent that declaration of one section or portion of a statute as unconstitutional does not act to void the statute in whole, and that "even in the absence of a severability clause, the "traditional" rule is that "the unconstitutional provision must be severed unless the statute created in its absence is legislation that Congress would not have enacted."  Alaska Airlines, Inc. v. Brock, 480 U. S. 678, 685 (1987).

 

The SCOTUS was again guided by its holding in Free Enterprise Fund, wherein it found a set of unconstitutional removal provisions severable in the absence of an express severability clause because the surviving provisions were capable of functioning independently. 

 

Similarly, here, the Court concluded that the structure and duties of the CFPB as provided under the Dodd-Frank Act remained fully operative without the offending tenure restriction, and was severable from the other provisions of Dodd-Frank that establish the CFPB. 

 

Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded for the Court of Appeals to consider whether the CID was ratified by an Acting Director accountable to the President.

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Tennessee   |   Texas   |   Washington, DC

 

 

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Sunday, June 28, 2020

FYI: 9th Cir Allows Chpt 13 Bankruptcy Plans With Estimated Durations

The U.S. Court of Appeals for the Ninth Circuit recently held that bankruptcy courts could confirm Chapter 13 plans proposing estimated time periods to complete the plan if unsecured creditors and the trustee did not object, reversing a contrary ruling from its Bankruptcy Appellate Panel ("BAP").

 

A copy of the opinion is available at:  Link to Opinion

 

Multiple debtors filed Chapter 13 bankruptcies. The debtors proposed payment plans largely conformed to the court's model plan. However, they relied on the court's prior model to replace the current model's fixed durational language with estimated time periods and to add an alternative provision that unsecured nonpriority creditors would receive "an aggregate dividend of $0." Neither the trustee nor any unsecured creditor objected to the proposed plans.

 

Despite the lack of any objection, the bankruptcy court conducted multiple hearings and ultimately rejected the debtors' proposed plan amendments. The court held that confirming plans with estimated lengths would effectively allow debtors to modify their plans without court approval.

 

To illustrate its concerns, the court pointed to two debtors who anticipated an increased income during the plan's timeframe. With their increased income, the debtors could pay off their secured and priority creditors, and -- because of the plan's estimated timeframe -- they could receive their discharge without seeking any amendment to their plan. The bankruptcy court found that this would improperly eliminate any opportunity for their unsecured nonpriority creditors to receive payment on their claims despite the increase in their income.

 

The BAP affirmed, but the Ninth Circuit reversed.

 

The Ninth Circuit first considered its jurisdiction to hear the appeal, noting the debtors' need under the U.S. Supreme Court's Spokeo ruling to demonstrate an injury in fact both "concrete and particularized" and "actual or imminent, not conjectural or hypothetical." The Court found that the debtors could suffer economic harm from being forced into a Chapter 13 plan with a fixed duration, because the fixed duration plan could result in them making additional payments to both unsecured creditors and the trustee beyond those they would have made in a plan with an estimated duration. The Court determined that these potential harms constituted sufficiently concrete and particularized injury for it to exercise jurisdiction over the appeal.

 

The Ninth Circuit next turned to the substance of the appeal, holding that no express provision of Chapter 13 prohibits plans with estimated lengths. The Court noted that only two provisions of Chapter 13 expressly discuss plan duration. Section 1322 imposes a maximum duration of five years for above-median-income debtors and three years for below-the-median debtors. Section 1325 mandates a fixed minimum duration, but only if the trustee or a creditor object to the plan.

 

Construing these provisions together, and noting on more than one occasion that section 1325 only requires the fixed minimum duration where the trustee or a creditor objects, the Ninth Circuit found that the statutory language did not impose a fixed minimum duration where the trustee or a creditor does not object to the plan. It also found that neither section prohibits estimated term plans. Noting that section 1325 explicitly imposes a minimum duration only when an objection is raised, the Court found that the section strongly suggests Congress intentionally chose not to include fixed terms for plans that do not draw objections.

 

The Ninth Circuit also considered the language in section 1329, which allows debtors, trustees, and unsecured creditors to modify bankruptcy plans at any time before the debtor completes payments. It declined to follow the BAP's conclusion that section 1329 prohibits debtors from unilaterally modifying their plans, which the BAP determined estimated term provisions effectively allow. Rather, the Court found that estimated term provisions allow the debtor to seek an early discharge, not modify the plan. It also noted that unsecured nonpriority creditors could still seek to modify the plan at any point before the debtors' discharge, as well as object to the plan to preclude an estimated timeframe before confirmation.

 

The Court further rejected the BAP's public policy rationale that fixed plan durations conformed to Congress's purposes in enacting the Bankruptcy Abuse Prevention and Consumer Protection Act ("BAPCPA") to ensure that debtors repay creditors the maximum they can afford. The Ninth Circuit expressed doubt that Congress intended a "pro-unsecured creditor" policy in crafting BAPCPA, and it found that "BAPCPA's purpose, whatever that may be, should not guide" the Court's interpretation. Although the Court recognized the possibility that requiring fixed minimum terms may better serve creditors, it held that "this does not give courts license to judicially amend Chapter 13's requirements."

 

The Ninth Circuit additionally found that the debtors did not propose the plan in bad faith, overruling the BAP's finding that debtors proposing estimated time periods unfairly manipulated the Bankruptcy Code. The Court reiterated earlier rulings that the good faith inquiry is not a vehicle to promulgate bankruptcy requirements not in the Code, and that debtors do not act in bad faith merely for doing what the Code permits them to do. It also noted that the BAP's bad faith finding would necessarily mean debtors using bankruptcy court's prior model -- which specifically allowed estimated plan durations -- unfairly manipulated the code for years before the bankruptcy court updated its model.

 

Finally, the Ninth Circuit disagreed with the debtors' position that the bankruptcy court violated the Code by taking more than forty-five days to rule on the debtors' plans and by holding hearings despite the lack of any objection. The Court found that the Chapter 13 only requires bankruptcy courts to hold a hearing within forty-five days, not conclude the hearing. It also found that bankruptcy courts have an independent duty to ensure plans conform to the Code even when no party objects, and that they have discretion to manage their dockets to aid their inquiry.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


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