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Recent Order on Vehicle Repossesion after Re-affirmation Denied In Maryland

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    Recent Order on Vehicle Repossesion after Re-affirmation Denied In Maryland

    IN THE UNITED STATES BANKRUPTCY COURT
    FOR THE DISTRICT OF MARYLAND
    at Greenbelt
    In Re: *XXXXXXXX
    * Case No. 11-XXXXXXX
    * Chapter 7
    *
    *
    Debtor(s) *
    ORDER DECLINING APPROVAL OF REAFFIRMATION AGREEMENT
    This bankruptcy case under Chapter 7 came before the court for approval of the
    Debtor's proposed Reaffirmation Agreement with Mariner Finance, LLC. The court
    held a hearing on June 16, 2011. As a result of the matters developed at the hearing
    and from the Schedules, the court finds as a fact that the presumption of 11 U.S.C. §
    524(m) that this debt is an undue hardship has not been rebutted to the satisfaction of
    this court. However, as in the case of In re Chim, 381 B.R. 191 (BC MD 2008), the
    Debtor has performed his duty under 11 U.S.C. § 521(a)(6) in that he timely filed a
    Statement of Intention and timely entered into the Reaffirmation Agreement. The
    Debtor is not required to surrender the 2004 Hyundai Elantra and 1998 Ford F150 to
    the Creditor, and as pointed out in In re Chim and In re Belanger, 962 F.2d 345, 348
    (CA4 1992), the default-on-filing clause in the installment loan contract is
    unenforceable as a matter of law.
    The court declines to approve the Reaffirmation Agreement. The provisions of
    11 U.S.C. §§ 362(h), 521(a)(6) and 521(d) are inapplicable to this case. The vehicles
    remain property of the estate, the automatic stay remains in place with respect to the
    vehicles until such time as the stay terminates under 11 U.S.C. § 362(c) or (d), the
    Debtor is not obligated to turn over possession of the vehicles to the Lender, and the
    Lender may not exercise remedies as a result of default and any ipso facto clause
    contained in the loan agreement.
    IT IS SO ORDERED.
    cc: Debtor
    Debtor's Counsel
    Chapter 7 Trustee
    Creditor
    End of Order

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