Bankruptcy

Asset Protection

Florida law provides considerable asset protection benefits to people that permanently reside in Florida.

Pension and Profit Sharing Plans, IRAs

To prepare for retirement and to defer income taxation many direct significant wealth into IRA accounts and other tax qualified retirement plans. In Florida, retirement money not only defers income taxation, but it is protected from creditors as well. Section 222.21(2)(a) of the Florida Statutes provides that any money or other assets payable to participant or beneficiary in a qualified retirement or profit sharing plan is exempt from all claims from creditors of the beneficiary or participant. A debtor’s IRAs, both rollover and inherited IRA accounts, are exempt from creditors.

​Disability Income

Disability income benefits under any disability insurance policy are exempt from legal process in Florida. The exemption includes health, life, and accident disability insurance. Further, federal law protects Social Security Disability benefits from judgment creditors.

​Life Insurance Policies and Annuity Contracts

Cash value in insurance policies and all annuities are protected from creditors’ claims by Section 222.14 of the Florida Statutes. While a Florida resident is alive, the cash value of their insurance policy on their life or on another Florida resident is exempt from creditors’ claims. The protection afforded to the cash surrender value of a life insurance policy is only for the benefit of the owner/insured. Death benefits are not protected from the creditors of the policy beneficiary. The law does not protect the cash value of life insurance when the insured is someone other than the debtor; for instance a wife cannot exempt the cash value of a policy issued on the life of her spouse or child.

Perhaps the most popular financial product for asset protection planning is an annuity. Annuities are exempt from creditors pursuant to Section 222.13 of the Florida Statutes. Florida courts have liberally construed this statutory exemption to include the broadest range of annuity contracts and arrangements. Private annuities between family members are entitled to the exemption as are the proceeds of personal injury settlements structured as an annuity. Additional protection is available by purchasing international annuities. Particularly, Switzerland and Liechtenstein have laws which guard annuities from attack by creditors for outside countries including the United States

The protection of cash value of life insurance and annuities extends to proceeds of these assets after receipt. Florida courts have held that funds withdrawn from the cash value of a life insurance policy and annuity payments received by a debtor remain protected after they are deposited in a financial account as long as the funds can be accurately traced back to the exempt assets. The money does not have to be segregated in a separate account so long as it is traceable.

Only annuities issued to Florida residents in Florida are exempt. A current Florida resident who purchased an annuity in another state prior to moving to Florida may find that his annuity is not exempt from creditors when neither the prior state’s laws nor the terms of the annuity contract protect the annuity and its proceeds.

​Prepaid College Plans

Florida prepaid college tuition plans and Florida’s 529 College Saving Plan are protected from creditors under Section 222.22 of the Florida Statutes.

​Automobile Exemption

Under Florida law, residents may protect up to $1,000 of equity in an automobile. Florida has one of the lowest automobile allowances in the country. The fact that a debtor needs their vehicle for work does not protect the vehicle from creditors to the extent that the debtor’s equity (value less loan amount) exceeds $1,000.

​Miscellaneous Exemptions

Florida Statutes include several narrow asset exemptions such as professionally prescribed health aids, hurricane savings accounts (with restrictions), medical savings accounts, and unemployment benefits. A debtor’s bank account held in a custodian financial account for the benefit of a minor child under the Florida Uniform Transfers To Minors Act is also protected from the debtor’s creditors because the account is considered property of the minor beneficiary.

​Salary or Wages

Wages, earnings, or compensation of the head-of-household which are due for personal labor or services, including wages deposited into a bank account (provided they are traceable and identified as such) are exempt from garnishment under Section 222.11 of the Florida Statutes. A debtor is head-of-household if they financially support someone for which they have a legal or moral support obligation, such as a spouse, child, or parent. The dependent does not have to reside in the debtor’s primary residence. When a married couple is joint judgment debtors, only one spouse can be head-of-household. You may support someone for purposes of establishing head-of-household status even if you do not claim that person as a tax dependent on your federal income tax return. A debtor can waive wage exemption provided the waiver is informed and done in writing. The waiver is limited under federal law. Most often banks and lenders include head-of-household exemption waivers in the loan documents, thus entitling the creditor to garnish wages to execute a judgment even though the debtor is a head-of-household.

​Application In Other States

Florida exemptions have no extraterritorial effect. Florida residents cannot export Florida exemptions to protect tangible and intangible personal property located in states other than Florida. Florida residents who work and maintain accounts or other property outside of Florida are subject to the exemption laws where of the state where the work is performed and the property is situated. Financial accounts are situated at the branch office where the account is maintained. For example, if a New York resident opens an IRA account at a New York branch of a national brokerage, and the same person subsequently moves to Florida, the IRA account may not be exempt because it is deemed to be anchored at the branch where it was opened. This person should move the account to a Florida branch of the same brokerage house or to a new broker with Florida offices. Further, wages earned in another state may be subject to that state’s laws for garnishment and not receive the same protection as afforded under Florida law.

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Fraudulent Transfers

A fraudulent conveyance is simply defined as an infringement of the creditor’s right to realize upon the available assets of the debtor. More particularly, it is fraudulent for a debtor to transfer its assets to a third party with intent to either actually or constructively obstruct creditors from reaching the assets to satisfy claims.

​Fraudulent transfers of assets in Florida are governed by Florida’s adaptation of the Uniform Fraudulent Transfer Act, Chapter 726, Florida Statutes (hereinafter “FUFTA”). The transfer of assets that are not exempt from the claims of creditors into assets that are exempt from the claims of creditors, is governed by Florida’s fraudulent conversion statute, §§ 222.29-222.30, Florida Statutes.

​A claim seeking relief pursuant to FUFTA is a claim arising out of equity, and is not an action at law. Accordingly, none of the creditor, the debtor, or any affected third parties are entitled to a jury trial for the issues raised by the claim.

​A fraudulent transfer as to present or future creditors is defined by FUFTA as:

(1) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor, whether the creditor’s claim arose before or after the transfer was made or the obligation was incurred, if the debtor made the transfer or incurred the obligation:

(a) With actual intent to hinder, delay, or defraud any creditor of the debtor; or

(b) Without receiving a reasonably equivalent value in exchange for the transfer or obligation, and the debtor:

1. Was engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small in relation to the business or transaction; or
2. Intended to incur, or believed or reasonably should have believed that he or she would incur, debts beyond his or her ability to pay as they became due.

 Florida Statute §726.105(1). ​

Additionally, with respect to present creditors, a fraudulent transfer is further defined by FUFTA as follows:

(1) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation.

(2) A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent.

Florida Statute §726.106. ​

Florida Statute §222.29 provides: An exemption from attachment, garnishment, or legal process provided by this chapter [Chapter 222, Exemptions] is not effective if it results from a fraudulent transfer or conveyance as provided in chapter 726.

​Florida Statute §222.30 adds the following:

(2) Any conversion by a debtor of an asset that results in the proceeds of the asset becoming exempt by law from the claims of a creditor of the debtor is a fraudulent asset conversion as to the creditor, whether the creditor’s claim to the asset arose before or after the conversion of the asset, if the debtor made the conversion with the intent to hinder, delay, or defraud the creditor.

​When construing the above provisions, the Florida Supreme Court has determined that these statutory provisions, allowing creditors to attack fraudulent conversions of assets from non-exempt to exempt, rightfully apply to all statutory exemptions other than the Constitutionally protected homestead exemption.

​A creditor is merely a person who “has a claim”. As defined in Florida Statute §726.102, a “claim” is broadly constructed and “means a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured, or unsecured” (Florida Statute §726.102(3)). It is well settled in Florida that a “claim” under the Act may be maintained even though “contingent” and not yet reduced to judgment.

​FUFTA sets forth, in § 726.110, time limits within which specific actions must be commenced. For transfers made with actual intent to defraud, hinder or delay creditors, the action must be commenced within four years of the transfer or, if later, within 1 year of discovery. Action must be brought within 4 years of the transfer if the debtor does not receive reasonably equivalent value for the transfer and (1) the debtor is engaged (or about to engage) in a business for which the remaining assets are unreasonably small in relation to the business or the debtor knows he/she will be unable to meet his/her debts, or (2) the debtor was insolvent at the time or became solvent as a result of the transfer. Action must be brought within 1 year for transfers made to an insider for an antecedent debt at a time when the debtor was insolvent and the insider had reasonable cause to believe that the debtor was insolvent.

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Bankruptcy – The Basics

Who can file bankruptcy? Any person who resides, domiciled, or having property or a place of business in the United States may file for bankruptcy relief.

​What is a Chapter 7 bankruptcy?

Chapter 7 bankruptcy is the most common type of bankruptcy and is often referred to as a “liquidation bankruptcy.” In Chapter 7, all of the debtor’s assets, other than those types of assets specifically exempt from liquidation by statute, are turned over to a bankruptcy trustee for sale. Sale proceeds, if any, are distributed among the creditors. Most Florida Chapter 7 debtors have little non-exempt personal property because of Florida’s liberal exemption laws. Chapter 7 bankruptcy is used to eliminate, or discharge, primarily unsecured debts such as credit cards or medical bills. Chapter 7 does not eliminate secured debts, such as vehicles (unless the secured item is surrendered). Chapter 7 will not save a house from foreclosure or a car from repossession if you are delinquent in payments. Under the new bankruptcy law, only people who pass the “means test” may file a Chapter 7 bankruptcy. People who fail the means test have to file Chapter 13 bankruptcy provided you are under Chapter 13 debt ceilings. The means test is a complicated mathematical formula. Your bankruptcy attorney can run a means test using bankruptcy software after he collects necessary information from you. 

What is a Chapter 13 bankruptcy?

Chapter 13 bankruptcy results in a plan to repay all or part of your debt, but it is not designed to discharge or eliminate most debts. Chapter 13 is used most often to save a house from a foreclosure sale. You can use Chapter 13 to “strip” a second mortgage under certain circumstances. Chapter 13 is also useful to eliminate some IRS debt and to establish an affordable plan to pay IRS debt that cannot be eliminated. Chapter 13 bankruptcy is available to debtors with regular income. A business cannot file Chapter 13. In addition, there are upper limits on the amount of the individual’s secured and unsecured debts in Chapter 13 cases.​

Bankruptcy – Before Filing

Unfair Debt Collection

The Federal Fair Debt Collection Practices Act (the “Act”) prohibits unfair collection of consumer debts. If you can prove that your creditors intentionally and repeatedly violated the Act before or after you retained your bankruptcy attorney, you may be able to recover damages. The following is a summary of a few prohibited debt collection practices:

1. Calling you before 8 a.m. or after 9 p.m. local time.
2. Contacting you directly after you told the creditor you retained an attorney to represent you.
3. Telling your employer or co-worker that you owe money to the creditor.
4. Calling you at work after you have told them not to.
5. Intentional and continuous harassment or abuse in connection with a debt.
6. A creditor’s representative falsely representing that he is an attorney when in fact he is not licensed to practice law.
7. Threatening you with arrest or imprisonment for failing to pay a debt.
8. Communicating with anyone other than you our your spouse about your debt.

The debt collection laws are complicated, and your right to recovery will depend on your specific facts and your evidence. Contact your bankruptcy attorney if you believe you can prove one of your creditors intentionally and repeatedly engaged in unfair collection practices. A copy of the complete Act is available at http://www.ftc.gov under Consumer Information.

​Use of Credit Cards.

Do not use any credit cards after the initial consultation with your bankruptcy attorney or once you have decided to file bankruptcy. If you have charges or cash advances in the months preceding filing bankruptcy, the creditor may file an adversary complaint alleging that you incurred recent charges with fraudulent intent and without the intent and/or ability to repay these debts.

​Relatively recent changes in the bankruptcy law (effective October 17, 2005) has complicated the bankruptcy process. Revisions to the bankruptcy laws have instituted stricter rules with regard to qualifying for bankruptcy relief, while implementing new court rules, forms, and additional work for debtors and legal counsel. With the revisions to the bankruptcy laws, the rules and procedures are sometimes confusing, ambiguous and subject to multiple interpretations. The information contained herein is specific to cases filed in the Middle District of Florida. This basic information should assist you in understanding the course of events that occur when you file bankruptcy. The information is provided for informational purposes only, and you are strongly encouraged and recommended to secure the advise of legal counsel before making any decisions. This website information does not replace or modify any separate written agreement with or written information provided to clients of Campione & Hackney, P.A.

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Chapter 7 Bankruptcy

Part 1

Filing Chapter 7 Bankruptcy in Florida – Exceptions and Residency

A permanent resident of Florida can file bankruptcy in a Florida bankruptcy court. Florida has three bankruptcy districts (Southern District, Middle District, and Northern District), and each of Florida’s counties is assigned to one of the three bankruptcy districts. You must file bankruptcy in the district where you reside.

​An important concept in both Chapter 7 and Chapter 13 bankruptcy is “exemptions” or “exempt property.” When you file a Chapter 7 bankruptcy, the Trustee takes all of your “non-exempt” property and sells it for the benefit of your unsecured creditors. The Trustee cannot take your exempt property and you may keep all of your exempt property regardless of its value and amount. What property is “exempt” and what property is “non-exempt” depends on the exemption laws of the applicable state. Each state has its own and different laws about what assets are exempt and non-exempt for bankruptcy purposes. Therefore, before you file bankruptcy you and your bankruptcy attorney must ascertain which state laws will determine your exempt assets.

Florida has liberal bankruptcy exemptions for some assets, including an unlimited homestead exemption in most cases, and limited exemptions for other assets. Only Florida residents are eligible for Florida exemptions. Just because you are a Florida resident when you file for bankruptcy does not mean you are entitled to Florida exemptions in bankruptcy.

Under the bankruptcy laws the state exemption law applicable to your bankruptcy is determined by the state in which you have been domiciled for the 730 days (two years) immediately preceding your filing date. If you have not been a permanent resident of Florida for the two-year period immediately preceding your bankruptcy, then your bankruptcy exemptions will be those allowed by the state in which you were domiciled for 180 days immediately preceding the two year period, or the state in which you were domiciled for the longer portion of such 180-day period. Otherwise stated, a person filing bankruptcy in Florida today is eligible for the property exemptions he could have claimed if he had filed two years ago. If this person was a Florida resident two years ago he claims Florida exemptions today; if two years ago he was a resident of a different state then he is entitled to the exemptions of the state of his prior residence.

Consider a person who sells his residence in Georgia for $100,000 and moves to Florida in January. In March of that year he purchases a Florida homestead for $100,000. The person gets a Florida drivers license and registers to vote in Florida. In March of the following year, 14 months after becoming a Florida resident, the same person loses his job and files bankruptcy. Under the bankruptcy law, Georgia’s relatively limited exemption laws would apply to this bankruptcy, and the debtor would not have the benefit of Florida homestead protection.

​In reality, the laws about bankruptcy exemptions are even more complicated than the example above. Before you file bankruptcy in Florida you and your bankruptcy attorney should discuss where you have resided during the past few years and should discuss whether Florida bankruptcy exemptions would apply in your case.

​Part 2

Exempt and Non-Exempt Property in Florida

If Florida exemption law applies to your bankruptcy, the following are the principle bankruptcy exemptions under Florida law.

​Exempt Property

1. Homestead. Your homestead is exempt property under Article X, Section 4 of the Florida Constitution. This protection is afforded homestead properties situated on one-half acre or less within a municipality and properties up to 160 acres outside a municipality. There is no dollar limitation. The homestead exemption applies to all Florida residents. The new bankruptcy law does not affect homestead protection for Florida residents in state court proceedings.

   The new bankruptcy law does change the homestead exemption for Florida residents who file bankruptcy. Under the new law you can protect unlimited equity in your homestead provided you purchased the residence 40 months or more prior to filing bankruptcy. If you purchased your home within 40 months the new law exempts up to $137,000 of equity. The exemption amount is increased (effective April, 2007) from the original $125,000 to approximately $137,000 per person. Additionally, if you injected cash in your home within the 40 months, such as by paying down the mortgage or building a home addition, the amount of investment made within the 40 months will not be exempt even if you purchased the home 40 months prior to filing. The $137,000 homestead exemption limit applies only in bankruptcy cases. Several courts have held that a married couple filing jointly can claim two homestead exemptions for a total homestead protection of $274,000.

2. Statutory Exemptions. Chapter 222 of the Florida Statutes includes several categories of exempt property, including: pensions, 401K plans, tax deferred retirement plans, Social Security income, disability income, IRAs, annuities, cash value of life insurance, college investment plans (including 529 Plans), health savings accounts, and hurricane savings accounts.
3. Automobile Exemption. You are allowed to exempt $1,000 of equity in an automobile. Spouses who jointly own a car may exempt $2,000 of value in that car. Most bankruptcy trustees accept the average retail/wholesale value from the yellow NADA book, adjusted for the condition of your car. If the balance of your car loan is greater than the car value (“upside down”) then you have no car equity and your car is protected in bankruptcy so long as you keep your car payments current.
4. Miscellaneous personal property exemption. Each bankruptcy debtor is allowed to exempt $1,000 ($2,000 for joint filings) of all other personal property including furniture, cloths, tools, and estimated cash on hand. For bankruptcy purposes the value of your personal property is its current fair market value at a public market such as a garage sale or flea market sale. A new Florida statute effective July 1, 2007, provides a $4,000 “wildcard” personal property exemption to bankruptcy debtors who do not claim a homestead exemption. You must not own a home or intend to surrender the home you do own to the mortgage lender in order to qualify for the wildcard exemption. Joint debtors can claim a $8,000 wildcard exemption.

   You meet a bankruptcy trustee after you file bankruptcy. The trustee has 30 days following your meeting to object to your exemptions. If you claim an asset as exempt on your bankruptcy petition and there is no objection within 30 days after your trustee meeting you may assume the asset is exempt and you may do whatever you want with that asset.

​Non-Exempt Property

Any property which is not exempt under Florida law is included in the bankruptcy estate. The Chapter 7 Trustee may take and sell all non-exempt property and distribute the proceeds to the unsecured creditors. (You will have the opportunity to keep your non-exempt property by entering into a “buy-back” agreement with the Trustee. If you execute a buy-back agreement with the Trustee, you will make either a lump sum payment to the Trustee or make monthly installment payments over a period of several months.)​

Part 3

Credit Counseling

The new bankruptcy law requires that anyone who files bankruptcy must received credit counseling and financial education by approved providers as a condition for filing bankruptcy and discharging debts. In addition, during the course of your bankruptcy you must also complete an instruction course concerning personal financial management in order to have your debts legally discharged. As is the case with credit counseling, financial management courses may be provided by phone or on line. You are responsible to pay credit counseling fees. Your bankruptcy attorney can tell you where to find approved financial management providers.

​Eligibility For Chapter 7 Bankruptcy (Means Test)

Under the old bankruptcy law almost any resident of the United States could file Chapter 7 bankruptcy. The new bankruptcy law includes a two part test of Chapter 7 eligibility. The first test applicable in every Chapter 7 filing is the “means test.” The means testis a mathematical formula to determine who may (and who may not) be eligible to file Chapter 7 bankruptcy. The means test applies only to people whose debts are primarily consumer debts. Consumer debtors include credit card debts, car debt, or mortgages for the primary residence. Many people are forced into bankruptcy because of non-consumer debt such as debts from a failed business, large business related judgment or delinquent mortgages on investment real estate. Those people whose debts are primarily business or investment debts, or debtors who owe primarily other non-consumer debts such as taxes or student loans, are exempt from the means test; these people may file Chapter 7 bankruptcy regardless of their income and expenses. Most importantly, if your family income is less than the median income for similarly sized Florida households you too are exempt from the means test.

​The means test formula is designed to evaluate whether the debtor has the financial means to pay back a substantial part of his debts in a repayment plan through Chapter 13 bankruptcy. The means test formula considers measures of income and allowable expenses. If, according to results of the formula, you do not have sufficient net monthly income to repay debts you are eligible to file Chapter 7; if the formula says you can repay your debts you are not eligible for Chapter 7 bankruptcy unless you prove “special circumstances” of hardship such as a recent job loss or medical problem. You may be eligible for relief in Chapter 13 bankruptcy.

​The means test formula is very complex and several of its important terms are counter-intuitive. The formula incorporates a variety of government statistics from several sources as well as information about each debtor’s financial situation. Calculations under the formula are difficult to do without a professional computer program designed for bankruptcy attorneys to prepare bankruptcy petitions.

​Passing the means test creates a presumption of eligibility to file a Chapter 7 bankruptcy, but the means test is not the only test applicable to Chapter 7 eligibility. The new bankruptcy law includes a secondary test under Section 707(b) known as the “good faith” or “abuse” test. The United States Trustee, or any other party in your case, can request the Court dismiss your Chapter 7 filing if it appears that the filing was done in “bad faith” or was otherwise an “abuse” of the bankruptcy system. This test is applicable only in those cases when the U.S. Trustee or other party files a motion to dismiss under the applicable Code section. If in the light of all relevant financial and family circumstances it appears that you have the ability to repay a significant amount of your unsecured debts a Court could dismiss your Chapter 7 if the filing appears to be abusive. Whereas the “means test” is mostly an objective mathematical computation, the “abuse” test is subjective. Therefore, it is difficult to predict with certainty whether debtors above median income can survive allegations of bankruptcy abuse under Section 707(b). Different court decisions have expressed a variety of facts and circumstances relevant to findings of abusive Chapter 7 cases.

​Part 4

Other Things That Happen After Filing

​Suggestion of Bankruptcy.

You should provide a copy of any lawsuits you have received to your bankruptcy attorney or provide a copy of the bankruptcy court’s notice of the commencement of your case to your civil attorney, so that a Suggestion of Bankruptcy can be filed in any civil case in which you are a party.

​Relief from Stay.

In Chapter 7 bankruptcy cases secured creditors typically file a Motion for Relief from the Automatic Stay so that they are able to foreclose on your secured property in the event you do not pay your secured debt in a timely manner. Relief from stay motions are most often filed by mortgage lenders or car finance companies. The Court will usually grant this Motion but that does not mean that the creditor can take your property. The creditor can take your property only if you do not pay the loan in a timely manner under the terms of your mortgage or loan contract with the creditor, and only after the creditor forecloses its mortgage or lien in state court. If you are behind in your car loan payments, however, the creditor can repossess the vehicle once the stay is lifted.​

​The Bankruptcy Discharge

​60-Day Waiting Period.

After the Creditors Meeting, there is a 60-day period during which time creditors can file claims if they believe you have non-exempt assets and during which creditors may object to being discharged provided they have legal grounds. Grounds for objection to discharge include the fraud, student loans, alimony and support obligations etc.

​Discharge Order.

A minimum of 60 days (usually more) following the creditors meeting you should receive a copy of a court order that discharges your debts. The discharge order wipes out your debts and liability to creditors in your bankruptcy. Do not expect to receive your discharge immediately after 60 days. You can call the Bankruptcy Voice Case Information System at (866) 879-1286 for an update on your case.

​Discharged Debts.

The entry of a discharge order does not affect a secured creditor’s rights in property which you pledged to repay the secured creditor. The secured creditor can always repossess the secured property if you do not pay according to your loan agreement. In addition, the discharge order only discharges debts that “are dischargeable.” Therefore, the order does not eliminate non-dischargeable debts, such as student loans, ineligible tax liability, or loans procured by fraud or by abuse of the bankruptcy system. The Order of Discharge does not give you a list of specific debts that were discharged; it simply states that dischargeable debts are discharged.

​Debts Not Discharged.

The Bankruptcy Code has a list of debts which cannot be discharged in Chapter 7 bankruptcy. These non-dischargeable debts include:

• Debts incurred through fraud or embezzlement;

• Recent income tax liability;

• Education loans / student loans;

• Fines and penalties payable to the government;

• Child support, alimony, and property settlement obligations;

• Debts incurred for the purchase of luxury goods.

There is a presumption of non-dischargeability for cash advances of over $750 taken within seventy (70) days of filing and for purchase of more than $500 within ninety (90) days of filing.

​CLOSING YOUR CASE

Approximately 30 to 45 days after the Discharge, you will receive another notice stating that your case is closed. This means that your bankruptcy case is over.

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