To limit the amount of a homestead exemption under Section 522(q)(1)(B)(ii), the fraud must have occurred after the debtor became a fiduciary.
The inability to modify a Section 524(a) discharge put the Ninth Circuit BAP in a bind.
A BAP decision raises the question of whether Ninth Circuit authority has been implicitly overruled by Supreme Court decisions.
July 2025
The circuits are split on whether equity can extend the 60-day deadline for filing dischargeability complaints.
