Don’ts and more Don’ts when considering a bankruptcy. 2017 Edition.

Thirty-Two Don’ts in preparing to File Bankruptcy

  1. Don’t leave out Bank, Checking, Savings, Brokerage, Credit Union Accounts, PayPal Accounts or HSA accounts.
  2. Don’t use your credit cards prior to filing.
  3. Don’t take Credit Card Cash Advances.
  4. Don’t use convenience checks
  5. Don’t do balance transfers
  6. Don’t pay money to family or friends until after your bankruptcy is done.
  7. Don’t tell a creditor that you intend to pay.
  8. Don’t leave assets off of your paperwork.
  9. Don’t file if you are about to receive a tax refund or an inheritance (without consulting your attorney).
  10. Don’t fail to tell your attorney about your small business, sole proprietorship, partnership, LLC, LLP, LC, corporation, or money making hobby.
  11. Don’t purchase a home shortly before filing bankruptcy without consulting your attorney.
  12. Don’t give or gift property to anyone.
  13. Don’t pay more than $600.00 on any past due bill.
  14. Don’t transfer property to anyone.
  15. Don’t cash out retirement plans or 401k’s.
  16. Don’t take out a second mortgage.
  17. Don’t gamble.
  18. Don’t hide assets or debts.
  19. Don’t take out payday loans.
  20. Don’t put your money in your kids’ bank accounts.
  21. Don’t omit or save a credit card for after your bankruptcy.
  22. Don’t fail to list a debt to a family member or other insider.
  23. Don’t write bad checks.
  24. Don’t borrow money.
  25. Don’t forget to tell your attorney about liens you may have on your home or unpaid judgments, we want to help you make them go away.
  26. Don’t make major financial decisions without talking to your attorney.
  27. Don’t get married before filing if your spouse has a high income.
  28. Don’t misrepresent facts to your attorney.
  29. Don’t run up your credit cards before filing
  30. Don’t fail to appear at State court hearings, trial or proceedings; coordinate with your attorney.
  31. Don’t hide from your attorney.  Keep him or her up-to-date with your address, phone number and email address.

Culled from NACBA listserve with embellishments from yours truly.

Steve Palmer
Licensed in WA and OH

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Do What You Love: I Am a Bankruptcy Attorney and I Love It.

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How many times were you told when you were growing up that you should do what makes you happy? Dozens? Hundreds?  I was told that over and over, and I struggled with it through university.  After taking a 4 year break teaching English in Japan, I went to law school.  I then graduated at a terrible time for attorneys.  Large firms were not hiring, government was not hiring, so I put out nearly one hundred applications until I was picked up by a large consumer bankruptcy law firm in Ohio.  I had no idea how I was going to like practicing bankruptcy law.  None.  About a year into it, I realized I really liked what I did.  Now nearly 1000 cases in, I love it.  I lucked into a career that I love.

As a bankruptcy attorney, I can help turn peoples lives around and give them the fresh start that is provided for in the law.  I can stop foreclosures, wipe out second mortgages, save cars from being auctioned, stop garnishments, get people their driver’s licenses back, and generally give them a new lease on life.  It is awesome.

Find something you love and stick with it. You are going to spend somewhere around 90,000 hours of your life doing it.

Best of Luck,

Steven Palmer
Licensed in WA and OH
http://www.northwestbankruptcyattorneys.com
http://www.curtislaw-pllc.com

Uber Leases: The Company Towns of the 21st Century

car and moneyRemember the stories of the little towns owned by coal companies?  The coal company would provide housing and had a general store where the miners would use company script to purchase their needed goods.  After paying for their rent and food needs, the miners often had nothing left while the coal companies made money from both the coal that was mined and from the miners themselves.

Fast forward to the “Gig Economy.” The Gig Economy, as it is known, has proven to be a decent way for people who are otherwise out of work to make some money.  Think Uber, Lyft, and Airbnb.  Some companies offering their platform offer money that rivals that of a full time job.  The work they offer seldom comes with benefits.  This post is a warning for people looking to lease through Uber.

As a bankruptcy attorney, I often see people who are down on their luck and who frankly have pretty bad credit.  These people are often offered the very worst rate on auto financing, home financing and credit cards.  How does a 29% interest car loan sound? Unfortunately, Uber is getting in on the subprime lease game through a company they own called Xchange Leasing.  Knowing, presumably that their drivers are often people who have lost a job and thus don’t have credit, they offer people a way to get into an “Uber qualified” car.  Bloomberg recently ran a report with an Xchange customer who is paying $160/week for a 2015 Honda Civic SE  That works out to $693.33 per month.  52 weeks in a year / 12 months.  Contrast that with Honda, who, as of this post, is offering a $139.oo per month lease with zero down.  That is a 499% premium that Uber Xchange customers pay over a qualified lessor.

I have had two clients in the past month come to me with these leases.  They have among the worst financing terms I have seen.  It would be a far better move to attempt to build your credit a bit and then buy or lease at a much better rate.   Granted, Uber has pretty liberal policies when it comes to getting out of the leases, but you would think that since they take the payment directly from the earnings of their drivers that they would offer something better than sub-prime lease rates.  As it stands, Uber is making money from the trips that are driven and now from the drivers themselves.  Sound familiar?

Best of Luck,

Steven Palmer
Licensed in WA and OH
http://www.northwestbankruptcyattorneys.com
http://www.curtislaw-pllc.com

Tax Refunds and Bankruptcy

Money

Tax refund season is typically the busiest time of year for bankruptcies to be filed.  The reason is pretty simple, people who have been slogging along trying to pay their bills have not had the extra money to use for a bankruptcy attorney.  Their tax refunds change that and finally make it possible for many people to get their cases filed.

If you are considering bankruptcy there are some things to keep in mind if you are expecting a big tax refund.

Filing a case before you receive the refund can lead to some or all of the refund having to be turned over to your bankruptcy trustee.  This all depends on your state’s exemptions. Some states, Ohio for example, will allow you to exempt all of your additional child tax credit and earned income credit.  Some states, Washington and New York for example,  allow you to use either state or federal exemptions.  If you have the option of using federal exemptions and you do not have a home with equity you can exempt a large amount which may protect your entire refund.  Still other states offer very anemic exemptions and make it very difficult to file before receiving a refund.

If you file a case after you receive the refund there are other considerations.  You can still use the exemptions mentioned above.  If, however, you are not able to protect the entire refund, you can spend it on items that are considered reasonable and necessary.  You just have to be aware that trustees will look to see if those were normal expenses that would usually be paid using your regular income.  Reasonable and necessary expenses are subjective but be aware that your attorneys fees and court costs are considered reasonable and necessary.

Many people rely on their refunds to get by.  If you are among them and are considering bankruptcy, make sure you speak to an attorney to protect as much of that refund as possible.

Best of Luck,

Steven Palmer
Licensed in WA and OH
http://www.northwestbankruptcyattorneys.com
http://www.curtislaw-pllc.com

 

Northwestbankruptcyattorneys Blog Year End Review

Fireworks

The year 2015 is almost ready for the history books.  Before we look ahead into what 2016 brings it makes sense to look back to get a greater sense of where we need to be headed.

This year I posted on a variety of bankruptcy issues, mostly general in nature to give my clients and anyone contemplating bankruptcy some issues to think about.

This year started out with looking at how loan modifications can still be pursued by debtors in chapter 13 bankruptcies. (They can be obtained and can be a great way to deal with a home that you had almost lost.)  I then looked at what happens to your car when you file a bankruptcy. (You have lots of options.)  Since so many of my clients are worried about how their credit scores will be impacted by the filing of a bankruptcy, we did a post on bankruptcy and your credit score. (The impact is not nearly as bad as people think.)  I then put together a post looking at some of the do’s and dont’s of filing a bankruptcy.  If you are contemplating a bankruptcy, please read or reread this post.  The award for the biggest northwestbankruptcyattorneys blog post goes to The History of Student Loans in Bankruptcy.  I did a ton of research for this post and am pretty happy with how it came out.  If you are at all interested in the topic, please give it a read.  The changes that have taken place over the course of 60 years are astonishing and terrible.  They remind me of the proverb, the road to hell is paved with good intentions.  From there, I tried to give potential filers some ideas of how they can find a good bankruptcy attorney in 5 Tips for Finding a Good Bankruptcy Attorney.  We then looked back at the topic of homes and bankruptcy in the Halloween Special Zombie Homes Attack.  (You do have options if you have a house that is stuck in your name after bankruptcy.)   The award for biggest rant post of the year goes to Credit Unions: The Devil is in the Details.  In that post we looked at the hidden dangers of using a credit union for a car loan and also having credit cards or bank accounts with those same credit unions.  Lastly, the Christmas Special this year was The Christmas before Bankruptcy.  In that post we looked at some of the hidden dangers of gift giving and receiving before filing a case.

In the coming year, look out for more posts on student loans and ways to deal with your small part of this national crisis.  Another post on zombie homes and getting rid of them through the bankruptcy process.  A more detailed look at what you can do to rebuild your credit.  A post on attempting to avoid bankruptcy.  There will be others as well as the inspiration strikes.  We are also open to writing on topics that people request, so if you have a topic you would like to see an article written on, please suggest it below.

Happy New Year from all of us at northwestbankruptcyattorneys.com and the Curtis and Casteel Law Group.

Steven M. Palmer, Esq.
Licensed in WA and OH
http://www.curtislaw-pllc.com
http://www.northwestbankruptcyattorneys.com

The Christmas before Bankruptcy

Depending on your family, Christmas gift giving may be huge or it may be minor.  If you fall in the former category and you are considering a bankruptcy you need to be aware of some bankruptcy rules which could impact your bankruptcy filing.

Gift giving and bankruptcy:

If you are a big giver and routinely rack up credit card debt ensuring that everyone gets just what they want, you will want to go easy the Christmas before bankruptcy.  In the forms that are required by the bankruptcy code, there is a requirement that you list any gifts made to a family member of more than $200.00 or more than $100.00 to a charitable organization.  Giving cash or items to a charity is generally not a problem so long as you don’t go over 15% of your gross income during the year in which the contributions were made.  The reason behind the restrictions is that congress did not want potential debtors to squander their assets in an attempt to hide them from their creditors before filing a bankruptcy.  If you did give a bunch of gifts to family members this Christmas, it may be best to wait until next year to file.  Your best bet if this situation applies to you is to contact a local bankruptcy attorney and ask their advice.

Gift receiving and bankruptcy:

What really matters here is what was given and is it an exempt asset.  If you received cash for Christmas, that cash gift could push you over the income threshold between a chapter 7 bankruptcy and a chapter 13 bankruptcy if you were already close.  If instead you received a car or a new mac book, those are items which would need to be listed.  What happens next depends on the value of the assets and the exemptions available.  If you have enough exemptions available, you will not have anything to worry about.  If on the other hand there are not enough exemptions to protect the new assets, a chapter 7 trustee may take them, or you may be pushed into a chapter 13 bankruptcy.  Again, you would want to talk to a local bankruptcy attorney to make sure that this will not be an issue in your case.

Best of Luck,

Steven M. Palmer, Esq.
Licensed in WA and OH
http://www.curtislaw-pllc.com
http://www.northwestbankruptcyattorneys.com

Credit Unions: The Devil Is In the Details.

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Credit Union Customers love their credit unions.  They love the level of service that they get and they love the relatively low rates for loans and high rates for savings.  Much of this love is not reciprocated.  Credit Unions, if you are ever forced into a bankruptcy proceeding are fond of forcing reaffirmation agreements and enforcing their nearly ubiquitous cross-collateralization and future advances clauses.  These are things that you almost never have to worry about if you get your financing elsewhere.

Customers must beware.  If you take out a loan with a credit union because they offer you a great rate, beware of the details.  You will likely be signing a loan document that includes language allowing them to hold on to your title until you pay any other loan that you have with them.  If you are a credit union customer and you have a credit card through the credit union the credit card agreement may include language allowing them to secure that card to any future security interest that they hold.  For example, you get a credit card, you happily use it and are happy with the rate, you then decide that you want to get a car loan through the credit union because they are offering a great rate.  Now the car loan is obviously secured by the car, what is not obvious to almost everyone is that the credit card is also secured by the car.  This means that after you have paid off your car loan, the credit union can withhold your title until the credit card is paid off.  The same goes for personal loans with credit unions.

Now if something bad happens to you financially, and believe me it happens all the time, whether you suffer an injury, a job loss, get divorced, or have to support a relative, you could be forced into a bankruptcy.  If that happens and you have a car loan with a credit union you will end up having to pay off debts that otherwise would have been discharged in the bankruptcy if you want to keep the car.

To protect yourself, if you insist on using a credit union to get a car loan, do not take out any credit cards with them, do not take out any personal loans, and do not take out any lines of credit.  Keep your other finances fenced off from the credit union’s dragnet.

If you find yourself needing to file a bankruptcy and you have a car loan through a credit union and a credit card, a personal loan, or a line of credit, speak to a bankruptcy attorney right away and see if there is anything that can be done to protect your interests.  Your best bet is to stay clear of them altogether.

Best of Luck,

Steven M. Palmer
Licensed in WA and OH
http://www.northwestbankruptcyattorneys.com
http://www.curtislaw-pllc.com

Bankruptcy and your Vehicle

The bill collectors are calling you and everyone you know, your wages are about to be garnished and you can barely pay the necessities.  You know you need to file bankruptcy.  So what is stopping you, the fear of losing your car, truck, or motorcycle?

In most cases when you file bankruptcy you can keep your vehicle.  Of course, it is a little more complicated than just file bankruptcy don’t worry about your car.  This article will explore several scenarios I have dealt with in the past dealing with bankruptcies and client’s vehicles.  Motorcycles come with a caveat, here it is…Motorcycles are slightly different from other vehicles in that they can been classified as non necessity luxury items so contact your attorney to see what your specific options are regarding motorcycles.

Scenarios in a Chapter 7 Fresh Start Bankruptcy.

Scenario 1. You owe nothing on the car and it is not worth that much.  You do not make enough money to cover even your basic needs, you have a car and you do not want to lose it.   Chances are if you have a car in this situation you own it outright.  Whether you can keep it or not will depend on the value of the car.  In Washington, for example, the automobile exemption for an individual is $3450.00.  Washington also allows a wildcard exemption of $3000.00.  If your car is worth $4500.00 in its current condition, an individual could use the full motor vehicle exemption and then use $1050 of the wildcard.  That will fully protect your car and still save $1950.00 of your wildcard.  Your car is safe.

Scenario 2. You owe nothing on the car but it is worth more than the exemption value.  This is the most complicated scenario in a chapter 7 bankruptcy and may be better dealt with in a chapter 13.  Nevertheless, there are options in a chapter 7.  Let’s say the car is worth $10,000.00.  As discussed above, you can use the current vehicle exemption of $3450.00.  You can then add to that the wild card exemption of $3000.00.  That protects $6450.00 of value in the vehicle. meaning that you have $3550.00 unprotected.  Now we have a couple of options.  You could: 1) Let the trustee take and sell the vehicle and use the proceeds to pay off some of your creditors.  If you do this, the trustee will cut you a check for $6450.00 and use the $3450 that is unprotected to pay some of your creditors.  You could then use this money to help get a new car or to buy a used car outright.  2) Try to work out a deal with the trustee to repay the unexempt equity.  Trustees are usually willing to work out a reasonable payment plan to allow you to keep something like a vehicle.  Common terms might be to pay back the equity in six equal installments, or to make a down payment with a monthly payment that ends in a larger payment when you get your tax refund.  You need to be careful with this useful arraignment, if you default on your payments your discharge could be denied or revoked. 3) Try to get a new loan on the car after the bankruptcy is finished which would allow you to pay the equity to the trustee.  You would then have a car payment to pay the newly incurred loan.

Scenario 3. You owe less on the car than what the car is worth.  If you are looking to file a chapter 7 to obtain a fresh start and avoid making a chapter 13 trustee payment, you should be able to protect that car.  Say the car is valued at $15000.00 and you still owe $12000.00.  In this case you have $3000.00 in equity.  Because the automobile exemption is worth more than the equity you have in the vehicle, your car will be protected.  You will need to speak with your attorney about what to do during and after the case, but you will need to maintain your loan payment if you wish to keep the vehicle.

Scenario 4.  You owe more on the car than it is worth.  In this scenario you might owe, for example, $15000.00 on a car that is only worth $7000.00.  You have several options under this scenario.  You could: 1) decide to let go of the car.  Why pay more than double the value of anything?  You could surrender the vehicle and then look to purchase a vehicle with better terms after the discharge; 2) You could continue to pay on the vehicle at the terms provided in the loan agreement; 3) We could seek a redemption loan whereby you get a new loan that is only up to the value of the car in its current condition.  In this case you need to qualify for the new loan and there may be additional attorney’s fees but it could potentially save you a lot of money and keep you in a car that you love.

Scenario 5. Bonus Scenario!  You have unexempt equity in your vehicle but you also have tax liens which attach to personal property.  This one is a little tricky, but if you have no other equity in any other property and the amount of the tax lien is greater than the unexempt equity in your vehicle, the trustee is not likely to bother with you or your vehicle.  The down side to this is that if they were to take and sell the car for the unexempt equity, they would then use that money to pay off or to pay down your tax lien.  If the trustee leaves you and your vehicle alone, you are still going to have to find a way to deal with those taxes once your bankruptcy is done.

Scenarios in a Chapter 13 repayment plan bankruptcy:

Scenario 1. You owe nothing on your car and it is worth less than the exemptible amounts.  Under this scenario, your vehicle would have no impact on your chapter 13 plan payment.

Scenario 2. You owe nothing on your car but it is worth more than the exemptible amounts.  Under this scenario, we have to offer the unexempt value to the creditors in the form of your trustee payment.  While this goes beyond the scope of this article, we can pay the unexempt value by way of the trustee payment over a period of time lasting as long as 60 months.  This is a valuable tool if you have a car that is worth a lot of money and you cannot bear to part with it.

Scenario 3. You owe money on the car and you want to keep it.  This scenario gets complicated depending on whether the loan on your car was taken out at the time that you bought the car.  It also matters as to how long ago you bought the car.  If you bought the car more than 910 days ago, we can cram down what you pay on the car based on its current value.  So say that you owe $15000.00 on the car but it is only worth $7000.00, we can propose a plan that only pays that creditor back $7000.00 as a secured claim.  We can also lower the interest payment on the car depending on the rate that the loan is for and depending on the jurisdiction.  If you bought the car less than 910 days ago, we may still be able to lower the interest rate that you pay on the car, but the full dollar amount of the outstanding loan would have to be paid back as a secured creditor.

Scenario 4.  You owe money on the car and you just do not want it any more.  In this scenario a chapter 13 can also be a good option depending on what the rest of your financial situation looks like.  We can propose a plan that surrenders the collateral.  The lien holder will come and get the car.  They then have to sell it and credit your account for the amount of the sale.  In the chapter 13 they are then able to file an unsecured claim for the remaining balance.  The benefit to you though is that you will end up paying less than you owed (possibly zero) and paying no further interest on the loan.

Conclusion:  As you can see, there is no simple answer to what happens to a car in a bankruptcy.  The good news though is that there are many options that allow you to keep your vehicle and still other options that will allow you to escape from a bad deal.  If you find yourself in financial difficulty and the thought of losing your only car is stopping you from filing, call your local bankruptcy attorney to discuss which option might be best for you.

The Intersection of Bankruptcy and Loan Modifications (Loss Mitigation).

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Source: The Intersection of Bankruptcy and Loan Modifications (Loss Mitigation).

Is your house in in foreclosure and you have been working with the mortgage company for months to try and get a loan modification which could solve the issue? Does the mortgage company seem to be dragging their feet, asking you for the same documents over and over and yet you do not seem any closer to actually accomplishing anything? Now seemingly out of the blue there has been a notice of Trustee/Sheriff’s sale. You panic. There is an option that will save your house and enable you to continue to work on obtaining a loan modification. That option is a chapter 13 bankruptcy. The chapter 13 will stop the sale now and give you a repayment plan which if you complete will put you right where you should be with your mortgage (your mortgage will become current). The filing of the chapter 13 does not mean that loan modifications are not possible, but if you had already started, you will likely have to begin again. This time, however, there will be no threat of losing your home. If on the other hand, you are surrendering the home, there are still option you should pursue while you are in the bankruptcy.

After you file the case and the sale is stopped, you can then restart the loan modification proceedings by requesting a loss mitigation package from the lender or servicer. When you do this they usually send out a “waterfall” package. This is an application that would check for eligibility for a HAMP loan modification, an in-house modification , eligibility for a shortsale, and eligibility for a deed-in-lieu of foreclosure, and possibly eligibility for a short payoff. This post will explore all of those options and additional loan mod options other than HAMP.

After you receive the loss mitigation package, it is important to make sure that you have all of the requested paperwork together prior to sending it to the mortgage company or servicer.   They will generally ask you for 2-3 months of bank statements, a Dodd-Frank Certification signed and dated, copies of your most recent pay stubs for 2 pay periods to 3 months or longer, a form 4506-T form signed and dated with your phone number and filled out correctly, copies of your last two years of taxes, and a hardship letter. A number of those are self-explanatory, some of them are probably unfamiliar. The Dodd-Frank Certification just needs signed and dated, no big deal there. The 4506-T form has to be filled out perfectly or your loss mitigation application process will be delayed by months. You really need to check with your attorney to ensure that you are filing it out correctly. Generally, you need to fill out the top completely, select the type of transcripts that you want them to send the mortgage company, you need to list the years that you want them to send, it is generally 3 years and they generally want the date format to be 12/31/2012, 12/31/2013, 12/31/2014 for example. You then need to sign it, date it, and put your phone number next to the signature line. As for the hardship letter, it should indicate why you began to fall behind on your mortgage, and when or why that hardship is or has ended so that you will be able to make some payment in the future.

Part of the application process also requires you to fill out your household income and expenses. A common mistake that people make is to under report their income/ over report their expenses. Keep in mind that part of the process, if you are seeking to modify the loan, is that the modification review has to go through underwriting. That means that they will be checking to see if you will be able to afford the new payment that they can offer. If you cannot show that you will be able to make the payment, you will not be offered a loan modification.

The different types of loan modifications that the bank can or will offer will depend on if they have ever offered you a loan modification in the past. HAMP stands for Home Affordable Modification Program. It is a program that was set up in the aftermath of the subprime mortgage crisis. Generally you receive only one HAMP loan modification offer per loan. This is not a hard and fast rule, however, and I have seen HAMP modifications offered more than once per loan. HAMP modifications may reduce the principal balance, they may reduce the interest rate, they may reamortize the loan over a longer period of time (stretch your loan out), or they may do a number of these things to help you to get a lower loan payment. Offers that include a principal reduction will usually have certain benchmarks that you have to meet in order to ensure that the principal really is forgiven. If you fail to meet these benchmarks, the forgiven principal will return. Generally, you will need to ensure that the loan is in good standing on the first, second, and third anniversaries of the effective date of the trial period. The amount that the principal is reduced by will generally not be treated as taxable income. Speak to your tax attorney or accountant for more information on this. Another type of loan modification that your mortgage lender may provide is an in-house modification. For an in-house loan mod, the lenders are not bound to the requirements of HAMP. They can also offer these even if they determine that you are not eligible for HAMP. The results may not be as good but they should still be better than what you currently have. Unfortunately, you may find that the modification offer is not to your liking. Perhaps it doesn’t reduce the interest rate by much, or maybe it adds 10 years onto your loan and you don’t find that palatable. So long as you continue through your chapter 13 bankruptcy you will finish it with your original loan intact at the original terms and on time per the original payment schedule. (There are some small caveats to this you should ask your attorney about.)

Another option if the modification will not work is to ask for a short payoff. Essentially, you are asking the lender/servicer to settle the remaining balance for something less than is owed. I have seen short payoffs between 10% and 33% so some incredible options are out there if your lender determines that you qualify. You would need to speak to your tax attorney/accountant to see if you will have to pay income tax on the forgiven debt.

Short-Sale, Deed-in-lieu – What if you decide that you don’t really want the property any longer? In that case, you have a couple of options. Simply surrendering the property in a bankruptcy is not enough. If you simply surrender the property in the bankruptcy and then the mortgage creditor sits on their rights and doesn’t move to complete the foreclosure process, you will be stuck with liability on the property if anyone were to get injured or for housing code violations. To avoid this, you can attempt to do a short sale. A short sale is potentially available where you are underwater on the home. If there is only one lien on the property you are much more likely to accomplish a short sale. The more liens there are, the more parties have to be satisfied with the sale offer. The same goes for a deed-in-lieu. A deed-in-lieu, short for deed-in-lieu of foreclosure is where you sign the property over to the mortgage creditor in exchange for them not foreclosing on the property. This can potentially save the banks lots of money and has the benefit to you of getting rid of any liability from continued home ownership.

If this sounds like you, just know that there is help out there. Contact a local bankruptcy attorney with experience in this field to help you out.

Best of Luck,

Steven Palmer
Licensed in WA and OH