From the Editor

By Wm. Houston Brown, United States Bankruptcy Judge (Retired)

Discharge - Section 523(a)(8)(A)(ii) does not include “loan.” Denying Navient’s motion to dismiss debtors’ complaint, reviewing the split of authority on whether § 523(a)(8)(A)(ii)’s “educational benefit” included loans, and finding no controlling authority in the Tenth Circuit, the Court concluded that Congress made a distinction between “loan” in § 523(a)(8)(A)(i) and “educational benefit” in § 523(a)(8)(A)(ii). The Court adopted the “trending narrower view of Section 523(a)(8)(A)(ii) espoused in

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