Buy Now/Pay Later – When the Bill Comes Due

-

Link to Post:

This excellent piece, from the archives, is as current today as it was when it first ran in October of 2023. “Under names like Affirm, Klarna, Afterpay, and Sezzle, these companies finance online purchases for the consumer.”

Unlock This Article

To get started, please let us know which of these best fits your current position:

Attorney
Trustee
Non-Profit
Government

Learn more about the membership.

Please sign in to continue reading this content.
enmark

Neil Lloyd Enmark

Staff Attorney to the Chapter 13 Trustee for the Eastern District of California (Sacramento

Neil Lloyd Enmark has represented Chapter 13 bankruptcy trustees since he became a member of the California bar in 1992. He graduated from the University of California at Berkeley with a degree in history in 1986, and received his juris doctor from San Joaquin College of Law in 1991. He has served on the Eastern District of California Bankruptcy Clerk’s Attorney Advisory Committee and has been a prior Director of the Sacramento Valley Bankruptcy Forum. He lives in Galt with his wife Pamela, and has three children and two grandchildren.

Related Articles

emily-connor-kennedy

Finding Your Village: An Introductory Guide to Bringing Fair Credit Reporting Act Claims for Clients Post-Bankruptcy

July 24, 2022
I hope that you’ve enjoyed the articles from Mark Leffler and Steve Relyea discussing how our firm began litigating against creditors in bankruptcy court and mortgage servicers in federal district court. In this (final) installment, I will discuss our entry into Fair Credit Reporting Act litigation. Our firm’s history with Fair Credit Reporting Act litigation is intertwined with the relationships...
View Article
Members

SBRA – The Sequel: Leases in Bankruptcy Under the Consolidated Appropriations Act of 2021 (“CAA”)

February 21, 2021
Lawrence R. Ahern, III, Brown & Ahern (Nashville, TN) Appendix 11 U.S.C. § 365(d)(3) and (4), Showing Changes Made by Consolidated Appropriation Act, 2021 ("CAA"), Pub. L. 116-260, 134 Stat. 1182 (eff. Dec. 27, 2020) (Sunset December 27, 2022. Changes continue to apply in cases commenced before sunset under subchapter V of Chapter 11.) 11 U.S.C. § 365(d)(3) Pre-CAA Post-CAA...
View Article
Members
Copy of Hildebrand-2016

Critical Case Comment – Funds on Hand at Dismissal Go to Debtor. Not So Fast. 13 Trustee May Be Subject to State Court Proceedings

January 16, 2022
While a 13 trustee is partially insulated by the Barton doctrine from being dragged into state court, if a movant seeks authority from the Bankruptcy Court to pursue the trustee and satisfies the conditions of the Barton doctrine, the trustee may be subject to state court judicial proceedings. (Hall) In re Alexander Louis Bednar, 2021 WL 1625399 (Bankr. W.D. Okla....
View Article
Members

A Fond Farewell to 007 – Frank M. Pees

May 3, 2020
On April 30, 2020, Frank M. Pees will retire from his position as the Chapter 13 Standing Trustee (Worthington) for the Southern District of Ohio, Eastern Division. Mr. Pees has been a Trustee since his appointment in 1978. Throughout his career, he has been actively involved in the National Association of Chapter 13 Trustees, serving as President (in 1987), and...
View Article
Members
Hale-Andrew-Antico

Quick Confirmation – BAP Says Not So Fast

September 25, 2022
Sahni v. Tajima (In re Tajima) 2022 WL 3354006 (9th Cir. BAP Aug 15, 2022)(unpublished) S.Klein J ISSUE Did the Bankruptcy Court err when confirming Chapter 13 plan? RULING Yes. FACTS This case involves the tension of litigation in bankruptcy causing delay, and the need to get a Chapter 13 plan confirmed quickly. Here, there was a dispute between debtors...
View Article
Members

CARES Act Rebates and Domestic Support Arrears

May 10, 2020
By Elizabeth Gunn, Assistant Attorney General, Virginia Division of Child Support Enforcement, Bankruptcy Specialisti In late April, the federal government began issuing economic impact rebate payments to qualifying individuals under the CARES Act. While the CARES Act specifically identified and exempted the rebate payments from reduction or offset against certain debts including federal taxes and student loans in default, the...
View Article
Members

New Payment Option Available to Taxpayers in Private Debt Collection Program

October 13, 2019
IRS officials announced on 10/8/19 that a new payment option has been added to the private debt collection program to make it easier for those who owe to pay their tax debts. Taxpayers now can choose the convenient option of a preauthorized direct debit to make one payment or a series of payments toward their federal tax debt. With direct...
View Article
Members
William-1_print_2019

FREE RESOURCE

June 22, 2025
The Federal Judicial Center has published, online, Judge William H. Brown’s second edition of an overview of Chapter 7 and 13 bankruptcy - Consumer Bankruptcy Law: Chapters 7 & 13, Second Edition
View Article
finberg

New Trustee Named

September 10, 2023
Andrew B. Finberg has been appointed as a Chapter 13 Standing Trustee for the District of New Jersey.  Finberg is picking up the mantle left by happily retiring Isabel Balboa.
View Article
ahern_larry_regular

The Effect of “Success” (or the Lack of It) on Attorneys’ Fees – Part 1: Judicial and Legislative Background

September 18, 2022
Introduction In In re Village Apothecary, Inc.,1 the Sixth Circuit last month reduced an attorney's fees by half, where the professional's services were not "successful." The results obtained (or, actually, the lack of results) justified cutting the fees of attorneys for a Chapter 7 trustee by 50%. Why It Matters to Chapter 13 People This analysis of the implications of...
View Article
Members

Looking to Become a Member?

ConsiderChapter13.org offers a forum to advance continuing education of consumer bankruptcy via access to insightful articles, informative webinars, and the latest industry news. Join now to benefit from expert resources and stay informed.

Webinars

These informative sessions are led by industry experts and cover a range of consumer bankruptcy topics.

Member Articles

Written by industry experts, these articles provide in-depth analysis and practical guidance on consumer bankruptcy topics.

Industry News

The Academy is the go-to source for the latest news and analysis in the Chapter 13 bankruptcy industry.

To get started, please let us know which of these best fits your current position:

Attorney
Trustee
Non-Profit
Government