BANKRUPTCIES
AND ASSESSMENTS
One
of the most dismaying events during the collection of past due
assessments is the filing for bankruptcy by a member. Bankruptcies
are governed by Federal law, and are designed to give the "debtor",
a new financial beginning or time to reorganize his or her financial
affairs.
The
provisions of the Bankruptcy Code are very detailed and rival
the Income Tax Code in complexity. There are different forms of
bankruptcies. Most community associations have been affected by
Chapter 7 liquidation, or Chapter 13 reorganization at one time
or another.
One
of the most significant aspects of filing for bankruptcy is that
as of the date of filing the Petition with the Court, all actions
to collect debts or enforce judgments are automatically stayed
by the bankruptcy filing. The bankruptcy stay prohibits the Association
from proceeding with its foreclosure for past due assessments
in State Court. Additionally, further contact with the debtor,
regarding past due assessments is prohibited. Violation of the
stay can result in a finding of contempt of Court fines.
The
bankruptcy stay is not totally unfair; it merely requires that
all actions pertaining to any claims against the debtor are heard
in one forum--the Bankruptcy Court.
The
Association may petition the Bankruptcy Court for a number of
remedies. The most significant is to ask the Bankruptcy Court
to "lift" the automatic stay in relation to the debtor's
property, which is subject to the community association's assessments.
The Association may also file a Proof of Claim to verify the amount
due with the Bankruptcy Court. A request for "adequate protection"
requiring the debtor to pay current assessments may also be made.
The type of bankruptcy and the facts of each case dictate the
best course of action.
Most
debtors file a Chapter 7 liquidation. This is known as a straight
bankruptcy, where the debts of the debtor are listed and personal
liability is eliminated. As the Association is a secured creditor
by virtue of the Association's documents, upon the conclusion
of a Chapter 7 case, the Association may proceed with a foreclosure
of the lien for nonpayment of past due assessments. However, the
Association may not also receive a judgment against the debtor
individually for the assessments.
Many
Associations find that members file a Chapter 13 bankruptcy, which
allows the debtor time to file a repayment plan for the past due
debts. A Chapter 13 case may be open from three to five years.
During the term of the case, the debtor is required to make payments
to the bankruptcy trustee, who in turn, distributes funds to the
various creditors, according to the terms of the plan. In a Chapter
13, it is essential that the Association verify the amounts due
by filing a Proof of Claim, as the plan will repay the creditors
based upon the amounts listed by the debtor or as filed in a Proof
of Claim by a creditor. Due to the duration of a Chapter 13 proceeding,
Associations also usually request relief from the automatic stay
and/or an order for adequate protection.
Condominiums
and cooperatives have clear authority in the Bankruptcy Code to
require that a debtor pay current assessments if the debtor is
continuing to reside in the property or if the debtor is receiving
rent for the property.
The
Bankruptcy Court is part of the Federal Court system and is governed
by the Federal Rules of Civil Procedure, along with additional
Federal and Local Rules of Bankruptcy Procedure. Attorneys must
be specifically admitted to practice in the federal district courts
to appear in Bankruptcy Court. Therefore, when an Association
is faced with a bankruptcy BY a member, the Association should
verify that its counsel is admitted to the federal district court
and is familiar with the bankruptcy procedures.
For
further information regarding the effect of a bankruptcy filing
by a member, consult an association attorney that is familiar
with the bankruptcy procedures.
By: Joseph R. Cianfrone, Esq.