Since the passage of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 ("BAPCPA") issues have come before this Court and most others across the country regarding the handling of Reaffirmation Agreements. Citing various reasons ranging from fear of conflict of interest, to questions of legal liability and the genuine concern that a particular reaffirmation agreement may not be in the best interest of the client, debtor's attorneys are facing issues regarding the counseling and representation of their clients in reaffirmation agreements. These issues have caused problems between debtors and their legal counsel and subsequent problems with the court itself as to when or whether debtor's attorneys or debtors themselves should sign reaffirmation agreements, whether attorneys should appear in court for hearings on reaffirmations or whether services regarding reaffirmations should be a part of the contractual relationship between the debtors and their counsel. Upon the urging of the Bench, the Detroit Consumer Bar Association has prepared these Best Practices for Reaffirmation Agreements as a means to guide the local bar through the questions that arise in the reaffirmation process. This document is by no means an order of the Court and the Bench has indicated that its usage is by no means mandated. This document is intended primarily to provide a discussion of the process and to delve into the issues that need to be considered by each individual attorney as they make their own determinations on handling their client's reaffirmation agreements.

I. Applicable Code - Section 524(c) carves out an exception to the Section 523 rule that a Chapter 7 debtor who receives a discharge under 11 U.S.C. 727 is relieved of all personal liability for debt that arose before the date of the order for relief. The language of Section 524(c) and (d) together lay out a series of requirements for an enforceable reaffirmation agreement that include:

• 524(c)(1) the agreement must be made before the granting of the discharge
• 524(c)(2) the debtor must have received the disclosures described in 524(k) at or before the time at which the debtor signed the agreement
• 524(c)(3) that the agreement must be filed with the court and, if necessary, be accompanied by a some kind of representation of the attorney representing the Debtor that
  • 524(c)(3)(A) the Debtor was fully informed and the agreement is voluntary
  • 524(c)(3)(B) the agreement does not impose an undue hardship
  • 524(c)(3)(C)the attorney has fully advised the debtor of the consequences of signing the agreement; and
  • 524(c)(4) that the Debtor hasn't rescinded the agreement in the sixty days after signing it.

II. What to do With a Reaffirmation - When Debtor's counsel receives a reaffirmation agreement counsel should carefully review the document to make some basic factual determinations regarding the creditor, collateral, and whether the payments are already provided for in the budget filed as Schedule J in the Chapter 7 bankruptcy proceeding. The second line of questions that must be reviewed by counsel address the legal questions raised by Section 523(c)(3)(B) regarding undue hardship and the greater issue of the costs and benefits to the client if the reaffirmation agreement is signed. A fairly comprehensive list of questions can be found in an article titled Reaffirmation Agreements: Basic Practice Tips and Pitfalls by Melanie Sonnenborn, Law Clerk to the Hon. Mary D. France, U.S. Bankruptcy Court (M.D. Pa.).

a. Is the agreement correctly filled out by the creditor, including a detailed description of the collateral and the required disclosures?
b. Who is asking for the reaffirmation (which creditor)?
c. Which collateral is involved?
d. Have the terms of the original contract been altered in the reaffirmation agreement?
e. What, if any, are the alternatives to reaffirmation?
f. What are the consequences of reaffirming vs. not reaffirming?
g. What are the benefits/costs to the client of reaffirming?
h. Can the debtor afford the payments under the agreement?
i. Has the debtor's income or expenses changed since Schedules I and J were completed?
j. Does the debtor need to make changes in his income or expenses to be able to afford the reaffirmation, and is he willing and able to do so?
k. Is the debtor current in his payments?

Of particular importance is whether the underlying debt is secured or unsecured and what collateral the debt is secured against. There are conflicting theories regarding whether to sign reaffirmation agreements for debts secured by homes or vehicles. These arguments revolve primarily around the logic that, no secured creditor will likely turn down payments on their collateral as long as the payments are made timely. Further, if the debtor were to default on the payments after discharge without signing a reaffirmation agreement, the creditor would not have the ability to collect the balance of the loan agreement from the debtor. However, the BAPCPA language and subsequent case law have given rise to the possibility that this option may no longer exist. Post-BAPCPA case law in other circuits has ruled that the BAPCPA amendments overruled previous decisions allowing vehicles to be retained post-discharge without signing a reaffirmation under the theory that the filing of the bankruptcy case is itself a default. (See an online article by John M. Hilla entitled Can I Reaffirm My Car in a Chapter 7 Bankruptcy at http://michiganbankruptcyblog.com) Further speculation indicates that under Section 521(a)(6) a debtor who does not sign a reaffirmation in a Chapter 7 cannot retain possession of personal property unless the debtor has signed a reaffirmation agreement or redeems within 45 days of the first meeting of creditors. (See Reaffirmation Agreements Under BAPCPA and Potential Liability of Bankruptcy Attorneys by Devin Palmer, Esq. located at http://www.boylanbrown.com/products/Articles.aspx)

III. The Duty to Counsel the Debtor - It is the opinion of some courts that if the debtor is represented by counsel, the agreement must be accompanied by an affidavit of the debtor's attorney attesting to the referenced items before the agreement will have legal effect. (See In re Schott, 282 B.R. 1, 5-6 (10th Cir. BAP 2002) and In re Minardi, 399 B.R. 841 (Bankr. N.D. Okla 2009). For a variety of reasons some debtors attorneys have taken the stance that counseling, signing and representation at hearings for reaffirmation agreements should not be part of the attorney-client agreement and both counsel their clients and include in their retainer agreements provisions that exclude these services from the scope of legal representation in the Chapter 7 proceedings. In the context of what the reaffirmation agreement means in the Chapter 7 process, the ability to separate out counseling regarding reaffirmations from the general counseling of the client regarding the Chapter 7 bankruptcy process seems hard to delineate. The previously mentioned Minardi decision explores this question in depth:

"Many debtors who file bankruptcy under Chapter 7 hold property that is subject to secured liens. Whether to surrender or redeem the property or reaffirm the underlying debt constitutes one of the most critical decisions faced by a debtor. It has a direct and significant effect upon a "fresh start" because 1) debt that is reaffirmed remains the personal liability of the debtor; and 2) creditors whose debt is reaffirmed have all of the rights and remedies available to them that were available prior to the filing of the bankruptcy case. It is unreasonable to conclude that a typical debtor that seeks out the assistance of an attorney to navigate through a bankruptcy case will not require further assistance in making such a critical decision as whether to reaffirm a debt. Similarly, if a debtor, in consultation with counsel, determines that reaffirmation of a debt is the best course, it is not reasonable that he or she will then be left to proceed without assistance to negotiate favorable terms with the creditor".

As pointed out in the Minardi decision, there appears to be a groundswell of opinion from the bench in many jurisdictions that the practice of excluding counseling regarding reaffirmations from the list of services to be provided by an attorney in the retainer agreement will not be well received. (See In re DeSantis, 395 B.R. 162, 169 (Bankr. M.D. Fla. 2008; In re Carvajal, 365 B.R. 631, 632 (Bankr. E.D. Va. 2007); Hodges v. Armada (In re Hodges), 342 B.R. 616, 620-21 (Bankr. E.D. Wash. 2006); In re Eqwim, 291 B.R. 559, 573 (Bankr. N.D. Ga. 2003); In re Castorena 270 B.R. 504, 530 (Bankr. D. Idaho 2001); In re Wagers, 340 B.R. 391, 398 (Bankr. D. Kan. 2006)l In re Isom, No 07-31469 WL 2110318 at 3 (Bankr E.D. Va July 17, 2007) which all represent cases where the bench has indicated its unwillingness to accept the notion that counseling regarding reaffirmations can be taken outside of the scope of the attorney-client relationship in bankruptcy).

a. Allowing Exclusion of Particular Services - Michigan Rule of Professional Conduct 1.2(b) states "A lawyer may limit the objectives of the representation if the client consents after consultation." It is this language and similar language that appears in the rules of professional conduct in other states that is often invoked when attorneys make the decision to exclude consultation regarding reaffirmation agreements in their retainer contract with their clients. However, the rule cannot be read without viewing the attached commentary and other associated Rules. The commentary to Rule 1.2 indicates:

"The objectives or scope of services provided by a lawyer may be limited by agreement with the client or by the terms under which the lawyer's services are made available to the client. For example, a retainer may be for a specifically defined purpose. .... An agreement concerning the scope of representation must accord with the Rules of Professional Conduct and other law. Thus, the client may not be asked to agree to representation so limited in scope as to violate Rule 1.1."

Michigan Rule of Professional Conduct 1.1(c) states:

"A lawyer shall provide competent representation to a client A lawyer shall not neglect a legal matter entrusted to the lawyer."

Finally Michigan Rule of Professional Conduct 1.3 regarding diligence and its associated commentary state:

"A lawyer shall act with reasonable diligence and promptness when representing a client." Commentary: "A lawyer should pursue a matter on behalf of a client despite opposition, obstruction or personal inconvenience to the lawyer....A lawyer should act with commitment and dedication to the interests of the client and with zeal in advocacy upon the client's behalf."

When assessing the plain language of Rule 1.2b in the scope of Rules 1.1 and Rule 1.3 and the relevant commentary, the argument that "the Model Rules say I can exclude what I want to" seems lacking, perhaps even standing in complete opposition to what the Model Rules intend. An attorney must reasonably consider how excluding such a core concept as choosing which debts would survive the Chapter 7 bankruptcy through reaffirmation from the scope of services could be something other than "neglecting a legal matter entrusted to the lawyer" as laid out in Rule 1.1. Can an attorney reasonably carry out the legal representation entrusted to him by his client regarding the core purpose of a bankruptcy filing, the discharge of debt, without discussing the mechanisms that exclude some of those debts from discharge? Can an attorney reasonably say that they don't wish to counsel their clients or represent their clients at hearings regarding reaffirmations because "they're not getting paid extra for it" or "it's a waste of their time to appear" if they are, as Rule 1.3 states "acting with reasonable diligence" or "pursuing the matter on behalf of a client despite...personal inconvenience to the lawyer"? (Attorney Liability in Bankruptcy, Vance, Catherine E. and Cooper. Corrine, at 281,282)

IV. The Duty to sign Reaffirmation Agreements

a. The Question of Whether to Sign or Not. - The question of whether an attorney should sign a reaffirmation agreement or not under BAPCPA has been discussed at length and written about often since the law's passage by Congress in 2005. Of particular use and accurate summation is a passage in the book Attorney Liability in Bankruptcy by Catherine E. Vance & Corinne Cooper:

"Ever since Congress first shifted reaffirmation approval from the courts to debtors' attorneys, those attorneys have faced a conflict in serving their clients. The client, not the lawyer has the ultimate authority to decide to reaffirm a debt, no matter how ill-advised the reaffirmation might be. Attorneys are advocates and legal representatives; controlling the client's conduct (so long as it is not illegal) is not he attorney's duty or right.

There are any number of reasons why a debtor might be tempted to reaffirm to retain collateral, maintain a relationship with a creditor, or settle dischargeability litigation, to name a few-despite the undue hardship that might result.

But the attorney's declaration must be meaningful, not a means to achieve the client's end. Courts have insisted that attorneys exercise independent judgment, declining to approve any reaffirmation the attorney believes will impose an undue hardship. No less will be expected under [BAPCPA}.

Indeed, as officers of the court, attorneys are forbidden from representing that reaffirming a debt imposes no undue hardship if it isn't so.

An attorney's refusal to provide the required certification is not the death knell for the client's reaffirmation. It simple triggers a hearing and review by the court.

It's true that the law of reaffirmation creates a conflict in the attorney's role of advocate, requiring attorney approval of decisions that belong to the client. But the law simply doesn't allow you to acquiesce to your client's wishes any more than it permits you to abdicate your responsibilities to the court in all cases by adopting a policy of blanket refusal to provide the certifications.

In the final analysis, the reaffirmation certifications involve the same analysis as any other paper presented to the court: sign and file only if you can do so with candor."

(Attorney Liability in Bankruptcy, Vance, Catherine E. and Cooper. Corrine, at 279)

i. Legitimate Disagreement with a Client - There will undoubtedly come a time when a Debtor wishes to sign a Reaffirmation Agreement that their attorney believes they should not sign. The question of what to do in that circumstance raises a few questions.

1. What is an attorney's duty to their client when the reason the attorney will not sign the Reaffirmation Agreement is that the budget as filed in Schedule I and Schedule J does not support the debt payment needed to reaffirm? When the issue revolves around budgetary concerns alone, then the attorney should inquire as to how the Debtor intends to afford this payment and if possible amend the schedules accordingly. If it is not possible to amend the schedules, but the Debtor still insists upon signing the Reaffirmation Agreement, the attorney should help the Debtor fill out Part D as well as the Motion that are typically provided with the agreement by the Creditor and send it back without the attorney signature to the Creditor for filing.

The next question becomes does the attorney that did not sign the agreement need to attend the hearing? Most Judges and anyone else with a hearing that day would prefer that attorneys attend these hearings with their clients, however it is up to the individual attorney to determine whether to appear at the hearing. Involved in that determination is the cost to the Debtor and their ability to pay as well as whether the attorney feels comfortable explaining the Debtor's reasoning for trying to reaffirm the debt when the Debtor does not have the ability to afford to do so.

2. What is an attorney's duty to their client when the reason the attorney will not sign the Reaffirmation Agreement is based on their legal opinion that signing the agreement would saddle the Debtor with debt of a kind that is unnecessary and thus unduly burdensome? When the issue involves a disagreement as to the prudency of reaffirming a debt and not just whether the Debtor can afford to do so, the attorney may feel that a conflict is being created in the attorney/client relationship. The attorney should counsel their client as to why they do not believe it is a good legal decision and then allow their client to make the decision. If the client insists on reaffirming a debt the attorney does not feel is in the best interests of their client, they can choose not to sign the agreement and proceed to send it back to the creditor without an attorney signature. The decision to attend the hearing in these circumstances is likely more difficult. As an attorney, you cannot advocate against your client, or break the attorney/client privilege. Therefore, unless you believe you can explain the Debtor's position to the court, and explain the reason you did not sign the agreement, if asked, without violating your duties to your client, you probably should not attend the hearing.

ii. Issues of Liability. - Dating back to the time in which the BAPCPA legislation was still being debated and scrutinized, through its passage and eventual implementation, there has been widespread speculation regarding issues of a Debtor's counsel's potential liability to the creditor for the reaffirmed debt it the Debtor were to default on the agreement. Discussions indicating that the requirement that Debtor's counsel certifies the Debtors ability to pay could create personal liability have been discussed in various legal journals and seminars (See Catherine E. Vance & Corinne Cooper, Nine Traps and One Slap: Attorney Liability under the New Bankruptcy Law, 79 Am. Bankr. L.J. 283 (2005)). The Nine Traps defense has even been used by Debtor's attorneys to defend themselves before various courts who have held hearings regarding the counsel's decision not to render advice to his client regarding reaffirmation agreements for fear of such liability. (See Minardi at 20,21)

Despite much hand wringing and debate, to date, now three and a half years after the effective date of BAPCPA, no such lawsuit by a creditor against a Debtor's counsel has occurred. Indeed, it appears unlikely that such a lawsuit would ever occur as it would likely unravel the entire balance between debtors, creditors and their legal counsel required for the consumer bankruptcy system to properly work. The entire reaffirmation system would come to a screeching halt were such a lawsuit filed and creditors, whose primary goal of the reaffirmation agreements is to receive payments, would essentially shoot themselves in the foot as no Debtor's counsel would ever sign a reaffirmation again. The authors of the Nine Traps argument themselves wrote a perfect summation of the argument and unlikely possibility of this issue ever arising:

"As a general rule, attorneys have no duty to non-clients. An exception to this is the case in which the attorney took an action or made a representation with the expectation that a third party would rely on it, and the third party did rely upon that action or representation.

The creditor can be expected to argue something like this against the attorney: "You certified that the debtor could make the payments. I would not have entered into this agreement but for your certification that she could. I relied upon that certification. But the debtor failed to perform. I have been damaged and you are the cause.
Is the attorney liable to the creditor as the guarantor of the debtor's reaffirmation agreement" We don't think so. There are enough waffle words in the statue that a clever attorney (one hired by the malpractice carrier, for example) can construct a defense. 'It was his opinion; there were facts not disclosed; there was a change in circumstances that he could not reasonably foresee' are some that come to mind.

What's more, the creditor will have a hard time convincing a court that its reliance was reasonable or even justifiable. There is an enormous body of case law discussing reliance under Code Section 523(a)(2)(A) and (B), which the courts can apply in the reaffirmation context. But here creditors face an additional hurdle: they are entitled to a wealth of information about the debtor's finances under various new provisions of the Code. The courts can and should view the creditor's reliance on the attorney's certification-or any other representation in a reaffirmation agreement, for that matter- in the context of what the creditors knew or should have known based on readily available information." (Attorney Liability in Bankruptcy, Vance, Catherine E. and Cooper. Corrine,at 279)

1. Creditors assistance in allaying fears of liability - Despite the unlikelihood of a creditor suing a debtor's attorney for certifying a reaffirmation agreement, there are steps creditors may take to provide "comfort language" in their reaffirmation agreements. Some creditors have already included the following language in their agreements and it is recommended that this be included in all agreements to set aside those remaining fears of debtors counsel.

"CREDITOR acknowledges that counsel does not warrant the ability of the debtor to perform the terms of the Reaffirmation Agreement and the signing of this declaration shall in no way be construed as a guaranty by counsel of the debtor's obligations under said Reaffirmation Agreement."

V. The Duty to Appear for Hearings Regarding Reaffirmation Agreements. - A further question in the reaffirmation process is presented when considering the issue of whether or not to appear at a hearing set by the court on a reaffirmation agreement. Section 524(d) of the Bankruptcy Code adds the requirement that a hearing must be held if the debtor was not represented by an attorney during the negotiation of a reaffirmation agreement. During those hearings the court is required to assure that disclosures regarding the legal effect of the agreement and voluntary nature of reaffirmation agreements are explained to the debtor in lieu of the same counseling that would ordinarily be provided by the debtor's legal counsel. Further, the court must determine that there is no undue hardship and that the reaffirmation is in the best interest of the debtor. Only at that point and after the court can affirm that all the required findings under Section 524(c)(6) have been made, can the reaffirmation be determined to be enforceable. Needless to say these hearings, particularly when dealing with an unsophisticated, unrepresented debtor can take a considerable amount of the court's time. In fact, the local bench has found its motion calls tied up with hours of hearings on reaffirmation agreements signed by debtors who agreed to retainer contracts with their attorneys that did not include counseling or representation for the reaffirmation process. The bench has indicated its displeasure with the situation both due to the hours of court time that could be avoided if the debtor's attorney were to simply counsel their clients, and for the fear of the debtors who are then left with insufficient understandings of the contracts they are attempting to reaffirm. Although there are certainly questions about whether or not the reaffirmation should be signed by counsel (as we discussed above) and what should or should not be said at any required hearing by counsel (as will be discussed below) there is one point that seems clear, counsel needs to make some form of representation before the Court as to what his stance is towards the reaffirmation agreement if the Court deems a hearing is necessary. Ideally, that stance would be made by an actual appearance by the attorney at any required reaffirmation agreement hearing.

a. Steps that Can Be Taken to Avoid Hearings - From the attorney perspective, many attorneys do include both consultation and representation of the debtors in negotiating reaffirmation agreements in their retainer contract. Most of said attorneys find that, as long as they have properly counseled their client, and that the monthly payment on the debt that has been reaffirmed is included in either the original Schedule J list of monthly expenses, or a subsequent amended Schedule J, there is no hearing required for their reaffirmation agreements and the amount of work required is no more than the time it takes to counsel the client and sign the agreements. Further, many debtor's counsels have also noted that they have had considerably fewer hearings on their reaffirmations when they maintain the practice of assuring that the combined monthly income listed on the Schedule I Statement of Income and the average monthly expenses listed on the Schedule J Statement of Household Expenses are equal. Many practitioners who have relied on what is referred to as the "negative budget" (meaning the monthly expenses on Schedule J are substantially higher than the combined monthly income on Schedule I) have found themselves defending their reaffirmation agreements before the court far more often than those whose income and expenses are equal or close. Section 524(m) requires the court to review the reaffirmation if the debtor's budget were to be a clear indication of that a presumption of undue hardship arises. Courts have thus far used these hearings as opportunities for the debtor and their counsel to explain and lay a foundation for the ability to pay on the reaffirmed debt despite having a budget that clearing indicates otherwise. (See In re Calabrese, 353 B.R. 925, 926 (Bankr. M.D. Fla. 2006)("A presumption of undue hardship occurs when the debtor does not have sufficient funds to make the required reaffirmation payments" and In re Laynas 345 B.R. 505 (Bankr. E.D. Pa 2006 and In re Wilson 363 B.R. 220 (Bankr. D.N.M. 2007) as cases that stand for the proposition that review is mandatory under 524(m) even where debtor is represented by counsel.) As has been pointed out by both the Bench and the bar, it is impossible to spend money you don't have, and accordingly, to create a budget that allows such a situation would certainly be open to question and would be prepared at debtor's counsel's own peril.

b. Hearings based on Disagreements between the Debtor and Counsel - Although both the Bench and the bar recommend that it is within the best practices of debtor's attorneys to represent their clients in reaffirmation agreements and at all hearings related to the reaffirmations, it is incorrect to believe that counsel should always sign the reaffirmation agreements their clients request for many of the reasons already discussed. The failure of counsel to sign the reaffirmation agreement under Section 524(c)(3), regardless of the reason, sends a clear statement to the court, that, in counsel's opinion, the agreement is not in the debtor's best interest and would trigger a hearing under Section 524(d). In situations where a hearing arises stemming from a reaffirmation agreement that was signed by the debtor and intentionally not signed by debtor's counsel, there are certainly many considerations that need to be considered before the hearing.

i. Issues regarding Conflicts of Interest and Privilege - Issues of conflict of interest may arise in the context of the hearing on a reaffirmation agreement on which debtor and his counsel disagree. Debtor's counsel faces the difficult decision of abstaining from the hearing and leaving the bench to guess as to the specifics of counsel's decision not to sign the reaffirmation, as compared to appearing and being stuck in the situation of potentially arguing against his own client. There is certainly no sure answer although it is recommended that counsel at least make his appearance at the hearing and, at let it be known that it they did in fact make a decision to not sign the reaffirmation agreement. However, what must be stated on the record under questioning from the bench certainly puts counsel in a precarious position. If counsel were to respond to questioning as to the reasoning of their failure to sign the reaffirmation, would an answer indicating their belief that it is not in the best interest of the debtor run afoul of Michigan Rule of Professional Conduct 1.7(b) Which states:

"A lawyer shall not represent a client if the representation of that client may be materially limited by ....the lawyers own interests unless: (1) the lawyer reasonably believes the representation will not be adversely affected; and (2) the client consents after consultation..."

Would making a representation to the Court in the course of a hearing violate Michigan Rule of Professional Conduct 1.6(b) regarding confidentiality of information which states:

"Except when permitted under paragraph (c), a lawyer shall not knowingly: (1) reveal a confidence or secret of a client; (2) use a confidence or secret of a client to the disadvantage of a client.."

All must be considered in how one answers questions at a hearing on a reaffirmation.

At this point there is no clear answer as to what should or shouldn't be said by counsel at a hearing where the debtor and their counsel disagree on whether the reaffirmation is in the debtor's best interest. A request has been made to the State Bar Ethics Committee requesting their opinion as to this issue. In the meantime, counsel clearly must individually decide what and how much information they should share with the court. Many attorneys fear the idea of appearing at a hearing for a reaffirmation they will not agree to sign. An alternative option advanced by this group involves the filing of a separate affidavit indicating that counsel indeed does not support the reaffirmation agreement. Proponents of this theory indicate that even if they appear at the hearing, the only testimony they could add without fear of creating conflict with their own client would be to assert that they are not in favor of the reaffirmation, and that the very same assertion can be made in an affidavit. Questions from the bench regarding why counsel believes the reaffirmation is not in the debtor's best interest beyond what is available in the pleadings would create a situation where counsel argues against his own client in court. This puts the attorney in the unenviable position of choosing between making assertions before the Court that contradict the desire of his own client, saying very little to the chagrin of the Court, or withdrawing from the case, which benefits no one. Other attorneys believe it is their obligation to attend the hearing, confirm their belief that the reaffirmation is not in the debtor's best interest, and spend the remainder of the hearing as their client's advocate while not delving further into their own reasons for not signing the reaffirmation. Despite these ethical dilemmas, failing to appear for the hearing entirely in situations where a hearing is required, regardless of how little counsel were to say, would likely cause more confusion and do a disservice to the debtor and the Court as they attempt to sort through the reaffirmation, despite whatever inconvenience there is to counsel.

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CBA Best Practices for Reaffirmation Agreements
A Debtor’s Attorney’s Duties to the Client regarding Reaffirmation Agreements.
By Detroit Bankruptcy Attorney Noel Aaron Cimmino and Heather McGivern
On behalf of the Detroit Consumer Bankruptcy Association