Heralded by debtor’s attorneys as “a wonderful loophole”¹ in the Bankruptcy Code, a debtor who has primarily business, rather than consumer, debts can qualify for a speedy Chapter 7 discharge despite a high earning capacity that would permit the debtor to repay some, or even all, of her debt. Though rarely used, banks faced with a high-income debtor’s Chapter 7 case can move to convert the case to Chapter 11 under 11 U.S.C. §706(b) to force the debtor to repay some of her debt prior to receiving a discharge.