It is not uncommon for firms to use standard language in their account agreements that creates liens on Individual Retirement Accounts (IRAs). Two recent federal court decisions, however, suggest that granting such a lien on an IRA may constitute a prohibited transaction that causes these accounts to lose their tax exempt status, which in turn could potentially make IRAs subject to third-party creditor claims. These two decisions could have far-reaching implications for any firm that has used or still uses similar lien-creating language in their account agreements.

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Taking the lead from its recent decision in In re River Road Hotel Partners,1 in In re River East Plaza, LLC,2 the Seventh Circuit held that a debtor cannot avoid the lien retention prong of Section 1129(b)(2)(A)(i)3 by transferring an undersecured creditor’s lien to substitute collateral as indubitable equivalence pursuant to Section 1129(b)(2)(A)(iii).

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In re GALP Highcross Limited Partnership (Bankr. S.D. Tex.) Case no. 11-36741
In re GALP Waters Limited Partnership (Bankr. S.D. Tex.) Case no. 11-36743

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