In a case of first impression, the Eleventh Circuit held that Roth IRAs are excluded from Georgia debtors’ bankruptcy estates under the Bankruptcy Code and Georgia’s garnishment statute. In Hoffman v. Signature Bank of Georgia (In re Hoffman), 2022 U.S. App. LEXIS 2119 (11th Cir. Jan. 24, 2022), the court reversed the district court’s affirmance of the bankruptcy court’s order concluding that the debtor’s Roth IRAs were not excluded from his bankruptcy estate.

Payment Orders were originally introduced in the CPC as a fast track route for creditors holding a financial instrument, such as a letter of credit or cheque, to obtain judgment against their debtor for what is a simple and indisputable debt. Payment Orders were rarely issued by the onshore UAE courts. In 2018, Cabinet Resolution No 57 of 2018 (the “2018 Cabinet Resolution”) significantly expanded the scope of application of Payment Orders by extending them to all admitted debts rather than simply those arising out of financial instruments only.

An IRA owner could not rely on a Florida exemption to shield his IRA account from creditors after engaging in prohibited acts of self-dealing with his IRA funds, the Eleventh Circuit held in Yerian v. Webber, 2019 WL 2610751 (11th Cir. June 26, 2019). The IRA owner, Keith Yerian, opened a self-directed IRA. The IRA was governed by two contracts.