In a comprehensive report issued last week, the American Bankruptcy Institute Commission on Consumer Bankruptcy proposed recommendations that would allow student loans to be easier to discharge in bankruptcy, citing the staggering $1.5 trillion in student loan debt held in the United States and the current difficulties with discharging this type of debt in bankruptcy.

In In re Cook, 2014 Bankr. LEXIS 67 (B.A.P. 8th Cir. Jan.

In a recent decision ^[1] arising from the In re Residential Capital LLC, et al.