On November 7, 2017, a panel of the Third Circuit, in an unreported decision, upheld the District Court’s determination that intended loss equaled the amount of concealed assets in a bankruptcy fraud case in which creditors were paid in full. U.S. v. Free, 2017 WL 5664671 (3d Cir. – Nov. 7, 2017). Significantly, Free filed for reorganization under Chapter 13 of the Bankruptcy Code, but he disclosed assets that exceeded his debts by several hundred thousand dollars.