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The Absolute Priority rule is alive and well for Chapter 11 cases

I. Explanation of absolute priority rule Consumer debtors that do not qualify for protection under Chapter 7 or Chapter 13 of the Bankruptcy Code, are left with filing under Chapter 11, where they will come face-to-face with the absolute priority rule (the “APR”).  The APR is a cornerstone of bankruptcy law.  It was first developed by the Supreme Court in the late nineteenth-century to deal with widespread collusion in railroad reorganizations. To prevent unfair deals between senior creditors and equity holders, the Court held that “stockholders are not entitled to any share of the capital stock nor to any dividend of the profits until all the debts of the corporation are paid.”[1] Simply stated, the APR establishes a hierarchy of rights in bankruptcy proceedings, commencing with secured creditors at the top of the heap and ending with equity holders (or the debtor when the case involves an individual) at the bottom.  This rule recognizes that equity holders, or debtors, have less rights and entitlement to recovery of a bankrupt enterprise’s assets because they stood to reap the most if the entity succeeded.  It also recognizes that equity-holders generally control the allocation of value and absent limitations, they would unfairly allocate a disproportionate share to themselves.  “This rule assured those who did business with the corporation that if the business were dissolved the creditors would be paid before the insiders would recover their investments. In case of collapse, the creditors could count on payment in full before equity collected anything from the business assets.”[2] Individuals debtors may find problematic their efforts to satisfy the APR because a Chapter 11 plan cannot be confirmed over the objection of a dissenting class of creditors if value is being allocated to the debtor, unless secured creditors and unsecured creditors are paid in full (see below discussion on the requirements for full payment), or the Plan meets the stringent “new value” test.[3]  On a practical level, an individual debtor cannot retain any property in a  Chapter 11,[4] unless all senior creditors are paid in full, including over an extended time period; all impaired classes accept the plan; or the debtor contributes what is known as “new value” in exchange for retaining its equity interests. [5] II. How the rule applies in chapter 11 The APR evolved beyond a judicially created doctrine when Congress codified it as part of the Bankruptcy Code in 1978.[6] To confirm a Chapter 11 plan, all impaired classes must accept the plan.[7]  However, a court may still confirm the plan (i.e., through a “cramdown”) if an impaired class rejects it, but only if the plan is otherwise “fair and equitable” within the meaning of the Bankruptcy Code, or, in some cases, the debtor contributes “new value” in accordance with that exception to the APR, and satisfies certain other criteria enumerated in §§1129(a)(1) through (a)(14).[8]  To be fair and equitable, a plan must provide property of a value, as of the effective date of the plan, equal to the allowed amount of a creditor’s claim or it must satisfy the APR.  A plan can satisfy the APR if value is allocated in accordance with the APR – e.g., if unsecured creditors are not paid in full, the debtor receives no property.  Full payment to senior classes does not necessarily require a single payment of the full amount owed and does not have to be immediate or in accordance with existing debt instruments (except for loans on an individual’s principal residence, which cannot be modified), so long as the payment stream is accompanied with an appropriate interest rate and is otherwise “fair and equitable.” Thus, the deferred cash payments can be structured in many ways, so long as the restructured terms are “fair and equitable” in the view of the Court.      This makes the cramdown of a Chapter 11 plan difficult for individual debtors that have a lot of debt and limited means to repay that debt.[9]    III. After BAPCPA a minority of lower courts have held that the APR no longer applies in individual chapter 11 cases. In 1988, the Supreme Court unanimously held the APR applied in individual Chapter 11 cases.[10] However, the Bankruptcy Abuse Prevention and Consumer Protection Act (“BAPCPA”) that was enacted in 2005, led some courts to question whether the APR was still applicable in individual Chapter 11 cases.[11]  BAPCPA modified §1129(b)(2)(B)(ii) and added §1115.  The interaction between these two provisions has generated some decisions holding that the APR no longer applies when the debtor is an individual, although the majority view, which is followed by five Circuit Courts, holds otherwise – i.e., the APR still applies and was not abrogated by BAPCPA.  Section 1129(b)(2)(B)(ii) provides that, “in a case in which the debtor is an individual, the debtor may retain property inclu… Read More
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Discharge of debts in Chapters 7 and 13; important differences you should know

Through a Chapter 13 payment plan, a debtor may discharge multiple types of debt that cannot be discharged in a Chapter 7 bankruptcy (a liquidation). Thus, if you qualify for a Chapter 13 bankruptcy, and your debts would be nondischargeable in a Chapter 7, Chapter 13 may be a better option. The most common debts that can be discharged in Chapter 13 bankruptcy, but not in a Chapter 7 bankruptcy include: Debts arising out of willful and maliciously property damage: If a court finds you willfully or maliciously damaged another person’s property, the resulting debt cannot be discharged in a Chapter 7 bankruptcy. But you can discharge debts related to willful and malicious property damage in Chapter 13 bankruptcy. Willful or malicious acts that cause personal injury or death cannot be discharged in either a Chapter 7 or Chapter 13 bankruptcy.Tax Obligations: If you incur a debt to pay off nondischargeable tax obligations (such as paying your tax liability with a credit card), you can discharge that debt in Chapter 13 bankruptcy, but not in Chapter 7.Certain debts incurred in divorce or separation proceedings: Domestic support obligations, such as alimony or child support, cannot be discharged in either a Chapter 7 or a Chapter 13 case. However, other types of debts to your spouse, former spouse, or child through a divorce decree, property settlement, separation agreement, or other related proceeding, can be discharged in a Chapter 13 bankruptcy. Such dischargeable obligations typically include debts assigned to you in the course of divorce or separation proceedings (e.g., obligation to pay off a joint credit card debt).Certain fines and penalties owed to the government: Other than criminal fines, fines and penalties payable to the government are generally dischargeable in a Chapter 13 bankruptcy. In contrast, a Chapter 7 bankruptcy will not discharge most government fines and penalties.Debts denied discharge in a prior bankruptcy: If you filed for bankruptcy previously and the court denied your discharge, you can’t eliminate those same debts in a subsequent Chapter 7 bankruptcy. However, you may be able to discharge those in Chapter 13.  Loans against your retirement account: A loan against your retirement account can be dischargeable in Chapter 13 bankruptcy, but not in Chapter 7 bankruptcy. There are, however, reasons to keep repaying such loans in a Chapter 13 bankruptcy. The amount you are required to pay under Chapter 13 plan depends upon the amount of your disposable income. Repaying a loan against your retirement funds reduces the amount of your disposable income, so it often makes sense to keep repaying that loan because the payments benefit you while reducing the amount you are required to pay other creditors. The above are just some of the factors to consider when deciding whether a Chapter 13 bankruptcy makes sense for you. Feel free to contact our office for a free consultation to further discuss whether a Chapter 13 bankruptcy is right for you. Read More
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5 Mortifying Reasons Mortgage Applications End Up in the 'Reject' Pile

An interesting article in Realtor.com explains why mortgage applications are sometimes denied.  According to the article a recent Federal Reserve study concluded that one out of every eight home loan applications (12%) ends in a rejection.  The causes mainly relate to low credit scores and Realtor.com identifies at least five reasons a score can suffer from consumer activity (or inactivity). They include:  1. You didn’t use credit cards enough “While a poor credit history riddled with late payments can certainly call your application into question, it’s just as bad, and perhaps worse, to have little or no credit history at all. Most lenders are reluctant to fork over money to individuals without substantial credit history. According to a recent report by the Consumer Financial Protection Bureau, roughly 45 million Americans are characterized as “credit invisible”—which means they don’t have a credit report on file with the three major credit bureaus (Equifax, Experian, and TransUnion). 2. You opened new credit cards recently “New credit card applications can ding your credit score by up to five points, says Beverly Harzog, a consumer credit expert and author of “The Debt Escape Plan.” 3. You missed a medical bill “Credit cards aren’t the only debt that count with a mortgage application—unpaid medical bills matter, too. When you default on medical bills, your doctor’s office or hospital is likely to outsource it to a debt collection agency, says independent credit expert John Ulzheimer. The debt collector may then decide to notify the credit bureaus that you’re overdue on your medical payments, which would place a black mark on your credit report. That’s a red flag to mortgage lenders. 4. You changed jobs “[M]ortgage lenders like to see at least two years of consistent income history when approving a loan. As a result, changing jobs shortly before you apply for a mortgagecan hurt your application. 5. You lied on your loan application “This one seems painfully obvious, but let’s face it—while it may be tempting to think that lenders don’t know everything about you financially, they really do their homework well! So no matter what, be honest with your lender—or there could be serious repercussions. Exaggerating or lying about your income on a mortgage application, or including any other other untruths, can be a federal offense. It’s called mortgage fraud, and it’s not something you want on your record.” Read More
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Bankruptcy Filings among Elderly Increased Exponentially over Last 25 Years

According to an article posted today in the New York Times by Tara Segal Bernard, “[f]or a rapidly growing share of older Americans, traditional ideas about life in retirement are being upended by a dismal reality: bankruptcy.” According to Ms. Bernard, “[t]he signs of potential trouble — vanishing pensions, soaring medical expenses, inadequate savings — have been building for years.”  A large part of her conclusions are drawn from a recently published study by the Consumer Bankruptcy Project, which found that the “rate of people 65 and older filing for bankruptcy is three times what it was in 1991, the study found, and the same group accounts for a far greater share of all filers.”    Ms. Bernard further reports that: Driving the surge, the study suggests, is a three-decade shift of financial risk from government and employers to individuals, who are bearing an ever-greater responsibility for their own financial well-being as the social safety net shrinks.  The transfer has come in the form of, among other things, longer waits for full Social Security benefits, the replacement of employer-provided pensions with 401(k) savings plans and more out-of-pocket spending on health care. Declining incomes, whether in retirement or leading up to it, compound the challenge.  As the study, from the Consumer Bankruptcy Project, explains, older people whose finances are precarious have few places to turn. “When the costs of aging are off-loaded onto a population that simply does not have access to adequate resources, something has to give,” the study says, “and older Americans turn to what little is left of the social safety net — bankruptcy court.” “The forces at work affect many Americans, but older people are often less able to weather them, according to Professor Thorne and her colleagues in the study. Finding, and keeping, one job is hard enough for an older person. Taking on another to pay unexpected bills is almost unfathomable.  Bankruptcy can offer a fresh start for people who need one, but for older Americans it ‘is too little too late,’ the study says. ‘By the time they file, their wealth has vanished and they simply do not have enough years to get back on their feet.’” Ms. Barnard also cites statistics from the Federal Reserve’s survey of consumer finances, via the Consumer Bankruptcy Project, showing that filings by people in the 55 to 64 age group increased by 66% from 1991 to 2016 and filings by people in the 65 to 74 age grou increased by 204% over the same period.  According to Ms. Bernard: The data gathered by the researchers is stark. From February 2013 to November 2016, there were 3.6 bankruptcy filers per 1,000 people 65 to 74; in 1991, there were 1.2.  Not only are more older people seeking relief through bankruptcy, but they also represent a widening slice of all filers: 12.2 percent of filers are now 65 or older, up from 2.1 percent in 1991.  The jump is so pronounced, the study says, that the aging of the baby boom generation cannot explain it. If you would like more information regarding bankruptcy filings and would like to speak to one of our experienced attorneys, please call (312) 878-6976 or fill out a contact form here. Read More
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Experts predicting increased ilIiquidity and link it to the climate that led to the 2008 crisis

According to a recent report by Morgan Stanley “market liquidity across assets is in decline” and  “low liquidity were the fundamental triggers of the 2008 crisis.”  Those bankruptcy practitioners that had first hand experience of the 2008-2010 turmoil, will recall the frustration of not being able to help clients workout of a distressed situation because of the lack of liquidity (e.g., alternatives).  Often bankruptcy was the only alternative and even that option was less than optimal because the market for additional capital or options was broken.  Liquidation was often the only option.    One example cited by Morgan Stanley relates to corporate bonds.  According to their report: “Dealer holdings of corporate bonds have shrunk from 3% of the market to just 0.3% today. While this means that dealers themselves have less to liquidate, their capacity to move risk to a new buyer may be limited and require larger repricing of the asset class in times of stress.”  The repricing is likely to mean reduced value for corporate bonds and may result in other strategies for offloading such positions.  One such strategy might be vulture buying of this asset class and potentially an “own to loan” strategy or a liquidation strategy for certain asset classes.   Morgan Stanley cites another example related to public debt.  According to Morgan Stanley, in the recent past, central banks built large positions in bonds.  “As central banks built these positions, liquidity in the affected assets was excellent. It’s hard to imagine anything better for liquidity than the presence of a steady, deep, well-telegraphed bid. But these forces are now swinging in the other direction. The Fed’s purchases have already begun to reverse, the ECB’s are likely to over the next six months, and with close to half of its bond market already owned by the BoJ, it will eventually face a constraint.” Given that the U.S. economy is in the late stages of an extended recovery that is close to a record-setting duration, and given the near certainty that the economy operates like a pendulum, the open question is not “if” but “when” will the U.S. economy stumble, how bad will it get and what will it mean for bankruptcy and other workout professionals.     If you would like more information regarding bankruptcy filings and would like to speak to one of our experienced attorneys, please call (312) 878-6976 or fill out a contact form here. Read More
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Law360 Satisfaction Survey finds that student loans are burdening lawyers too.

According to Forbes magazine, “student loan debt is now the second highest consumer debt category – behind only mortgage debt – and higher than both credit cards and auto loans and according to Make Lemonade, there are more than 44 million borrowers with $1.3 trillion in student loan debt in the U.S. alone. The average student in the Class of 2016 has $37,172 in student loan debt.” Law360, a legal publication that covers a wide range of practice areas and topics, conducted a Satisfaction Survey of lawyers to ascertain how student loan debt affects today’s practitioners.  According to their data: 1. There was a correlation between high levels of debt and high levels of stress among lawyers. 2. Nearly a third of attorneys who graduated within the past five years reported having six-figure student debt, and attorneys in this category were more likely to report that they feel stressed all the time. Debt also correlates with delays in major life events like marriage or having children, as well as a desire to leave a current job. 3. Nearly three-quarters of the respondents who had accumulated between $100,000 and $250,000 in student loans said they had to delay a major life event for financial reasons. That number jumped to 78 percent for those with more than $250,000 in student debt. 4. The portion of attorneys borrowing more than $100,000 for their education hit 60 percent in recent years, up from 26 percent during the 1990s, a Gallup poll has found. And the average median starting salary for 2016 law school graduates, according to the National Association for Law Placement, was $65,000. Read More
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America is heading for a level of income inequality that hasn't been seen since 1928

Economists have noted that the level of income inequality between the top 1% and the rest of the country is approaching levels last seen in 1928, which, of course, was just before the tragic financial meltdown that pre-dated, or even caused, massive impacts in the U.S. and the rest of the world. The obvious implication of this data is that another meltdown looms on the horizon.  For further insight into this dynamic, FactorLaw recommends the this article published in Money Watch. Read More
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Discharging Student Loans - one success and one failure

In Janice Faye Hopson v. Illinois Student Assistance Commission and U.S. Department of Education, Adv. No. 16 A 206, (Bankr. N.D. Ill. June 22, 2018), the court ruled against a chapter 7 debtor trying to discharge her student loans. The debtor was a 63-year old social worker who asserted that if she were forced to repay her student loans over a ten-year period, she would have to pay $1,111 per month, which was more than she could afford in light of her limited income consisting mainly of social security. The debtor consolidated all of her student loans into one $57,186 Federal Family Education consolidated loan and filed an action to discharge this debt. Between 2014 and 2016, the debtor had temporary social work assignments earning less than $20,000 in 2014, approximately $26,000 in 2015 and just over $20,000 in 2016. In August, 2016, the debtor moved to Georgia for better employment opportunities and started out as a bus driver for Fulton County Community Schools where her average monthly net pay was $1395.86. She then stopped working as a bus driver in August, 2017 when she began working at her current job as a Case Manager with the Georgia Division of Family and Children Services (“DFCS”) making a gross salary of $42,816.00 ($2439.83 net monthly income). Her monthly expenses were $2,480.26 per month. During the trial, the Court concluded that the debtor could achieve potential cost savings of approximately $900 per month by, among other things, moving from a 2 bedroom apartment into a one bedroom, stopping 401K contributions and stopping payments on a time share she acquired 15 years ago. In finding the loans non-dischargeable, the court first concluded that with the expense cutbacks discussed in the opinion, the debtor can make monthly payments on her student loans while enjoying a substantial standard of living, which she is now doing. According to the court, the debtor “has not met the first Brunner prong by a preponderance of the evidence that repayment of her student loans would cause her to not have a minimal standard of living.” Although not directly relevant to its decision because the debtor failed to meet the first prong of the Brunner test, the court also noted that the debtor’s “student loans are currently enrolled in !BR plans – her monthly payments are zero.” Further, even if the debtor retired in two years and was limited to social security income, “the drop in income would very likely keep her !BR payments at zero dollars per month.” Conversely, in Janees L. Martin v. Great Lakes Higher Education Group, Adversary No. 16–09052 (Bankr. N.D. Iowa February 16, 2018), the bankruptcy court for the Northern District of Iowa ruled in favor of a debtor who was seeking to discharge $230,000 in student loans related to the debtor’s bachelor’s degree, law degree, and Masters of Public Administration degree from the University of South Dakota between 1989 and 1993. the original principal amount of the loans was $48,000, but grew to over $200,000, as a result of interest. The debtor was 50 years old, she was currently living in South Dakota with her husband, who was 66, and their 2 daughters, 423 and 21. The debtor was unemployed, after losing her last job in 2008. the bankruptcy court found that the Debtor looked for employment more or less continuously after her job. She had applied for hundreds of jobs, law and non-law related, in and around Sioux Falls South Dakota and Sioux City Iowa. In the 9 years since her last job the debtor received only a few interviews and no offers of employment. The bankruptcy court also found that the debtor very much wanted to work and support herself and her family. over the years, the debtor paid a total of $30,077.76 against her student loans, of which $26,040.78 went to interest and the balance to principal. most of the debtor’s day was devoted to taking care of her to college-age daughter’s and taking care of the household. The debtor and her family depended entirely on her husband’s income, whichtotal $39,243 from employment and a pension. The bankruptcy court analyzed the dischargeability issue under the “more flexible totality of the circumstances” test employed in the 8th Circuit, instead of the more commonly used Brunner test. The “totality of the circumstances” test requires the Court to examine the debtor’s undue hardship arguments “on the unique facts and circumstances that surround the particular bankruptcy.” Andrews v. South Dakota Student Loan Assistance Corp. (In re Andrews), 661 F.2d 702 (8th Cir. 1981). In considering the facts of a particular case, the Court must focus on three factors: “(1) the debtor’s past, present, and reasonably reliable future financial resources; (2) the debtor’s reasonable and necessary living expenses; and (3) any other relevant facts and circumstances.” Id. The debtor must prove, by a p… Read More
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Merchant Cash Advances – A Trap for the Unwary

Small business owners should think carefully before taking out merchant cash advances, which is a form of financing that is heavily marketed. Small businesses, like any other business, need cash to run. It can be difficult, though, for some small businesses to get access to financing when they need it. Whether this is because they have poor credit, the amount they need to finance is too small, or some other reason, small businesses often find that traditional financing sources, such as banks, do not want to work with them. Some small businesses turn to merchant cash advances. While merchant cash advances may seem like regular loans, there are many important differences to watch out for. First, many merchant cash advance companies take the position that their product is not a loan at all, but a purchase of the small business’s accounts receivable. This is an important difference because borrower protections such as usury laws may not apply if the merchant cash advance is a purchase instead of a loan. Second, merchant cash advances can be very expensive. Not only is the interest rate often very high (and difficult to figure out), but there are often hidden fees that can cripple a small business in unexpected ways. For example, one contract we recently reviewed had a $5,000 fee if the small business obtained any other “funding or loans” without the merchant cash advance company’s consent. Under such a broad provision, the merchant cash advance company could argue that using a company credit card or ordering inventory on credit violates the contract and incurs the $5,000 fee. The same contract also charged a fee of 5% of the outstanding loan amount each time the small business requested a reduction of the required payment, even for a limited time period. So if a small business finds the payments unaffordable and tries to negotiate a settlement, the merchant cash advance only becomes more unaffordable. This would also arguably apply to each request, regardless of whether the merchant cash advance company agrees to the request. Third, merchant cash advance contracts may have other unexpected terms. Some contracts have “confession of judgment” clauses. These clauses allow the merchant cash advance company to get a judgment against a small business that defaults, often in a court far away from the small business’s home and without giving any notice to the small business. The merchant cash advance company can then begin taking steps to collect its judgment. Often, the first time a small business learns about the judgment is when it discovers that its bank account is frozen. By then it may be too late: it is very difficult in some courts to get relief from judgments by confession. There may be legal options available to small businesses that would bring better results than taking out a merchant cash advance. For example, a FactorLaw lawyer may help negotiate a workout with an existing lender or pursue an assignment for the benefit of creditors or chapter 11 bankruptcy reorganization. Similar options may be available for small business that have already taken out an unaffordable merchant cash advance and are looking for a way to deal with it. We encourage you to e-mail or call us before you make the decision to take out another merchant cash advance. Read More
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Rising home values are nudging more Chicago-area homeowners to tap the equity in their homes via lines of credit.

There appears to be an increase in consumer debt that is reminiscent of the near-collapse of 2008-2010. A recent article in Crain’s Chicago Business (reprinted below), reports that consumers are using increases in home equity to secure further borrowing and spending. Whether the increase in borrowing secured by second liens on homes will backfire and lead to a crisis like the one that started in 2008, remains to be seen, but the trends do indicate that consumer debt is rising, which makes consumers vulnerable to unforeseen events, such as job loss or income reduction. Reprinted from Crain’s Chicago Business. http://www.chicagobusiness.com/realestate/20180619/CRED0701/180619876/more-home-equity-loans-issued-in-chicago#utm_medium=email&utm_source=ccb-morning10&utm_campaign=ccb-morning10-20180619 In the first quarter of 2018, about 22 percent of home loans in the Chicago area were home equity lines of credit, according to Attom Data Solutions, a property information firm based in Irvine, Calif. That is, more than one of every five home loans issued was a home equity line. It was the first time the figure was over 20 percent since the last quarter of 2008. For most of the time between those dates, home equity loans were 15 percent or less of Chicago-area home loans, and for a stretch of three years, they stayed below 10 percent. A home equity line of credit does not entail refinancing an existing mortgage, but attaches borrowing power to the equity homeowners have. It is, essentially, a credit card backed by the homeowners’ stake in their house. In a metropolitan area with the nation’s largest number of homeowners who are underwater on their mortgage, the good news in the rise of home equity lines of credit is that there are large numbers of homeowners who have sufficient equity to borrow against it. “Prices have really rebounded in my neighborhood,” said Raminder Chadha, who last week took out a line of credit on the North Center home he owns with his wife, Nabeelah. “I thought it was time to get a cushion ready” in case of coming spikes in property taxes or other home-related expenses, he said, so when his debt on the house dropped to 70 percent of its value, he took out a line of credit for about 7 percent, still staying within the recommended 80-percent debt threshold. This sort of borrowing can turn into a cash infusion into the local economy, Daren Blomquist, senior vice president at Attom, said in an email. “(Home equity lines) used properly can be good for the wider economy, as they will help put the housing wealth to work in the economy,” Blomquist wrote, “particularly in the home improvement and construction sectors, while also helping to add value back into homes.” While abuse of home equity lines of credit may have contributed to the housing bust—some homeowners tapped equity for items unrelated to the homes’ value, such as travel, boats or weddings—Blomquist points out that under the new tax structure unveiled in 2017, interest paid on loans used for anything other than home improvements is not tax-deductible. That should reduce the appeal for people who would “treat their home as an ATM machine,” he wrote, and mostly limit the use of the loans to fixing up homes. Across the country, home equity loans were 19.2 percent of all home loans during the first quarter, Attom reported. Among the nation’s 10 largest cities, Chicago had one of the largest shares of loans that were home equity, after Philadelphia (26.2 percent of loans during the quarter) and Boston (26.1 percent). One reason for the increase—and for potential future growth in home equity loans’ popularity—may be that such loans could be the more cost-effective way of two primary tools homeowners have for spending equity, said a BMO Harris Bank executive. Interest rates on mortgages are rising, said Paul Dilda, head of retail strategy, products and segments for BMO Harris, so “home equity borrowing is likely to increase as borrowers will prefer to tap the equity in their homes rather than refinance their low-rate mortgages” to get at the equity. While the number of Chicago-area borrowers who took out home equity loans is rising, it’s not rising as fast as the national figure, possibly the result of our slower-than-average recovery leaving many homeowners still underwater with no equity to tap. About 11,280 Chicago-area homeowners took out the loans in first-quarter 2018, according to Attom, up 7 percent from the year-earlier figure. Nationally, the number of such borrowers increased 14 percent in the same period. In the fourth quarter of 2008, the last time home equity loans’ share was over 20 percent, Chicago homeowners took out a little more than 12,500 such loans, or 22 percent of the roughly 57,400 home loans issued. At 22.5 percent, the first-quarter 2018 share of Chicago loans that were home equit… Read More
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