H1: Can You File Chapter 7 After Filing Chapter 13? Your Complete Guide
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H1: Can You File Chapter 7 After Filing Chapter 13? Your Complete Guide
H2: Understanding the Basics: Chapter 7 & Chapter 13
It’s funny, isn't it? Life has this uncanny knack for throwing curveballs, just when you think you’ve finally got a handle on things. You’ve made a tough decision, perhaps swallowed a bit of pride, and embarked on a Chapter 13 bankruptcy, thinking, "Okay, this is it. This is my path to financial recovery." You’ve committed to a payment plan, you’re making your sacrifices, you’re looking ahead. And then, bam! Another unexpected event – a job loss, a medical emergency, a business failure – hits you square in the face, making that carefully constructed Chapter 13 plan feel like a sandcastle against a rising tide. Suddenly, you’re wondering, "Wait, can I even do this again? Is there another option? Can I file Chapter 7 after Chapter 13?" It’s a question that often comes steeped in frustration, fear, and a sense of utter exhaustion, and believe me, I’ve seen that look on countless faces. It's a heavy question, loaded with implication, and it's precisely what we're going to unravel here, piece by painful piece, until you have a crystal-clear understanding.
H3: The Core Question: Filing Chapter 7 After Chapter 13
Let’s not beat around the bush or sugarcoat it. The short answer to whether you can file Chapter 7 after Chapter 13 is a resounding, albeit conditional, "Yes." But oh, the conditions! It’s like being told you can have dessert after dinner, but only if you’ve eaten all your vegetables, done your homework, cleaned your room, and then probably solved a few calculus problems just for good measure. It’s not a simple, straightforward "yes" where you just waltz into court and declare a new bankruptcy. There are specific rules, waiting periods, eligibility requirements, and a whole lot of strategic thinking that goes into making such a move. This isn't just a legal maneuver; it's often a deeply personal and emotional one, signifying another significant shift in your financial landscape, and sometimes, another blow to your sense of stability.
When folks first come to me with this question, there’s often a palpable sense of desperation in their voice. They’ve already gone through the arduous process of filing Chapter 13, which is, let's be honest, a multi-year commitment. It’s a serious undertaking, demanding discipline and consistent effort to make those monthly payments. So, to even consider another bankruptcy, especially a Chapter 7, implies a level of financial distress that has pushed them beyond their breaking point, beyond what their Chapter 13 plan could possibly accommodate. They’re not looking for a shortcut; they’re looking for a lifeline. They’re looking for a way out of a financial quagmire that has only deepened since their initial filing. It’s crucial to understand that bankruptcy, in any form, is a tool for a fresh start, not a financial game. The laws are designed to provide relief, but also to prevent abuse. Therefore, the ability to switch from one chapter to another, or to file sequentially, is heavily regulated, ensuring that only those genuinely in need, and who meet specific criteria, can pursue such a path. We're talking about intricate timing rules, the impact of prior discharges, and a careful consideration of your current financial situation, which, let’s face it, is probably far worse than it was when you first filed Chapter 13. This isn't a decision to be taken lightly, nor one to be navigated without expert guidance, because the consequences of getting it wrong can be severe, potentially delaying your discharge or even leading to your case being dismissed.
Pro-Tip: Don't Assume!
Never assume that because you qualified for Chapter 13, you'll automatically qualify for Chapter 7, or vice-versa. The eligibility criteria, particularly the means test for Chapter 7, are distinct and can be a significant hurdle. Always re-evaluate your full financial picture with an attorney.
H3: What is Chapter 7 Bankruptcy?
Alright, let’s rewind a bit and establish a solid foundation, just to make sure we're all speaking the same language. If Chapter 13 is like a long-distance marathon where you pay off a portion of your debts over three to five years, Chapter 7, in many ways, is a sprint. It’s often referred to as "liquidation bankruptcy," and that term, while accurate, can sound a bit scary, conjuring images of losing everything you own. But for the vast majority of people who file Chapter 7, that’s simply not the reality. Its primary purpose is to provide a relatively quick and complete discharge of most unsecured debts – think credit card balances, medical bills, personal loans, and sometimes even old utility bills. The discharge is the legal order that says you no longer owe those debts, offering what many describe as an unparalleled sense of relief, a true financial reset button.
The core idea behind Chapter 7 is that if you don't have enough disposable income to make meaningful payments to your unsecured creditors, and your assets fall within certain protected categories (known as exemptions), then the law allows you to wipe the slate clean. A bankruptcy trustee is appointed, and their job is to identify any non-exempt assets you might have. These are assets that are not protected by state or federal exemption laws. If such assets exist, the trustee can sell them and distribute the proceeds to your creditors. However, and this is a crucial point that often surprises people, most Chapter 7 cases are "no-asset" cases. This means the debtor’s property is entirely covered by exemptions, and there’s nothing for the trustee to liquidate. Imagine a client I had, Sarah, a single mom working two jobs. She had a modest car, some basic furniture, and a small amount in her checking account. Her house was rented. When she filed Chapter 7, she was terrified of losing her car, which was essential for her commute. But because its value fell within her state’s exemption limits, the trustee had no interest in it. Her discharge came through, and she kept everything she needed, finally able to breathe without the crushing weight of medical bills from a past illness.
Eligibility for Chapter 7 is primarily determined by the "means test." This isn't just a quick glance at your bank account; it’s a detailed calculation that compares your income to the median income for households of similar size in your state. If your income is below the median, you generally pass the means test and are presumed eligible for Chapter 7. If your income is above the median, it gets more complicated, requiring a look at your disposable income after allowed expenses. The goal is to determine if you truly lack the ability to repay your debts through a Chapter 13 plan. If the court determines you do have the ability to pay, you might be required to file Chapter 13 instead. This is why the means test is such a critical gatekeeper for Chapter 7. It ensures that this powerful tool for debt elimination is reserved for those who genuinely need it and aren't simply trying to avoid repayment when they have the capacity to do so. The entire process, from filing to discharge, typically takes about four to six months, which is significantly faster than the multi-year commitment of a Chapter 13 plan. It’s a rapid, often life-changing shift, and for many, it’s the only viable path to truly escape the suffocating grip of overwhelming debt.
Insider Note: The "Fresh Start" Myth
While Chapter 7 offers a "fresh start," it's not a magic wand that erases all financial consequences. Your credit score will take a hit, and certain debts (like most student loans, recent taxes, and child support) are generally non-dischargeable. It's a new beginning, but one that requires careful financial planning moving forward.
H2: The Road from Chapter 13 to Chapter 7: Key Considerations
Navigating the transition, or even the possibility of a transition, from a Chapter 13 to a Chapter 7 filing is where things get genuinely intricate, where the rubber meets the road, so to speak. It’s not just a matter of deciding you want to switch; it’s about understanding the complex interplay of legal rules, timing restrictions, and the very real impact this will have on your financial future. Think of it like this: you’ve been driving on a winding, uphill road (Chapter 13), making slow but steady progress, and suddenly you hit a massive roadblock. Now you’re looking at a different, faster highway (Chapter 7), but there are specific on-ramps and off-ramps you have to use, and you can’t just jump from one to the other without checking your mirrors, signaling, and making sure the path is clear. This isn't a casual detour; it's a significant change in trajectory for your financial life, and it demands precision and foresight.
The decision to move from Chapter 13 to Chapter 7 usually stems from a fundamental inability to maintain the Chapter 13 payment plan. Perhaps your income dropped drastically, or you faced an unforeseen expense that made your monthly plan payments utterly impossible. Or maybe, and this is often overlooked, the value of your assets changed, or your debt structure shifted in a way that makes Chapter 13 no longer the most advantageous path. For example, if you had a significant amount of unsecured debt that was going to be paid back at a low percentage through your Chapter 13 plan, but now your income has plummeted, converting to Chapter 7 could allow for a full discharge of those debts without any repayment. This isn't a sign of failure; it's often a pragmatic recognition that circumstances have changed beyond your control, and the original plan is no longer viable or optimal. It's about adapting, about finding the best legal tool for your current situation, not the one you were in a few years ago when you first filed.
H3: The 8-Year Rule: Discharge from a Prior Chapter 7
This is perhaps one of the most critical rules to grasp when considering a Chapter 7 filing after a Chapter 13. The Bankruptcy Code has specific waiting periods between different types of bankruptcy discharges, and these aren't suggestions; they are hard-and-fast rules. One of the most common scenarios that people encounter, and sometimes misunderstand, involves the "8-year rule." This rule dictates that you cannot receive a discharge in a Chapter 7 case if you have already received a discharge in a prior Chapter 7 case filed within the preceding eight years. It's designed to prevent serial filings of Chapter 7, ensuring that the "fresh start" isn't abused by individuals who might try to repeatedly wipe out debts without a significant change in circumstances or an attempt at repayment.
Now, here's where it gets interesting in the context of Chapter 13. If your previous bankruptcy was a Chapter 7, and you received a discharge, you must wait eight years from the date you filed that Chapter 7 case before you can receive a discharge in a new Chapter 7 case. This means if you initially filed Chapter 7, got your discharge, and then later filed Chapter 13 because new debts piled up or you needed to save an asset, and now you're considering converting that Chapter 13 to a Chapter 7, you need to look back at the original Chapter 7 filing date. If eight years haven't passed, you simply won't be able to get a Chapter 7 discharge. You might be able to convert to Chapter 7, but the court won't grant a discharge, which pretty much defeats the purpose for most people. I remember a client who came in, convinced he could convert his Chapter 13. We looked at his history, and lo and behold, he had a Chapter 7 discharge seven years ago. He was heartbroken. We had to explain that while he could technically convert, he wouldn't get the debt relief he desperately sought for another year, making the conversion at that moment largely pointless for his unsecured debts. It's a hard pill to swallow, but it illustrates why understanding these timelines is absolutely non-negotiable. This rule is a major gatekeeper, and often the first hurdle we check when someone asks about this complex path.
H3: The 6-Year Rule: Discharge from a Prior Chapter 13
Just as there's a waiting period after a Chapter 7 discharge, there's also a crucial rule concerning a prior Chapter 13 discharge when you're seeking a Chapter 7 discharge. This is commonly known as the "6-year rule," though it's a bit more nuanced than the 8-year Chapter 7 rule. You generally cannot receive a discharge in a Chapter 7 case if you have received a discharge in a prior Chapter 13 case filed within the preceding six years. However, and this is a significant "however," there are two very important exceptions to this rule that often make conversion or subsequent filing possible. These exceptions are the lifelines for many who find themselves in this predicament, struggling to complete their Chapter 13 plan.
The first exception applies if you paid at least 100% of your unsecured claims in the prior Chapter 13 case. This is relatively rare for most Chapter 13 filers, as the purpose of Chapter 13 is often to repay a portion of unsecured debt. But if you did, perhaps because your financial situation improved dramatically during the plan, then the 6-year waiting period is waived, and you could potentially file Chapter 7 immediately. The second, and far more common, exception is if you paid at least 70% of your unsecured claims in the prior Chapter 13 case, and your plan was proposed in good faith and was your best effort. This "70% good faith" rule is the one that often allows people to move forward. It means that if you made a substantial effort to repay your debts under Chapter 13, even if you couldn't pay them all, the law recognizes your good faith and allows you to seek the full discharge of Chapter 7 sooner. This is a critical distinction because it acknowledges that life happens, and sometimes even the best intentions and most diligent efforts aren't enough to overcome truly adverse circumstances. It’s a recognition that the system needs to be flexible enough to provide relief when people genuinely try but are ultimately overwhelmed.
So, for example, if you filed Chapter 13 three years ago, received your discharge, and now, due to a new crisis, you need to file Chapter 7, you would typically be barred by the 6-year rule. However, if your Chapter 13 plan paid 75% of your unsecured debts, and you can demonstrate it was a good faith effort, you could potentially file Chapter 7 immediately, bypassing the 6-year wait. This is why careful analysis of your prior Chapter 13 plan and payment history is absolutely essential. It’s not just about the date; it's about the effort and the outcome of that prior case. This exception provides a path for those who genuinely attempted to fulfill their obligations under Chapter 13 but found themselves needing further relief, proving that the system, while strict, also has elements of compassion and practicality built into its framework for those who demonstrate genuine effort.
H3: The 4-Year Rule: Filing Chapter 7 After Chapter 13 Filing Date
Beyond the rules governing discharges from prior bankruptcies, there's another crucial timeline to consider when you're looking to file Chapter 7 after a Chapter 13, and this one refers to the filing date of the previous case. Specifically, you cannot receive a discharge under Chapter 7 if you filed a previous Chapter 13 case within four years of the new Chapter 7 filing date, and you received a discharge in that Chapter 13 case. This rule is designed to ensure that debtors don't simply "churn" through bankruptcy chapters, particularly using Chapter 13 as a temporary shield before jumping to Chapter 7. It's a different angle than the 6-year rule; it's about the proximity of the filing of the Chapter 13 to the filing of the Chapter 7.
Let's break this down. If you filed Chapter 13 on January 1, 2020, and received your discharge in, say, January 2023, you generally cannot file a new Chapter 7 case and receive a discharge until January 1, 2024 (four years from the original Chapter 13 filing date). This rule is particularly relevant if you're attempting to file a new Chapter 7 case rather than converting an existing Chapter 13 case. Conversion has its own set of rules, which we'll get into, but for a fresh, standalone Chapter 7 filing, this four-year clock is critical. It acts as a barrier to prevent individuals from using a Chapter 13 discharge as a quick stepping stone to a Chapter 7 discharge for new debts, without sufficient time having passed to demonstrate a sustained effort at financial recovery. It’s about creating a reasonable buffer, forcing a period of time where you’re either living debt-free (thanks to the Chapter 13 discharge) or dealing with new debts without immediate access to another bankruptcy discharge.
The nuance here is important: this rule applies to receiving a discharge in the new Chapter 7 case. You might be able to file the Chapter 7 case, but if you're within that four-year window from your prior Chapter 13 filing date (and you received a discharge in that Chapter 13), you won't get a discharge in the Chapter 7. This is a subtle but absolutely vital distinction. Imagine someone who finished their Chapter 13 plan, got their discharge, and then six months later, due to unforeseen circumstances, found themselves drowning in new debt. If they try to file Chapter 7, they'll hit this four-year wall. They might have to consider another Chapter 13, or wait out the clock, or explore other debt relief options. This rule, therefore, significantly impacts the timing and strategy for individuals who have recently completed a Chapter 13 and are now facing new financial hardship. It underscores the importance of not just looking at the calendar for discharge dates, but also for initial filing dates, as the legal implications can be dramatically different.
Numbered List: Key Timing Rules for Chapter 7 After Chapter 13
- 8-Year Rule (Prior Chapter 7 Discharge): You cannot receive a Chapter 7 discharge if you received a Chapter 7 discharge in a case filed within the preceding 8 years. If your prior bankruptcy was a Chapter 7, this is your primary concern.
- 6-Year Rule (Prior Chapter 13 Discharge): You generally cannot receive a Chapter 7 discharge if you received a Chapter 13 discharge in a case filed within the preceding 6 years. However, this rule has two crucial exceptions:
- 4-Year Rule (Prior Chapter 13 Filing Date): You cannot receive a Chapter 7 discharge if you filed a previous Chapter 13 case within four years of the new Chapter 7 filing date, and you received a discharge in that Chapter 13 case. This rule is distinct from the 6-year discharge rule and focuses on the proximity of the filing dates.
H2: Reasons for Converting or Refiling
Life, as we know, is incredibly unpredictable. When someone files a Chapter 13 bankruptcy, they’re making a commitment based on their current financial situation and a reasonable projection of the future. But sometimes, those projections go wildly off course. The reasons for needing to convert an existing Chapter 13 case to a Chapter 7, or even filing a new Chapter 7 after a Chapter 13 has been discharged, are almost always rooted in unforeseen and often devastating changes in circumstances. It’s rarely a frivolous decision; it's typically a desperate one, a recognition that the original plan, no matter how well-intentioned, has become utterly untenable. I’ve sat across from countless clients who, through no fault of their own, found their meticulously planned Chapter 13 unraveling, leaving them in a worse position than when they started. It’s heartbreaking to witness, but thankfully, the bankruptcy system, with all its complexities, does offer avenues for relief in these situations.
Think about it: a Chapter 13 plan is a multi-year commitment, often spanning three to five years. During that time, a lot can happen. A stable job can disappear overnight, a serious illness can strike, leading to astronomical medical bills and an inability to work, or a family crisis can drain every available resource. These aren't minor hiccups; these are seismic shifts that can completely derail even the most robust financial plan. When the income that was supposed to fund the Chapter 13 payments vanishes, or when new, insurmountable debts arise, continuing the Chapter 13 becomes an exercise in futility, often leading to default and dismissal of the case. In such scenarios, converting to Chapter 7 or filing a new one isn't a choice of convenience; it's a necessity, a last resort to gain stability and prevent a total financial collapse. Understanding these common triggers helps to demystify the process and underscores the very human element behind these legal decisions.
H3: Loss of Income or Job Loss
This is, without a doubt, one of the most common and devastating reasons why a Chapter 13 plan becomes unsustainable. When you file Chapter 13, your payment plan is meticulously calculated based on your disposable income – what you have left after essential living expenses. This calculation relies heavily on your current employment and income stability. But what happens when that stability evaporates? What happens when the job you’ve held for years suddenly disappears due to downsizing, industry shifts, or a global economic downturn? Or worse, what if you become too ill or injured to work, and your income dwindles to nothing or to a fraction of what it once was? The answer is often immediate and catastrophic for your Chapter 13 plan.
Suddenly, those monthly payments, which were already a stretch, become utterly impossible. You might try to modify your plan, and the courts do allow for modifications, but there’s a limit to how much you can modify a plan when your income has drastically reduced or vanished entirely. If you're no longer earning enough to cover your basic living expenses and make your Chapter 13 payment, the plan is doomed. It's not a matter of willpower; it's a matter of basic arithmetic. I remember a client, Mark, who was diligently paying his Chapter 13 for two years. He worked in manufacturing, a stable job for decades. Then, his plant closed, moving operations overseas. Mark, in his late 50s, found himself unemployed with limited prospects. His Chapter 13 payment of $800 a month became an insurmountable mountain. He tried to get by on unemployment, but it was a fraction of his former income. For Mark, converting to Chapter 7 became the only viable option. It allowed him to discharge his remaining unsecured debts, eliminate the monthly payment, and focus on finding new employment without the constant threat of his Chapter 13 case being dismissed, which would have put him right back where he started, with all his original debts intact. This scenario is incredibly common and highlights the vulnerability of long-term payment plans to the vagaries of the employment market and personal health. The loss of income isn't just a financial setback; it's a life-altering event that necessitates a fundamental re-evaluation of one's entire financial strategy, often pointing directly toward a Chapter 7 conversion.
H3: Unexpected Medical Emergencies or Expenses
Life has a cruel way of reminding us who’s really in charge, and often, that reminder comes in the form of an unexpected medical crisis. One moment you’re relatively healthy, managing your Chapter 13 payments, and the next, you or a loved one is facing a serious illness, an accident, or a chronic condition that racks up medical bills faster than you can say "co-pay." Even with insurance, the out-of-pocket maximums, deductibles, and non-covered services can quickly amount to tens of thousands of dollars, completely obliterating any financial stability you might have managed to build, even within the confines of a Chapter 13 plan. These aren’t discretionary expenses; these are often life-or-death situations, and they don't care about your bankruptcy payment schedule.
When these medical emergencies strike, the carefully balanced budget of a Chapter 13 debtor is instantly thrown into chaos. Not only are there new, overwhelming debts, but the illness itself might lead to a loss of income, as we just discussed, creating a compounding effect of financial distress. Imagine a situation where a client, already in a Chapter 13, has a child who develops a severe chronic illness. Suddenly, they're facing not only massive medical bills but also lost wages from taking time off work for appointments and care. Their Chapter 13 plan, designed to pay off old debts, simply cannot accommodate these new, unavoidable expenses. The original plan becomes impossible to maintain. In such a scenario, converting to Chapter 7 can offer the critical relief needed. The new medical debts, if they arose before the conversion, can often be included and discharged in the Chapter 7, providing a much-needed lifeline. It allows the family to focus on their child's health rather than drowning under an avalanche of medical debt and an unmanageable Chapter 13 payment. It's a stark reminder that while financial planning is essential, life's most unpredictable and often most expensive challenges can emerge without warning, demanding a flexible and robust legal solution like Chapter 7 to prevent total financial ruin.
H3: Significant Increase in Necessary Living Expenses
It’s not always a dramatic job loss or a sudden medical emergency that derails a Chapter 13 plan. Sometimes, it’s a more gradual, but equally insidious, increase in necessary living expenses that slowly but surely chokes off a debtor’s ability to make their payments. When a Chapter 13 plan is confirmed, it’s based on a snapshot of your expenses at that particular time. But life doesn't stand still for three to five years. Rent can go up, the cost of groceries can skyrocket (anyone been to a supermarket lately?), childcare costs can increase, or the cost of transportation might rise unexpectedly. These aren't luxuries; these are the absolute essentials that keep a household functioning.
Consider a family I worked with whose Chapter 13 plan was confirmed based on an affordable rental agreement. Two years into their plan, their landlord decided to sell the property, forcing them to move. The only comparable housing they could find in their area was significantly more expensive, adding several hundred dollars to their monthly housing costs. This, combined with general inflation and an unexpected car repair that wiped out their meager savings, made their Chapter 13 payment completely unsustainable. They were left with a brutal choice: default on their Chapter 13 and risk losing everything, or somehow find money they simply didn't have. For them, the accumulated increase in necessary living expenses, while not a single catastrophic event, was just as debilitating as a job loss. Converting to Chapter 7 allowed them to eliminate their unsecured debts and free up their limited disposable income to cover their essential, increased living costs. This situation highlights how fragile financial recovery can be, especially for those living close to the margin. Even seemingly small, incremental increases in the cost of living can cumulatively push a debtor over the edge, making a Chapter 7 conversion or new filing the only pragmatic option to regain some semblance of financial stability. It’s a testament to the fact that bankruptcy isn't just about big, dramatic events; it's also about the relentless pressure of everyday economics.
Pro-Tip: Keep Detailed Records!
If you're considering converting your Chapter 13 to Chapter 7 due to changed circumstances, meticulously document all the reasons. Gather pay stubs, medical bills, rent increases, or any other evidence of your changed financial situation. This evidence will be crucial in demonstrating to the court that your need for conversion is legitimate and not an abuse of the system.
H2: The Conversion Process vs. Filing a New Case
When you find yourself unable to continue with your Chapter 13 plan, you generally have two main avenues to explore for Chapter 7 relief: converting your existing Chapter 13 case or dismissing the Chapter 13 and filing a brand-new Chapter 7 case. While both ultimately aim for Chapter 7 relief, they are distinct processes with different implications, advantages, and disadvantages. It’s not a "six of one, half dozen of the other" situation; the choice between conversion and refiling is a strategic one, heavily dependent on your specific circumstances, the stage of your Chapter 13 case, and the timing rules we've already discussed. Deciding which path to take requires a careful analysis by an experienced bankruptcy attorney, because an incorrect choice can lead to significant complications, delays, or even a denial of discharge. It’s like standing at a fork in the road, both paths leading to the same destination, but one is a smooth, paved highway and the other is a bumpy, unmaintained dirt track. You definitely want to pick the right one.
The primary difference lies in the continuity of the legal proceedings. A conversion is essentially a modification of your existing case, a seamless transition (as seamless as bankruptcy can be, anyway) from one chapter to another under the same case number. A new filing, on the other hand, means starting from scratch, with a new case number, new filing fees, and a complete re-evaluation of your situation as if the Chapter 13 never happened (though the prior filing will certainly be noted). Each approach has its own set of rules and consequences regarding assets, debts, and the all-important discharge. Understanding these distinctions is paramount to making an informed decision and navigating this complex legal landscape effectively.
H3: Converting an Existing Chapter 13 Case to Chapter 7
Converting an existing Chapter 13 case to Chapter 7 is often the preferred route when possible, mainly because it maintains the original filing date, which can be advantageous for certain timing rules and the automatic stay. The automatic stay, that wonderful legal shield that stops creditors from harassing you, remains in effect throughout the conversion process, providing continuous protection. When you convert, you’re essentially asking the court to change the nature of your existing bankruptcy case. This is typically done by filing a "Motion to Convert" with the bankruptcy court. The process is usually relatively straightforward from a procedural standpoint, assuming you meet the eligibility requirements for Chapter 7.
Upon conversion, your case essentially "becomes" a Chapter 7 case. A new Chapter 7 trustee will be appointed, replacing your Chapter 13 trustee. You'll then need to file new schedules (or amend your existing ones) to reflect your current financial situation, particularly your income and expenses, as the means test will now apply. This is where the eligibility for Chapter 7, especially the means test, comes into sharp focus. Even if you were eligible for Chapter 13, you might not automatically qualify for Chapter 7, especially if your income has increased significantly since your initial Chapter 13 filing (though more often, people are converting because their
