The new bankruptcy law changes the rules of asset protection.
Planners usually are not lawyers, but many will now
have to learn a little more about law. The potential impact of the new
federal bankruptcy law means that planning asset-protection strategies
should now be a bigger part of the advisor's practice, according to
lawyers and planners with experience in estate planning.
Gideon Rothschild, a New York-based trusts and
estates attorney, warns that many high-net-worth professionals could
now be at risk. Asset-protection strategies, he asserts, must change to
address these new risks. "The new bankruptcy law changes how and when
people can use these strategies and how people should plan for these
problems," says Rothschild, the former chairman of the American Bar
Association's Committee on Asset Protection.
Most financial planners agree. "Advisors should
familiarize themselves with this, and should be ready with lawyer
referrals for clients who need lots of information," says A. Raymond
Benton, a certified financial planner with his own firm in Denver.
Benton, interviewed in early October, notes that businesses and
individuals were rushing to file for bankruptcy under the expiring
code. A record 1.3 million Americans are expected to file for
bankruptcy this year, about double the number of a decade ago,
according to a recent article in the American Bankruptcy Law Journal.
It labeled the numbers an "epidemic."
The Bankruptcy Abuse Protection and Consumer
Protection Act of 2005 (BAPCPA) changed or tightened rules on things
that include trusts, business liability, IRAs and homestead exemption
laws. The new law, which took effect on October 17, represents the
biggest change in the nation's bankruptcy rules since 1978. Under its
provisions, it will be more difficult for families and individuals who
earn more than the median income to qualify for bankruptcy protection
under the code's Chapter 7, which wipes out debts and allows someone to
begin again.
Many people now asking for bankruptcy protection
will also be required to pay more to debtors than under the previous
code. The new code also clarifies and, in some cases, expands
protections from creditors for retirement accounts. "Wealthier
Americans and even those of more modest incomes are going to find it
more difficult to file for Chapter 7 protection," says Gary Schatsky, a
New York attorney and planner.
Scott Farber, a certified financial planner in
Natick, Mass., has mixed feelings about the new bankruptcy law. He also
is a certified public accountant and a lawyer with extensive experience
in trusts and estates. "I think the IRA protection is a very good
thing. But I have some doubts about some of the new tests for people to
qualify for wiping out their debts," Farber says.
Both Schatsky and Farber disagreed with the credit
card industry's contention that there was "widespread abuse" of the
previous law. Nevertheless, both agree with Rothschild that it is duty
of advisors to alert clients to the greater risks of the new act.
"Perhaps asset protection is now more
important because now one of the asset-protection vehicles, bankruptcy,
is almost being taken off the table for every middle- and
upper-middle-income American," says Schatsky.
But do advisors understand this? The problem is that
advisors tend to view the client's world based from a tax and
investment point of view. "We're planners. We're usually not lawyers.
Even if we wanted to, we don't have the expertise to give legal
advice," says Michael Kitces, a certified financial planner with his
own practice in Colombia, Md.
Kitces says the new bankruptcy law magnifies an
existing advisor problem: The average advisor, if he or she ever thinks
about potential liability issues, usually doesn't think about asset
protection until it is too late. "Once a lawsuit is filed against a
client, it's usually too late to do anything," explains Kitces.
For example, advisors rarely consider the
possibility of a client's children or business facing a lawsuit. That,
adds Rothschild, can sometimes put client assets at risk.
"The best evidence of that is the number of wills I
have seen where there is no effort to go beyond a credit-shelter trust.
As a result, spouses and children inherit assets outright instead of in
a trust, which is often a big mistake," Rothschild argues.
Credit-shelter trusts can help couples avoid estate
taxes. However, when the second spouse dies the assets in the trust
typically go to the children rather than remain in a trust, so they are
no longer protected from creditors. "The planners fail to note the
possibility that the children, after their receive this inheritance,
could file bankruptcy. They could have judgments against them. Or maybe
they will be subject to business failures," the attorney adds.
BAPCPA was the result of years of lobbying by
frustrated banking and credit-card industry officials. The industry
charged that many delinquent cardholders were abusing the previous
bankruptcy code and maintained that the old code too easily allowed
people to qualify for Chapter 7. The latter discharged debts and
required very little repayment. That's even though many debtors could
have repaid a bigger portion of the red ink, the credit card companies
argued.
Therefore credit card companies and banks, in some
seven years of lobbying Congress, worked to ensure that a new
bankruptcy law treated the average delinquent cardholder much more
stringently. But, under pressure from credit-card industry critics,
last-minute provisions were added to the new law that were aimed at
corporate rogues, such as WorldCom's Bernie Ebbers and others,
Rothschild says. Congress, in taking aim at corporate heavyweights who
committed fraud, also went after vehicles such as self-settled trusts
and other asset-protection trusts, which have some legitimate uses, he
says. A self-settled trust is one in which the client names himself the
beneficiary.
Under the previous bankruptcy law, individuals could
use these trusts to seek some protection from creditors, Rothschild
says. "Self-settled and asset-protection trusts, whether they are
onshore or offshore, have been dealt a blow," he adds.
Under BAPCPA, a new fraudulent transfer provision
has been added, which means these trusts don't offer as much
protection, Rothschild claims. He says that the provision of the new
law is too stringent because "anyone" can be sued today.
Rothschild says that traditionally these trusts have been used as an
asset-protection strategy for those in high-risk professions,
professions in which one easily could be sued. Rothschild uses, as an
example, a young doctor. "Let's say the doctor just came out of medical
school and has inherited $5 million. He puts it in an asset-protection
trust because he is in a business in which it is easy to be sued and
have a $10 million judgment against him,"
R Rothschild explains. "Should he have his
inheritance at risk if he makes one mistake over the course of a
40-year career? I don't think that is right."
Rothschild also argues that there is little evidence
that most people who set up these trusts were engaged in fraud.
Still, Kitces isn't upset about any clampdown on
self-settled trusts or other forms of domestic asset-protection trusts,
neither of which he uses in his practice. "These trusts are based on
untested theory and they must be in place for ten years to be
recognized," he says. The new bankruptcy law also limits the homestead
exemption. Under the new bankruptcy law, the homestead exemption is now
limited to $125,000 per debtor. It also requires that one own the house
for three years and four months, according to Kitces.
One of the common strategies of those filing for
bankruptcy protection previously was to move to a state with easy
bankruptcy laws, then put much of their assets in a home. In many
states, all the assets in the home were exempt from bankruptcy
proceedings.
Former baseball commissioner Bowie Kuhn used this
tactic-he moved to Florida and bought a house after his business debts
became onerous. Former football star O.J. Simpson also used this
strategy and bought a house in Florida. The house and his pro football
pension were shielded through the bankruptcy law from the multi-million
legal judgments levied against him. Those winning judgments against him
couldn't collect.
Planners now have to do more research, says Kitces.
"It's not enough anymore just to tell the client that he should buy a
house in Florida or some other state," he says.
IRA rules have changed as well. Previously, some
states had an unlimited exemption on an IRA in a bankruptcy action, but
in other states there was no protection of IRA assets from a bankruptcy
proceeding. Under the new federal law, bankruptcy protection is capped
at $1 million for IRAs. However, the $1 million cap doesn't apply to
rollover IRAs.
"You should be very careful in terms of IRA
rollovers, not to merge them because you could have $20 million in a
rollover IRA and it would still be protected," says Benton, the Denver
planner. He also adds that some rollover IRAs of less than $1 million
should not be merged. "No IRA should be merged if one thinks it has the
potential to grow to over $1 million," Benton cautioned.
Farber believes that advisors should draw up a
balance sheet of client assets that might be subject to legal dangers.
And even those advisors who take such a step, he points out, cannot
guarantee that all assets are safe.
"The problem is that nothing is 100% bulletproof,"
Farber says. He says insurance is often a good way of protecting an
asset. But he also wonders how far each client wants to go in
protecting a business or some other property. "Almost any asset can be
vulnerable to creditors or legal problems. The issue is to devise
strategies that make sense for each client," Farber says.