Supreme Court Holds ‘Actual Fraud’ Does Not Require Misrepresentation

On May 16, 2016, the U.S. Supreme Court resolved a split among the circuit courts of appeal regarding the definition of “actual fraud” in the Bankruptcy Code. Section 523(a)(2)(A) states: A discharge … does not discharge an individual debtor from any debt for money, property, services, or an extension, renewal, or refinancing of credit to …

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