Mississippi Bankruptcy Court Requires Cramdown On Motor Vehicle Based On "Transformation" Rule

LexisNexis (April 26, 2017, 1:50 PM EDT) -- In our prior story, we featured a recent Texas decision where a motor vehicle financer did not get the benefit of the "hanging paragraph" because of cross-collateral provisions in its secured lending documentation.  In another variation on that theme, a Mississippi court has ruled that a vehicle financer who initially had a PMSI lost that precious status when it refinanced the loan in order to pay off two unrelated unsecured loans.  In reaching that result, the Mississippi court invoked the "transformation rule" and rejected the "dual-status" rule....