Last October we highlighted an important ruling issued in September 2019 by the Seventh Circuit in the bankruptcy proceeding of In re I80 Equipment, LLC.  The Circuit Court in that case reversed a decision from the lower bankruptcy court and held that, under Article 9 of the UCC, a financing statement sufficiently indicates collateral even though it contains no actual collateral description but rather incorporates a collateral description by reference to an unattached security agreement. In re I80 Equip., LLC, 938 F.3d 866, 871-72 (7th Cir. 2019).  We noted that this decision put the Seventh Circuit directly at odds with the First Circuit, which ruled to the contrary in January 2019 in the bankruptcy proceeding for Puerto Rico (In re Financial Oversight & Management Board).

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