In my August post , I discussed two cases. In the Failla case, the Eleventh Circuit affirmed the District Court's opinion that “once the debtor decides to 'surrender' secured property [w]hile the debtor need not physically deliver the property to the secured party, the debtor is precluded from taking any action which would interfere with the secured creditor's ability to obtain legal title to, and possession of, the property through legal means.”

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