Comment on FR Doc # E8-01450

Specific comments about UST Form 102-13-FR-S (Chapter 13 Standing Trustee?s Final Report and Account): Paragraph 8: ?total value of assets abandoned by court order? - in many jurisdictions (including mine), we don?t ?abandon? assets; we merely consent to the stay being lifted. If a creditor wants to obtain an abandonment order, I usually have no involvement in that, once the stay is lifted. Therefore, the total value of abandoned assets in my cases will always be $0. This will skew the national numbers. On the other hand, if ?abandoned? is supposed to be synonymous with ?stay lifted,? then we need to know that. Paragraph 9: ?total value of assets exempted? - it would be simple enough to add up the totals from Schedule C; however, many debtors claim the value of their exemption as ?100%? in certain assets without stating a value. If that is added in as $0, that will also skew the total numbers nationally. There are several categories of property in which it is entirely appropriate for a debtor to claim 100% as exempt, regardless of the actual value, even if the value is known at the time of filing (though in the case of certain pending lawsuits, the value is often NOT known). Paragraph 10: ?amount of general unsecured claims discharged without payment? - if this refers to the amount of claims FILED that were not paid, it may not be an accurate reflection, since many creditors do not file claims in low dividend plans; on the other hand, if it refers to the amount of claims SCHEDULED that were not paid, it may not be accurate either, since debtors are notoriously unfamiliar with the amounts they owe. I am unsure what this question is seeking, so I can?t propose an alternative wording. Under the section headed ?summary of disbursements to creditors,? there is a breakdown of ?debt secured by vehicle? and ?other secured.? There are numerous cases in which the secured debt has a vehicle AND OTHER COLLATERAL also securing the loan, with no specific breakdown of how much is secured by the vehicle and how much is secured by the other property. This inability to break out the totals will either cause the ?secured vehicle debt? to be inaccurately high (because it includes other personal property), or it will cause the ?other secured? debt to be inaccurately high (because it includes debts also secured by vehicles).