Rick D. Lange, Chapter 7 Trustee v. State Farm Bank, F.S.B. (In re Craig Billesbach), Ch. 7, BK10-43560-TLS, A11-4026-TLS
The refinancing lender's security interest was unperfected because it was not noted on the vehicle's certificate of title until more than 30 days after transfer. Neither earmarking nor contemporaneous exchange for new value were viable defenses.