compliance with the requirements of 11 U.S.C. § 522(f)(2)(B).1 Due to the Debtor’s apparent confusion with this calculation when multiple liens are sought to be avoided, this Order has been issued to provide further clarity.
The language “all other liens on the property” under § 522(f)(2)(A)(ii) includes “mortgages and all judicial and statutory liens.” See In re Derocha, 503 B.R. 553, 557 (Bankr. D.R.I. 2014). For instance, avoiding one of three liens on a property will require including the two other liens in the § 522(b)(2)(A)(ii) portion of the formula in order to successfully avoid the first lien. If the debtor seeks to then avoid the second lien (having already sought to avoid the first lien, whether pending or granted), the formula would only include the third lien as the first “must be deemed already avoided for purposes of the analysis and excluded from the calculation” assuming the first is avoidable in its entirety. Id. at 558. See In re Derocha, 503 B.R. 553 (Bankr. D.R.I. 2014)