Although courts generally consider the commercial law of the State to determine whether a contract of guarantee for consumer goods is valid (382), insolvency law has a long tradition of distinguishing between guarantees held as collateral for asset-based loans and interest secured in nominal terms if the guarantees provided little to creditors at the time of withdrawal. This step is necessary to determine priority among creditors` claims. The division of secured debt into secured and unsecured elements, both in business and in consumer matters, reflects this policy, as shown by the legislative history of the Bankruptcy Reform Act 1978: Part C – Certification by the debtor`s lawyer – Not applicable to a pro-Se part D debtor – The debtor`s statement to support confirmation. Back to the text Reaffirmations were almost banned by Congress in 1978. Instead, Congress decided to allow further confirmations under very limited and monitored conditions.