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In re Putnal: Adequately Protecting Postpetition Rents September/October 2013 Oliver S. Zeltner Section 552(b)(2) of the Bankruptcy Code provides that if a creditor prior to bankruptcy obtained a security interest in rents paid to the debtor, that security interest extends to postpetition rents to the extent provided in the security agreement. Courts have disagreed, however, on the question of whether the debtor must provide adequate protection with respect to such postpetition rents. The resolution of this issue typically determines whether the debtor may use a portion of the postpetition rents that it receives to fund the administrative costs of its bankruptcy. Particularly in cases in which all, or nearly all, of the debtor’s income comes from rental income, the debtor’s ability to fund the administrative costs of bankruptcy can hinge on this issue. Recently, the U.S. District Court for the Middle District of Georgia, in Putnal v. SunTrust Bank, 489 B.R. 285 (M.D. Ga. 2013), joined ...