How to Fill Out U.S. Courts Form 106Sum (w/Examples) + FAQs

Form 106Sum is the one-page snapshot the bankruptcy court uses to size up your whole financial life, and you fill it out by copying the totals from Schedules A/B, D, E/F, I, and J onto the lines provided, then answering three short statistical questions in Part 3. The official name is the Summary of Your Assets and Liabilities and Certain Statistical Information, and it is filed by every individual debtor under Chapters 7, 11, 12, and 13.

The form looks easy because it has only a handful of lines, but each line pulls from a different schedule, and a single math slip can flag your case for the trustee, trigger an amendment under Federal Rule of Bankruptcy Procedure 1009, or even support a denial of discharge under 11 U.S.C. §727. The form is signed under penalty of perjury through Form 106Dec, so false numbers can trigger criminal exposure under 18 U.S.C. §152.

According to the Administrative Office of the U.S. Courts, more than 517,000 non-business bankruptcy cases were filed in the year ending December 2025, and every individual filer had to complete Form 106Sum. That single page is often the first document a Chapter 7 trustee reads at the §341 meeting of creditors.

Here is what you will learn in this guide:

  • 📋 The exact line-by-line meaning of every box on Official Form 106Sum
  • 🧮 How to reconcile the totals so Schedules A/B, D, E/F, I, and J all match
  • ⚖️ Why Part 3’s “consumer vs. non-consumer” question controls the §707(b) means test
  • 🚩 The trustee red flags that lead to amendments, 2004 exams, or denial of discharge
  • 🛠️ Three named-person examples (single filer, married couple, sole proprietor) showing real numbers

What Form 106Sum Is and Why It Exists

Form 106Sum is an Official Form promulgated by the Judicial Conference of the United States under the authority of 28 U.S.C. §2075. It serves as the cover sheet for the individual debtor’s schedules, giving the trustee, the U.S. Trustee, and creditors a fast read of the estate.

The form exists because 11 U.S.C. §521(a)(1) requires every debtor to file a schedule of assets and liabilities, a schedule of current income and expenditures, and a statement of financial affairs. Without a single summary page, the trustee would have to add the schedules by hand at every meeting, which would slow the system to a crawl. The form turns a 30-page filing into a one-page dashboard.

The plain-English purpose is simple. The summary tells the court three things at a glance: what you own, what you owe, and whether your debts are mostly consumer debts. The consequence of getting it wrong is real, because the U.S. Trustee uses the same numbers to decide whether to file a presumption of abuse motion under §707(b)(2).

A common misconception is that 106Sum is “just a cover page” that does not need careful work. That is wrong. Trustees compare the summary line totals to the Statement of Financial Affairs (Form 107) and to the means test on Form 122A-2, and any mismatch triggers questions.

Who Must File Form 106Sum

Every individual debtor in a voluntary or involuntary case under Chapters 7, 11, 12, or 13 must file Form 106Sum. Joint filers under 11 U.S.C. §302 file one combined form covering both spouses. Corporate and partnership debtors instead file the Form 206Sum summary.

The filing deadline tracks Bankruptcy Rule 1007(c), which gives the debtor 14 days from the petition date to file all schedules in a voluntary case. A debtor who needs more time can move for an extension, but missing the deadline can lead to dismissal under 11 U.S.C. §521(i) if the debtor blows the 45-day automatic dismissal window.

The consequence of skipping the form is automatic case dismissal in many districts. A real-world example is the case of In re Acosta-Rivera, where the First Circuit confirmed in 495 F.3d 4 (1st Cir. 2007) that §521(i) dismissal can be automatic when required documents are missing.

How 106Sum Connects to the Other Schedules

Form 106Sum is not a standalone document. It is a roll-up of six other forms in the Form 106 series: Schedule A/B (property), Schedule C (exemptions), Schedule D (secured creditors), Schedule E/F (priority and unsecured creditors), Schedule G (executory contracts), Schedule H (codebtors), Schedule I (income), and Schedule J (expenses).

Each line on 106Sum points to a specific line on a specific schedule. Line 1a, for example, copies the total real property from line 55 of Schedule A/B. Line 2c copies the total claims from Schedule E/F.

The plain-English explanation is that 106Sum is a calculator that adds up the work you already did. The consequence of inconsistent numbers is a trustee objection, an amended set of schedules, and possibly a Rule 2004 examination under oath. A common misconception is that you can round numbers; the form requires the exact totals from the underlying schedules.

Line-by-Line Walkthrough of Form 106Sum

Form 106Sum has three parts. Part 1 captures assets, Part 2 captures liabilities, and Part 3 captures statistical information used by the U.S. Trustee. Each part has just a few lines, but every line carries weight.

Part 1 — Summary of Assets

Part 1 has three lines. Line 1a asks for the total of real property from line 55 of Schedule A/B, which is the running total of houses, condos, land, and any other real estate the debtor owns or has an interest in. Line 1b asks for the total of personal property from line 92 of Schedule A/B, which sweeps in cars, cash, retirement accounts, household goods, and intangible rights.

Line 1c is the grand total of all property, which equals 1a plus 1b and must equal line 93 of Schedule A/B. The plain-English explanation is that this line tells the trustee the gross value of the bankruptcy estate before exemptions under 11 U.S.C. §541.

The consequence of understating assets is severe. A real-world example is In re Coombs, 193 B.R. 557 (Bankr. S.D. Cal. 1996), where the debtor’s omission of property led to a §727(a)(4) denial of discharge for a false oath. A common misconception is that “low value” items can be left off; the form requires every asset, no matter how small.

Part 2 — Summary of Liabilities

Part 2 has four lines. Line 2a asks for the total secured claims from line 3 of Schedule D, which includes mortgages, car loans, and any other debt tied to collateral. Line 2b asks for the total priority unsecured claims from line 5a of Schedule E/F, which sweeps in domestic support obligations, recent income taxes, and certain wage claims under 11 U.S.C. §507.

Line 2c asks for the total non-priority unsecured claims from line 5b of Schedule E/F, which is where credit cards, medical bills, deficiency claims, and most personal loans live. Line 2d is the grand total of liabilities, equal to 2a plus 2b plus 2c.

The plain-English explanation is that this part tells the trustee how deep the debt hole is. The consequence of underreporting a debt is that the omitted creditor may not be discharged under 11 U.S.C. §523(a)(3). A real-world example is the Judd v. Wolfe line of cases discussed in 298 F.3d 122 (3d Cir. 2002), where omitted creditors fought the discharge.

A common misconception is that “disputed” debts can be left off. They cannot. The instructions tell the debtor to list disputed debts and check the “disputed” box on Schedule E/F.

Part 3 — Statistical Information

Part 3 is the most overlooked part of the form, and it carries the highest stakes. The form first asks whether the debtor is filing under Chapter 7, 11, 12, or 13, and whether the debts are primarily consumer debts as defined in 11 U.S.C. §101(8).

Line 3 asks for total current monthly income from line 12 of Form 122A-1, Form 122B, or Form 122C-1. Line 4 then breaks down the debts on Schedule E/F into specific buckets the U.S. Trustee tracks for statistical reporting under 28 U.S.C. §159.

The buckets on line 4 include domestic support obligations, taxes and certain other debts owed to governmental units, claims for death or personal injury while intoxicated, and student loans. The plain-English consequence is that mislabeling a debt here can mislead the U.S. Trustee about whether a presumption of abuse exists.

A common misconception is that Part 3 “does not matter” because it is statistical. Wrong. The U.S. Trustee uses the same numbers to decide whether to seek dismissal under §707(b), and the Department of Justice publishes aggregate data based on these answers.

Three Named-Person Examples

Concrete numbers help more than abstract instructions. Below are three examples drawn from common filing patterns. Each shows how the totals flow from the underlying schedules into Form 106Sum.

Example 1: Maria Lopez, Single Chapter 7 Filer

Maria Lopez is a single nurse in Tampa, Florida, who lost overtime hours and fell behind on credit cards. She owns a 2019 Honda Civic worth 14,000 dollars and rents her apartment, so she has no real property. Her personal property totals 22,500 dollars on Schedule A/B line 92.

On Schedule D, she lists the Honda loan with a balance of 9,800 dollars. On Schedule E/F, she lists 41,200 dollars in credit card debt and 6,500 dollars in medical bills. She files under Chapter 7 with primarily consumer debts and reports current monthly income of 3,950 dollars from line 12 of Form 122A-1.

The plain-English consequence for Maria is that her secured-to-unsecured ratio shows a clean Chapter 7 case. A common misconception is that her Florida homestead exemption matters here; it does not, because she rents.

Example 2: David and Susan Patel, Joint Chapter 13 Filers

David and Susan Patel are a married couple in Columbus, Ohio, filing a joint Chapter 13 to save their home from foreclosure. Their house is worth 285,000 dollars on Schedule A/B line 1, and their personal property totals 38,000 dollars on line 92, for a grand total of 323,000 dollars on line 93.

On Schedule D, they list a 248,000-dollar mortgage and two car loans totaling 31,500 dollars. On Schedule E/F, they list 4,200 dollars in priority tax debt and 67,000 dollars in non-priority unsecured claims. They check the Chapter 13 box and confirm primarily consumer debts.

The plain-English consequence is that their combined current monthly income from Form 122C-1 controls their applicable commitment period under §1325(b)(4). The common misconception is that joint filers file two summaries; they file one combined Form 106Sum under §302.

Example 3: James Becker, Sole Proprietor Chapter 7 Filer

James Becker runs a small landscaping business in Austin, Texas, as a sole proprietor. His debts are not primarily consumer debts because more than half come from business credit lines and an SBA disaster loan. He owns business equipment worth 48,000 dollars and a personal truck worth 22,000 dollars.

On Schedule D, he lists a 31,000-dollar equipment loan. On Schedule E/F, he lists 7,800 dollars in priority business taxes and 142,000 dollars in non-priority business debt. He checks “no” to primarily consumer debts on Part 3.

The plain-English consequence is huge. By checking “no,” James escapes the §707(b) means test entirely, because the means test only applies to consumer debtors. The common misconception is that all individual filers face the means test; they do not.

Common Filing Scenarios

The next three tables walk through the most common scenarios that trip up filers. Each shows the filer’s choice and the resulting consequence.

Filer’s Choice Bankruptcy Outcome
Lists home value at tax-assessor figure (often low) instead of fair market value on line 1a Trustee may hire appraiser, claw back equity, and object under §704(a)(1)
Forgets to include 401(k) loan repayment in Schedule J expenses tied to line 1b assets Disposable income on Form 122 may be miscalculated, triggering a §707(b) presumption
Checks “primarily consumer debts” when business debt actually exceeds half Filer subjects self to means test that did not apply, possibly losing Chapter 7 eligibility
Math Mistake Trustee Response
Line 1c does not equal line 93 of Schedule A/B Trustee files objection and demands amended schedules under Rule 1009
Line 2d does not equal sum of Schedules D and E/F U.S. Trustee may set Rule 2004 exam to probe books and records
Line 3 current monthly income differs from Form 122 Presumption of abuse review under §707(b)(2) is delayed and case is flagged
Omission on 106Sum Long-Term Consequence
Inherited but undistributed property left off line 1a Possible §727(a)(4) denial of discharge for false oath
Pending lawsuit recovery left off Schedule A/B line 33 Trustee can reopen case under §350(b) and administer the asset
Co-signed debt left off Schedule E/F line 5b Co-signer faces collection because §524(e) does not protect them

Mistakes to Avoid

The summary form is short, but the ways to mess it up are long. Here are the most common errors and the negative outcome each one causes.

  1. Rounding numbers up or down. The form requires exact totals from the schedules. Rounding causes line 1c or 2d to mismatch the underlying schedule, which triggers a trustee objection and a forced amendment.
  2. Filing 106Sum before finishing Schedules A/B, D, and E/F. The summary depends on totals from those schedules. Filing first creates inconsistencies that look like a §727(a)(4) false oath risk.
  3. Checking “primarily consumer debts” without doing the math. The test under §101(8) compares total consumer debt to total debt. Wrong checks subject the filer to a means test that may not apply.
  4. Leaving Part 3 line 4 blank. The U.S. Trustee uses these buckets for statistical reporting under 28 U.S.C. §159. Blank entries can lead to a deficiency notice and possible dismissal.
  5. Confusing fair market value with replacement value. 11 U.S.C. §506(a)(2) requires replacement value for personal property of consumer debtors. Using fair market value understates assets.
  6. Forgetting to include retirement loans as debt. A 401(k) loan is a debt to the plan, but it is not a creditor claim against the estate. Listing it as a Schedule D debt is wrong, but failing to disclose it on Schedule I as a payroll deduction is also wrong.
  7. Failing to update 106Sum when amending a schedule. Rule 1009(a) lets a debtor amend as a matter of course before the case is closed, but the summary must be amended too. Failing to amend creates a record mismatch.
  8. Treating a domestic support obligation as non-priority. Domestic support is first priority under §507(a)(1). Misclassifying it on line 2b versus 2c can change the dividend math in Chapter 13.
  9. Putting tax debt that is non-priority into priority. Only certain recent taxes qualify under §507(a)(8). Listing all tax debt as priority overstates priority claims and harms unsecured creditors’ dividend.
  10. Signing 106Dec without re-reading 106Sum. Form 106Dec attaches the perjury oath to the summary. A signature locks in every number, and 18 U.S.C. §152 makes false answers a federal crime punishable by up to five years.

Do’s and Don’ts

The list below covers practical do’s and don’ts that experienced bankruptcy practitioners follow. Each item explains the why.

Do’s

  • Do reconcile every line to the underlying schedule line cited on the form. Reconciliation prevents the trustee from finding mismatches at the §341 meeting.
  • Do use replacement value for personal property under §506(a)(2). Using the right standard avoids a trustee challenge to undervalued assets.
  • Do attach amended 106Sum whenever you amend a schedule. Rule 1009 requires the summary to mirror the amended schedule.
  • Do double-check Part 3’s consumer-debt question. This single check controls whether the means test applies and is the most-litigated item on the form.
  • Do keep your math worksheets. If the trustee questions a number, contemporaneous worksheets show good faith and rebut a §727(a)(4) intent finding.

Don’ts

  • Don’t sign 106Dec until 106Sum is final. Signing under penalty of perjury locks in numbers and invites criminal exposure under 18 U.S.C. §152 if wrong.
  • Don’t list contingent or unliquidated claims at zero on line 2c. Rule 1007(b) requires a good-faith estimate; zero is rarely defensible for a pending lawsuit.
  • Don’t ignore line 4’s death-or-personal-injury bucket. Misclassifying a §523(a)(9) DUI claim affects dischargeability.
  • Don’t assume joint filers each file their own 106Sum. Section 302 joint cases use one combined summary.
  • Don’t file with TBD entries. “To be determined” entries trigger automatic dismissal warnings under §521(i).

Pros and Cons of Self-Preparing Form 106Sum

Many filers consider preparing 106Sum themselves to save on attorney fees. The list below weighs the trade-offs honestly.

Pros

  • Cost savings. Self-preparation avoids attorney fees that average between 1,200 and 2,500 dollars for a Chapter 7, according to USCourts.gov filing data.
  • Education. Filling out the form teaches the filer how the bankruptcy estate works under §541.
  • Speed. Some filers complete schedules faster than they could schedule an attorney appointment.
  • Privacy. Self-preparers handle sensitive numbers themselves, with no third party seeing the data.
  • Control. The filer chooses how to value items, subject to the §506 rules.

Cons

  • Perjury risk. A wrong number signed under Form 106Dec can lead to criminal charges under 18 U.S.C. §152.
  • Discharge risk. A false statement may support a §727(a)(4) denial of discharge.
  • Means-test errors. Misanswering Part 3 can wrongly subject the filer to the means test.
  • Exemption mistakes. Without counsel, filers often miss valuable exemptions like the federal §522(d) wildcard.
  • Trustee scrutiny. Pro se filings often draw deeper review at the §341 meeting because trustees expect more errors.

Federal Rules Versus State Nuances

Federal law sets the form, but state law sets the exemptions that affect the numbers behind 106Sum. This section starts with the federal baseline and then notes key state nuances.

Federal Baseline

The federal exemption scheme lives in 11 U.S.C. §522(d). It includes a homestead exemption, a motor-vehicle exemption, a wildcard, and category-specific protections. The federal scheme applies unless the state has opted out under §522(b)(2).

The plain-English consequence is that filers in opt-out states must use state exemptions only. The Department of Justice’s UST Exemption Chart lists median income figures used in the means test that flow from line 3.

State Nuances

Florida offers an unlimited homestead exemption under Article X §4 of the state constitution, subject to the federal cap of 189,050 dollars in 11 U.S.C. §522(p). Texas offers a similarly broad homestead under Texas Property Code §41.001. California allows filers to choose between the §703 set and the §704 set under California Code of Civil Procedure §703.140.

The plain-English consequence is that line 1a’s real-property total interacts with state homestead rules to determine whether the trustee abandons the property under §554 or sells it. The common misconception is that state exemptions appear on 106Sum; they do not. Exemptions live on Schedule C, not on the summary.

Key Court Rulings to Know

Several court rulings shape how trustees and judges treat 106Sum errors. Understanding these cases helps the filer set the right tone in good-faith preparation.

The Supreme Court’s decision in Law v. Siegel, 571 U.S. 415 (2014) limits a court’s power to surcharge exempt property even when a debtor commits misconduct. The plain-English takeaway is that the trustee cannot simply take exemptions away as punishment, but the discharge can still be denied.

In Marrama v. Citizens Bank, 549 U.S. 365 (2007), the Court held that a debtor who acts in bad faith on schedules can be barred from converting to Chapter 13. That ruling sharpens the stakes for accurate 106Sum totals.

The Fifth Circuit in In re Sholdra, 249 F.3d 380 (5th Cir. 2001) affirmed denial of discharge under §727(a)(4) where the debtor signed schedules he had not read. The plain-English consequence is that signing 106Dec without reading 106Sum is itself dangerous.

Step-by-Step Process to Complete Form 106Sum

The cleanest workflow is to leave 106Sum for last. Below are the steps experienced practitioners follow, with the reasoning behind each.

  1. Finish Schedules A/B, C, D, E/F, G, H, I, and J first. The summary depends on their totals.
  2. Pull line 55 of Schedule A/B into Part 1 line 1a as real property.
  3. Pull line 92 of Schedule A/B into Part 1 line 1b as personal property.
  4. Add 1a and 1b and place the result on line 1c. Confirm that 1c equals line 93 of Schedule A/B.
  5. Pull line 3 of Schedule D into Part 2 line 2a as secured claims.
  6. Pull line 5a of Schedule E/F into Part 2 line 2b as priority unsecured claims.
  7. Pull line 5b of Schedule E/F into Part 2 line 2c as non-priority unsecured claims.
  8. Add 2a, 2b, and 2c and place the result on line 2d. This is total liabilities.
  9. Check the chapter box (7, 11, 12, or 13) and the consumer-debt box in Part 3.
  10. Pull current monthly income from the relevant Form 122 line into Part 3 line 3.
  11. Complete the four buckets on line 4 using only the figures from Schedule E/F lines 6a–6f.
  12. Sign and date Form 106Dec only after every line is reconciled.

FAQs

Is Form 106Sum required in every individual bankruptcy case?

Yes. Every individual debtor in Chapters 7, 11, 12, and 13 must file Form 106Sum under Bankruptcy Rule 1007 and 11 U.S.C. §521(a)(1), and skipping it can trigger automatic dismissal under §521(i).

Do joint filers file two separate 106Sum forms?

No. Spouses filing jointly under 11 U.S.C. §302 file one combined Form 106Sum that reflects both spouses’ assets, debts, income, and statistical information.

Can I amend Form 106Sum after filing?

Yes. Federal Rule of Bankruptcy Procedure 1009(a) lets the debtor amend schedules and the summary as a matter of course any time before the case is closed, though notice must reach affected parties.

Does Form 106Sum apply to corporate or partnership debtors?

No. Corporations, partnerships, and LLCs use Form 206Sum instead, which is designed for non-individual debtors and tracks different categories under the Bankruptcy Code.

Is the consumer-debt question on Part 3 important?

Yes. That single check controls whether the §707(b) means test applies, and a wrong answer can cost a filer Chapter 7 eligibility or expose the case to a presumption of abuse motion.

Can a trustee object to numbers on Form 106Sum?

Yes. Trustees regularly object when totals on 106Sum do not match the underlying schedules, when assets appear undervalued, or when the consumer-debt designation looks wrong under §101(8).

Does Form 106Sum show my exemptions?

No. Exemptions appear only on Schedule C, not on the summary, because 106Sum is a gross snapshot of assets and liabilities before any exemption analysis under 11 U.S.C. §522.

Is signing Form 106Dec the same as signing 106Sum?

Yes. Form 106Dec attaches one perjury oath to all the schedules, including 106Sum, so a wrong number on the summary is signed under penalty of perjury under 18 U.S.C. §152.

Can errors on Form 106Sum lead to denial of discharge?

Yes. Material false statements can support denial of discharge under 11 U.S.C. §727(a)(4), as confirmed in cases like In re Sholdra in the Fifth Circuit.

Does the U.S. Trustee read Form 106Sum?

Yes. The U.S. Trustee Program reviews 106Sum in every case to evaluate the means test, statistical reporting under 28 U.S.C. §159, and whether to file a §707(b) motion.

Is there a filing fee for Form 106Sum specifically?

No. There is no separate fee for the summary; the standard chapter filing fee published on the U.S. Courts fee schedule covers the entire petition package.

Can a bankruptcy petition preparer fill out Form 106Sum for me?

Yes. A non-attorney petition preparer can type the form under 11 U.S.C. §110, but they cannot give legal advice and must sign the document and disclose their fee.

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