How to Fill Out U.S. Courts Form 206D (w/Examples) + FAQs

If your business is filing bankruptcy and owes money backed by property, you must list every secured creditor on Official Form 206D, which is the Schedule D filed by non-individual debtors under Chapter 7, Chapter 11, Subchapter V, or Chapter 12. The form tells the court, the trustee, and other creditors exactly who holds a lien, mortgage, security interest, or judgment against the company’s assets.

The problem the form addresses is simple. Without a clear, signed, sworn list of secured claims, the court cannot value collateral, confirm a plan, or distribute property. The governing rule is Federal Rule of Bankruptcy Procedure 1007, which forces a debtor to file complete schedules within 14 days of the petition, and the 11 U.S.C. § 521 duty to disclose. Filing a sloppy or incomplete 206D can trigger dismissal under § 707(a) or § 1112(b), and a false answer is a federal crime under 18 U.S.C. § 152.

According to the Administrative Office of the U.S. Courts, business bankruptcy filings rose 33.5% in the 12 months ending June 2024, with secured-debt disputes at the center of nearly every Chapter 11 confirmation hearing.

Here is what you will learn in this guide:

📋 How to read every line, box, and prompt on Form 206D and what each one means in plain English.
⚖️ Which Bankruptcy Code sections, like § 506 and § 1111(b), control how your secured claims get valued and paid.
🧾 Real, named-person examples for an LLC restaurant, a holding company, and a trucking firm.
🚫 The seven most common mistakes filers make and the exact consequence of each one.
❓ Ten high-value FAQs that answer the questions trustees and creditors ask most often.

What Form 206D Actually Is

Form 206D is the official non-individual Schedule D: Creditors Who Have Claims Secured by Property. It is part of the B200 series of bankruptcy forms used by corporations, limited liability companies, partnerships, and other non-human debtors. The form sits inside the larger packet that begins with Form 201 (the petition) and continues through Schedules A/B, E/F, G, H, and the Summary on Form 206Sum.

The form has one core job. It forces the debtor to swear, under penalty of perjury, to a complete list of every creditor that holds a security interest in the debtor’s property. A security interest is a legal right to take or sell specific property if the debt is not paid, and it is created by contract, statute, or court order under Article 9 of the Uniform Commercial Code for personal property and by mortgage or deed of trust law for real property.

The consequence of leaving a creditor off this form is severe. An omitted secured creditor can argue its lien rides through the bankruptcy unaffected, it can object to confirmation, and the debtor may lose the discharge protections of § 1141 for the omitted debt. A common misconception is that small secured debts can be skipped. They cannot. Every lien, no matter the dollar amount, must appear on Form 206D.

Who Files Form 206D

Only non-individual debtors file Form 206D. That means corporations, LLCs, LLPs, partnerships, and other business entities use the 206-series forms, while individual humans use the 106-series.

The rule comes from Bankruptcy Rule 1007(b)(1), which separates individual and non-individual schedules. The consequence of using the wrong form is rejection by the clerk, which can blow your filing deadline. A small consulting LLC, Harborline Strategy LLC, must use 206D even if it has only one member-owner, because the LLC is a separate legal entity.

The misconception trap is the single-member LLC. Owners often assume the company is the same as the owner, so they grab the 106D. The court treats the entity as separate, and the wrong form means an amended filing under Rule 1009.

When Form 206D Is Due

The deadline is tight. Rule 1007(c) requires schedules within 14 days after the voluntary petition, or within 7 days for an involuntary case where the order for relief has been entered.

Late filings risk dismissal under the § 521 duty to file and the local rules of the U.S. Trustee Program. The trustee may move to convert or dismiss within days. Atlas Freight Co. learned this when it filed its petition without 206D and faced a § 1112(b) motion ten days later.

The misconception is that an extension is automatic. It is not. You must file a motion under Rule 1007(c) and show cause.

Where to Find the Current Version

Always pull Form 206D directly from the official U.S. Courts forms page. Local stationery copies and old PDFs are often outdated, and the Judicial Conference Advisory Committee updates these forms on a published schedule.

The version date appears in the lower-right corner. Filing an outdated version triggers a clerk’s notice of deficiency and a CM/ECF rejection. Greenline Foods Inc. once filed a 2015 version in 2024 and had its case flagged within a day.

The misconception is that “the PDF is the PDF.” Each revision changes line numbering, attachments, and certifications. Always pull fresh.

The Legal Backbone Behind Form 206D

Form 206D is not just paperwork. It is the input into the entire secured-claim machine of the Bankruptcy Code. Five interlocking rules drive how every line on the form gets read.

Section 506(a) splits each claim into a secured portion (up to the value of the collateral) and an unsecured portion (anything above that value). Section 506(d) lets the debtor strip a lien that secures a disallowed claim. Section 1111(b) gives non-recourse secured creditors a powerful election in Chapter 11 to be treated as fully secured. Section 1129(b) controls cramdown over an objecting class. Section 552 cuts off after-acquired property liens at the petition date.

The plain-English version is this. The numbers you write on Form 206D set the ceiling and floor of every fight that follows. The consequence of a wrong number is real money lost. Sunline Fabrics LLC listed a $400,000 secured claim that should have been $250,000 because of § 506(a) valuation, and the lender pocketed the difference at confirmation. The misconception is that the trustee fixes errors. The trustee does not. The debtor is bound by the schedules unless they amend.

Perjury and Disclosure Duties

Every Form 206D is signed under 28 U.S.C. § 1746 penalty of perjury, and a knowing false statement violates 18 U.S.C. § 152. Penalties include up to five years in federal prison.

The rule exists because the entire bankruptcy system runs on disclosure, not investigation. The consequence of a lie is criminal referral by the U.S. Trustee and denial of discharge under § 727(a)(4). David Nowak, an officer of a closed corporation, signed a 206D that hid a sister-company lien and earned an indictment.

A common misconception is that “I forgot” is a defense. Reckless disregard is enough under most circuits, including the holding referenced in In re Retz, 606 F.3d 1189 (9th Cir. 2010).

Interaction With Other Schedules

Form 206D does not stand alone. It must reconcile with Form 206A/B (assets), Form 206E/F (unsecured creditors), Form 206G (executory contracts), and Form 206H (codebtors).

If you list a $500,000 mortgage on 206D, the underlying real property must appear on 206A/B at a stated value. The consequence of a mismatch is a Rule 2004 examination by creditors. Riverbend Holdings LLC listed a building on 206A/B at $1.2M and a mortgage on 206D at $1.6M, but forgot to mark the unsecured deficiency on 206E/F, and the lender objected.

The misconception is that “secured means I do not list the deficiency anywhere else.” Wrong. The unsecured deficiency belongs on 206E/F.

Line-By-Line Walkthrough of Form 206D

Form 206D has three parts: a yes/no header, Part 1 (creditors with secured claims), and Part 2 (others to be notified). Each line carries a specific legal consequence.

Header and Case Caption

The top of the form asks for the debtor’s full legal name, any aliases (DBA, FKA), the district, the case number, and a checkbox for whether this is an amended filing. The legal name must match the articles of organization or articles of incorporation on file with the secretary of state.

The plain-English explanation is that the caption tells the clerk where the form belongs in PACER/CM-ECF. The consequence of a typo is a misfiled docket entry and a notice of deficiency. Linnea Park, controller of NorthGate Bakery LLC, once filed under “North Gate Bakery LLC” with a space, and the clerk rejected it.

The amendment box matters. If you check it, you must serve the amendment on every affected creditor under Rule 1009(a). The misconception is that amending Schedule D is informal. It is a sworn filing with full service requirements.

Part 1: Creditors With Secured Claims

Part 1 is the heart of the form. The first prompt asks: Does the debtor have any creditors holding secured claims? If yes, you list each creditor in numbered rows, starting with row 2.1, then 2.2, and so on.

Each numbered entry asks for the creditor’s name and mailing address, the date the debt was incurred, the last four digits of the account number, a description of each lien, the amount of the claim, the value of the collateral, and the unsecured portion if any. The form also asks whether the claim is contingent, unliquidated, or disputed, plus the nature of the lien (mortgage, UCC-1, judgment, statutory).

The consequence of leaving any column blank is a deficiency notice. Marcus Heller, CFO of Cobalt Press Inc., left the “value of collateral” blank on a press equipment lien and triggered a § 341 meeting follow-up. The misconception is that “claim amount” alone is enough. The court needs both the claim amount and the collateral value to apply § 506(a).

Field: Creditor Name and Address

The mailing address must be the § 342(c) notice address that the creditor specified in the last two communications, if any. Otherwise use the address on the loan documents.

The consequence of a wrong address is a void notice and a creditor that can later argue its claim is unaffected. Pinegrove Auto Repair LLC sent notice to a closed branch and lost a stay-violation argument. The misconception is that the corporate headquarters is always right. Many lenders require notice at a specific bankruptcy notice center.

Field: Date Debt Was Incurred

Enter the date the loan or security agreement was signed, not the date of the last advance. This date controls § 547 preference look-back and § 546 statute of limitations.

The consequence of a wrong date can be a missed preference recovery for the estate. Tessa Brandt, trustee in Wexford Tools Inc., recovered $180,000 because the date on 206D was inside the 90-day window. The misconception is that the recording date controls. The petition-date relation-back is set by perfection, not contract date.

Field: Account Number (Last 4)

Only list the last four digits. Bankruptcy Rule 9037 requires redaction of full account numbers, full Social Security numbers, full birthdates, and minors’ names.

The consequence of disclosing full numbers is a Rule 9037 sanctions motion and possible identity-theft liability. Sun Coast Marina Inc. faced a redaction motion and a $2,500 sanction. The misconception is that “no one reads PACER.” Public docket access is universal.

Field: Lien Description

Identify the type of lien (purchase-money security interest, blanket UCC-1, mortgage, deed of trust, judgment lien, statutory lien, mechanic’s lien, tax lien) and the collateral covered (e.g., “all inventory and accounts,” “2019 Peterbilt VIN ending 1234,” “real estate at 22 Main St., Akron, OH”).

The consequence of a vague description is a successful § 506(d) lien-stripping attack. Quill & Stone LLC described its lien as “equipment” and the trustee argued the lien did not attach to a $90,000 specific-asset deposit. The misconception is that the loan number alone is enough description. The Code wants the collateral.

Field: Claim Amount and Collateral Value

The claim amount is the full debt as of the petition date, including accrued interest, late fees, and contractual attorney’s fees allowed under § 506(b). Collateral value is the fair market replacement value under Associates Commercial Corp. v. Rash, 520 U.S. 953 (1997) for personal property in a Chapter 13, and a similar standard governs business cases.

The consequence of overstating collateral value is loss of cramdown leverage under § 1129(b). The consequence of understating it is creditor objection and a valuation hearing under Rule 3012. Highline Logistics LLC understated truck values by 40% and faced an emergency valuation hearing. The misconception is that book value is fine. It is not. Use market value supported by an appraisal or NADA/Kelley Blue Book pull.

Field: Unsecured Portion

Subtract collateral value from claim amount. If the result is positive, that is the unsecured deficiency, and it must also appear on Form 206E/F.

The consequence of skipping the unsecured portion is a creditor losing its right to vote in the unsecured class on a Chapter 11 plan. Walden Brewing Co. missed this and faced a re-solicitation order under § 1126. The misconception is that “the lender will fix it with a proof of claim.” Schedules and proofs of claim work in tandem; both must be right.

Field: Contingent, Unliquidated, Disputed

Mark C if the debt depends on a future event (like a guaranty), U if the amount is not yet fixed, and D if you dispute the debt. These flags drive Rule 3003(c)(2) proof-of-claim requirements.

The consequence of leaving the flags off when they apply is that the creditor’s scheduled amount becomes deemed allowed. Forge Metalworks Inc. failed to flag a disputed mechanic’s lien and the lien was deemed allowed at $300,000. The misconception is that you can fight it later without flagging. You generally cannot, absent an objection under § 502(a).

Part 2: Others to Be Notified

Part 2 lists collection agencies, attorneys, servicers, and assignees who should also receive notice. This is not a second creditor list. It is a notice list.

The consequence of skipping Part 2 is missed service. The original creditor gets notice but the loan servicer does not, and the servicer keeps collecting in violation of the § 362 automatic stay. Crane Bay Resort LLC skipped the servicer and faced stay-violation sanctions. The misconception is that “they share notice internally.” They often do not.

Three Real-World Scenarios

Form 206D errors play out in predictable ways. The scenarios below show the most common patterns.

What the Filer Did	What Happened Next
Listed the loan on 206D but forgot the UCC-1 collateral description	Trustee filed a § 506(d) motion and stripped the lien to unsecured
Used book value of equipment instead of market value	Lender forced a Rule 3012 valuation hearing and won a higher secured claim
Forgot to mark the claim “Disputed” while litigating it pre-petition	Scheduled amount was deemed allowed and the debtor lost the dispute

Industry Profile	Typical 206D Pitfall
Restaurant LLC with leased equipment and SBA loan	Confusing lease (Schedule G) with secured loan (206D)
Real estate holding company with multiple mortgages	Listing one global mortgage instead of property-by-property liens
Trucking company with 12 vehicles under one floor-plan loan	Failing to identify each VIN under the lien description

Filing Behavior	Resulting Outcome
Filing 206D without reconciling to 206A/B	Mismatched values triggered a Rule 2004 exam
Skipping Part 2 servicer notice	Servicer kept calling and faced stay-violation sanctions
Filing an outdated form version	Clerk rejected the filing and the 14-day deadline lapsed

Three Named Examples

Example 1: Harborline Strategy LLC. Anita Reyes, the sole member of a small consulting LLC, files Chapter 7. She lists a $45,000 SBA-backed line of credit on 206D with collateral described as “all business assets,” claim amount $45,000, collateral value $12,000, unsecured portion $33,000. She marks the claim neither contingent, unliquidated, nor disputed. She also lists the SBA-approved lender’s bankruptcy notice address from the most recent statement and adds the loan servicer in Part 2. Her form survives the § 341 meeting without objection.

Example 2: Riverbend Holdings LLC. Daniel Cho runs a real estate holding company with three rental buildings. He files Chapter 11 and prepares 206D with one row per mortgage, each row identifying the property by street address, the lender, the date the mortgage was signed, the principal balance plus accrued interest, and the Zillow market value cross-checked against a county appraiser pull. He flags one mortgage as Disputed because of a payoff dispute, which preserves his right to challenge the claim under § 502.

Example 3: Atlas Freight Co. Marcus Heller, CFO of a 12-truck trucking company, files Subchapter V. He lists each truck’s floor-plan financier on 206D, identifying every VIN, mileage, and NADA value in the lien description column. He also lists the IRS as a secured creditor for a $40,000 § 6321 federal tax lien and lists the state’s department of revenue for a $9,000 sales-tax lien. He flags a disputed judgment lien from a prior shipping dispute as Disputed, preserving his ability to object.

Mistakes to Avoid

The following errors come up repeatedly in U.S. Trustee enforcement reports and reported decisions. Each one carries a real, named consequence.

Leaving the unsecured portion blank. The unsecured deficiency is invisible to the unsecured class and the creditor loses voting rights, leading to plan re-solicitation under § 1126.
Listing book value instead of market value. Under Associates Commercial Corp. v. Rash, market value controls, and an understatement triggers a Rule 3012 valuation hearing.
Failing to flag contingent, unliquidated, or disputed claims. The scheduled amount is deemed allowed under Rule 3003(b)(1), and you lose the right to object without filing an objection under § 502(a).
Skipping Part 2 servicers and collection agents. Service is incomplete and the § 362 automatic stay does not bind the unnoticed party for willful-violation purposes.
Using full account numbers. Rule 9037 requires redaction, and the violation invites sanctions and identity-theft liability.
Confusing leases with secured loans. True leases belong on Form 206G, and disguised security arrangements belong on 206D under UCC § 1-203.
Forgetting to mark the form as amended. A Rule 1009 amendment without the checkbox creates docket confusion and risks rejection.
Listing one global lien instead of property-specific liens. Lenders with blanket UCC-1 filings still need the underlying assets identified to avoid § 506(d) lien stripping.
Forgetting tax liens. Federal liens under § 6321 and state statutory liens are secured claims and must be on 206D, not 206E/F.
Filing the wrong version of the form. Always pull the current PDF from uscourts.gov.

Do’s and Don’ts

The do’s below come straight from the Federal Rules of Bankruptcy Procedure and the U.S. Trustee Manual.

Do cross-check every 206D row against Form 206A/B so the collateral exists on the asset side at a comparable value.
Do pull a fresh UCC-1 search from the secretary of state to confirm every perfected lien.
Do use the creditor’s § 342(c) notice address rather than a generic corporate headquarters.
Do support every collateral value with a source (appraisal, NADA, Kelley Blue Book, Zillow, or county tax record).
Do mark Disputed on any claim where you intend to file a § 502 objection later.

The don’ts protect you from sanctions, dismissal, and waived rights.

Don’t estimate values to the nearest hundred thousand. Use specific numbers anchored to a source.
Don’t leave the unsecured deficiency off Form 206E/F.
Don’t include full Social Security or full account numbers under Rule 9037.
Don’t sign 206D blind. Officers face perjury exposure under 18 U.S.C. § 152.
Don’t wait past the Rule 1007(c) 14-day deadline without a motion for extension.

Pros and Cons of Aggressive Valuation

Some debtors push collateral values low on 206D to maximize cramdown leverage. Others push values high to keep secured creditors fully secured. Each approach has trade-offs.

Pro: Lower collateral values increase the unsecured class size and may help confirm a § 1129(b) cramdown.
Pro: Lower values let the debtor strip junior liens under § 506(d) where allowed.
Pro: Honest, supported low values defeat overreaching creditor § 1111(b) elections.
Pro: Clear values speed § 363 sale approvals.
Pro: Documented values reduce Rule 2004 discovery battles.
Con: Aggressively low values invite Rule 3012 valuation hearings and expert fees.
Con: A losing valuation fight raises legal costs and erodes the estate.
Con: A creditor’s § 1111(b) election can be triggered by a low value and tie up the plan.
Con: A pattern of understatement risks bad-faith findings under § 1112(b).
Con: Officers signing under penalty of perjury face personal exposure under 18 U.S.C. § 152 for unsupported numbers.

State-Level Nuances After the Federal Rules

Federal bankruptcy law sets the form, but state law decides whether a lien attached and was perfected. Always start with Article 9 of the UCC for personal property and your state’s recording statutes for real property.

In Texas, mechanic’s and materialman’s liens follow Chapter 53 of the Texas Property Code, and the perfection date controls the 206D entry. In California, real-estate liens follow Civil Code § 2924, and you must list the trustee on the deed of trust in addition to the beneficiary. In New York, judgment liens require docketing under CPLR § 5018, and the docket date drives the lien’s priority.

The consequence of ignoring state law is listing a lien that never attached. Coastal Surveys LLC listed a lien that was never perfected under California law and the trustee avoided it under § 544. The misconception is that “the lender filed it, so it’s good.” A filed UCC-1 with a defective collateral description fails under UCC § 9-108.

Recap of Key Court Rulings

Five cases shape how courts read Form 206D entries.

Associates Commercial Corp. v. Rash, 520 U.S. 953 (1997) sets replacement value as the standard for collateral that the debtor keeps. Dewsnup v. Timm, 502 U.S. 410 (1992) limits lien stripping in Chapter 7 for individual debtors but informs how courts read § 506(d) generally. In re Rash and In re Sunnyslope Housing LP, 859 F.3d 637 (9th Cir. 2017) extend valuation rules to commercial collateral. In re Retz, 606 F.3d 1189 (9th Cir. 2010) treats reckless disregard as enough for § 727(a)(4) false-oath denial of discharge.

The plain-English takeaway is that judges read 206D as a sworn financial statement. The consequence of careless entries is loss of discharge, lien stripping reversed, and personal liability. Helena Strand, an officer of a closed S-corp, lost her individual discharge defense after a Retz-style finding tied to numbers on her company’s 206D.

How to Amend Form 206D

Amendments are routine. Rule 1009(a) lets a debtor amend a schedule “as a matter of course” any time before the case is closed.

Mark the amended box on the form, file the amendment through CM/ECF, pay any local-rule amendment fee, and serve notice on every affected party. The consequence of skipping service is that the amendment is not effective against unnoticed creditors. Greenline Foods Inc. amended without service and faced a successful objection at confirmation. The misconception is that amendments are retroactive without notice. They are not.

Filing Mechanics and Fees

You file Form 206D electronically through PACER/CM-ECF. The filing itself does not carry a separate fee, because the petition fee under 28 U.S.C. § 1930 covers the schedule. Amendments may carry a local fee, often $34, depending on the district’s local rules.

The consequence of a fee error is rejection. Sun Coast Marina Inc. missed an amendment fee in the Middle District of Florida and the amendment was struck. The misconception is that fees waived under in forma pauperis extend to non-individual debtors. They do not. Corporate debtors cannot proceed IFP.

FAQs

Is Form 206D the same as Schedule D for individuals?

No. Form 206D is for non-individual debtors. Individual debtors use Form 106D, and the line items, certifications, and signature blocks differ.

Do I have to list a creditor whose lien I plan to dispute?

Yes. List every secured creditor and mark the claim Disputed so you preserve your right to object under § 502(a).

Does an unperfected lien still go on 206D?

Yes. List it and flag any dispute, because the trustee may still try to avoid it under § 544, and the creditor still deserves notice.

Can I value collateral at book value?

No. Use fair market or replacement value supported by an appraisal, NADA, or comparable source under the Rash standard.

Do I list the unsecured deficiency on 206D or 206E/F?

Yes — both. Show the unsecured portion in the 206D column and also list the same creditor on Form 206E/F for the deficiency amount.

Are tax liens secured claims for 206D?

Yes. Federal tax liens under § 6321 and state statutory tax liens are secured by the debtor’s property and belong on 206D.

Does an equipment lease go on 206D?

No. True leases belong on Form 206G. Only put a lease on 206D if it is a disguised security agreement under UCC § 1-203.

Can I file Form 206D late?

No — not without leave. You need a Rule 1007(c) extension motion showing cause, otherwise the case faces dismissal.

Do I list guarantors on 206D?

No. Guarantors of the debtor’s secured debt belong on Form 206H, the codebtor schedule.

Will the bankruptcy court correct mistakes for me?

No. The court does not audit your schedules. You must amend under Rule 1009, and unamended errors are binding.

Is a signature on Form 206D under penalty of perjury?

Yes. The declaration is signed under 28 U.S.C. § 1746 and exposes the signer to 18 U.S.C. § 152 criminal penalties for false statements.

Do single-member LLCs file 206D or 106D?

No to 106D. A single-member LLC is a separate legal entity and uses the non-individual 206-series forms.

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