In re Renaud

The Renauds refinanced their mobile home and the underlying real property with Simmons Bank (Simmons); the prior lienholder released its lien on the mobile home's certificate of title, and Arkansas issued a clean title, but Simmons never noted its own interest on that title, even though it properly recorded a mortgage on the real property covering all existing and future fixtures. After the Renauds filed for bankruptcy, the bankruptcy court found Simmons had failed to perfect its interest in the mobile home, since Arkansas law requires perfecting a security interest in a mobile home solely through notation on its certificate of title; Simmons appealed, arguing its recorded mortgage alone perfected its interest.