IRA Held Non-Exempt In Bankruptcy

[pdf] (standardagents.com): ". . . [M]onies inside IRAs do not have ERISA protection from claims of creditors. ERISA protects the accounts of employer-sponsored plans; IRAs are by definition individual plans. This is not new information and most of our readers are aware of it, but a recent bankruptcy case, In re Richard Rousey, decided by the 8th Circuit bankruptcy Appellate Panel reminds us to continue counseling clients on this important issue."