"[A] three-judge panel of the U.S. 6th Circuit Court of Appeals upheld a Michigan federal district court's finding that unless individual debtors were already putting money toward retirement savings accounts in the six months before the bankruptcy, they cannot begin doing so after the bankruptcy is filed, as those funds must be set aside for creditors." [Penfound v. Ruskin, No. 19-2200 (6th Cir. Aug. 10, 2021)]