The Court in In re Tembulak, ___ B.R. ___ (2007 WL 420188 (Bankr.D.N.J.) held that a debtor who died after filing chapter 7 bankruptcy was exempted from BAPCPA’s requirement to complete an instructional course concerning personal financial management after the filing of the petition in order to obtain a discharge. The Court based its decision on section 109(h)(4) which allows a bankruptcy court to waive the requirement of a personal financial management course for debtors who are incapacitated, disabled, or on active military duty in a military combat zone.
