Rice v. Simmons First Bank of Searcy (In Re Renaud)

VENTERS, Bankruptcy Judge.

This is an appeal from two rulings of the bankruptcy court 1 holding that Simmons First Bank of Searcy (“Simmons Bank”) holds unperfected liens on Henry and Opal Renaud’s (“Debtors”) 2001 Polaris ATV and mobile home. The issues on appeal are twofold: (1) whether a security interest in an ATV may be perfected under Arkansas’ Uniform Commercial Code when that interest was not noted on the ATVs certificate of title, and (2) whether the Debtors’ mobile home was transformed from personal to real property when the Debtors affixed it to their land, such that a security…