The Fourth Circuit has held that under applicable state law creditors have purchase money security interests in the portion of a debt used to pay off of negative equity on a trade-in vehicle. See In re Price, __ F.3d __, 2009 WL 975796 (4th Cir. Apr. 13, 2009). The Fourth Circuit reasoned that a natural reading of the statute mandated such finding “because that financing enabled the Prices to acquire rights in their new car,” thus the trade-in of the vehicle in which the debtors had negative equity was closely connected to the acquisition of the new vehicle. Additionally, the court found that its decision was supported by Congress’ intent in enacting the hanging paragraph of the Bankruptcy Code, “to protect secured car lenders from having their claims bifurcated in Chapter 13." The court, however, fails to address the fact that purchase money obligations traditionally have not included the payment of antecedent debt.