March 17, 2021 Unsurprisingly, Second Circuit Reaffirms the Strictures of Brunner Second Circuit insinuates that “undue hardship” and the Brunner test are synonymous. 2nd Circuit , January 6, 2016 SEC Can Freeze Assets Without Violating the Automatic Stay, Circuit Holds Bankruptcy failed to insulate the Wyly brothers from an SEC asset freeze. 2nd Circuit ,