In General Motors Acceptance Corp. v. Waligora, 24 B.R. 905 (W.D.N.Y. 1982), an individual's purchase of an automobile was financed with a loan from GMAC. Although an application for a certificate of title was submitted to DMV listing GMAC as a lienholder, DMV issued a certificate of title which did not indicate any lien on the vehicle. The owner subsequently filed for bankruptcy. The United States Bankruptcy Court held that as a result of the omission, GMAC did not attain the status of a secured creditor, and that the trustee in bankruptcy could avoid the lien. GMAC appealed to the United States District Court. The District Court affirmed. The District Court in Waligora acknowledged that Vehicle and Traffic Law 2118 (b)(1)(a) superficially supported GMAC's position that GMAC's mere delivery to DMV of an application for a certificate of title listing the name and address of the lienholder, and accompanied by the appropriate supporting documents, was sufficient to perfect GMAC's lien. However, the District Court then observed that the provisions of VTL 2108(a)(3), 2 107(c), 2118(b)(2)(B), 2119, and 2107(c) collectively (1) require DMV to list lienholders on certificates of title and notify lienholders that the lien has been recorded, and (2) permit lienholders if they do not receive such notice to themselves demand a listing of their lien on the certificate, and obtain an administrative hearing if they do not receive satisfaction. The District Court determined that these sections "basically enable a lienholder to protect himself from some clerical error such as an inadvertent omission from the certificate of title of his position as lienholder." (24 B.R. at 907.) Such protection, opined the District Court, would be meaningless if a security interest were perfected by the mere delivery of an application to DMV. Continued the District Court, (24 B.R. at 908): Furthermore, [VTL] Article 46 is intended to provide for the orderly transfer of motor vehicles and to protect purchasers as well as lenders . Under Article 46 a purchaser should be able to determine whether there are any outstanding liens on the automobile merely by examining the face of the certificate of title without referring to a central filing repository.