of the provision. See, e.g., Ghomeshi v. Sabban (In re Sabban), 600 F.3d 1219, 1222 (9th Cir.2010) (“[M]aking out a claim of non-dischargeability under § 523(a)(2)(A) requires the creditor to demonstrate ... [that] the debtor made representations; ... that at the time he knew they were false; [and] that he made them with the intention and purpose of deceiving the creditor.” (emphasis added)); Citibank v. Eashai (In re Eashai), 87 F.3d 1082, 1086 (9th Cir.1996) (“[T]o prove actual fraud, a creditor must establish ... that the debtor made the representations-” (emphasis added)). In fact, we have recently suggested that the debtor’s involvement in the fraudulent activity might be the only relevant consideration in determining whether the exception applies. See Sabban, 600 F.3d at 1222 (<HOLDING>). We have read § 523(a)(4) in a similar
holding that the principal of a corporate debtor does not become a transferee by the mere act of causing the debtor to make a fraudulent transfer recognizing potential for fraudulent transfer in foreclosure context if debtor enjoyed significant equity in property but received little or no value from the transfer holding that where the debtor did not act but merely had knowledge of and benefit from the fraudulent transfer he was not considered to have performed it holding that judgment in prior state court proceeding against debtor in which court found that debtor made false representations had preclusive effect on courts determination of nondischargeability under  523a2a based on false representations holding that a debtor need not have received a benefit from the fraudulent activity in order for  523a2a to prevent a discharge