Congress, of course, remains free to establish a uniform definition of PMSI applicable to cases governed by the hanging paragraph. 2 . Several federal circuit cases from the 1980s addressed the treatment of overloaded PMSIs in bankruptcy, with respect to the anti-avoidance provision in § 522(f). See In re Billings, 838 F.2d at 408 (suggesting that an obligation can "be considered only partly a purchase money debt," and therefore a security interest can still be considered a PMSI with respect to the portion that is not overloaded (emphasis added)); Pristas v. Landaus of Plymouth, Inc. (In re Pristas), 742 F.2d 797, 801 (3d Cir.1984) (adopting "pro tanto preservation of purchase-money security interests,” but invalidating overloaded portions of PMSIs); In re Matthews, 724 F.2d at 801 (<HOLDING>). 3 . The Fourth Circuit has suggested that
holding that a purchase money security in jewelry was not lost when the perfected purchase money security interest was consolidated with a subsequent retail installment contract holding that when a creditor refinances a purchase money obligation the pmsi is extinguished recognizing that an action will lie for conversion of money when its identification is possible and there is an obligation to deliver the specific money in question or otherwise particularly treat the specific money holding that in georgia pursuant to  9107 of the ucc refinancing of a promissory note transforms the obligation thereby destroying purchase money nature of the security interest therefore the creditor lost its purchase money security interest pmsi in a television set when the loans were consolidated and lien was avoidable id 89 br 264 18 bcd 58 holding that under minnesota law refinancing and consolidation of purchase money loans did not destroy their purchase money character for bankruptcy lien avoidance purposes