and whether its failure to do so violates the automatic stay or confirmation order. When presented with this issue in a prior case, I found that surrender under a Chapter 13 plan does not require the creditor to take affirmative action to foreclose on property and failure to do so does not violate the automatic stay. In re Arse-nault, 456 B.R. 627, 630 (Bankr.S.D.Ga. 2011) affd Arsenault v. JP Morgan Chase Bank, N.A., Civ. Action No. CV 311-106 (S.D.Ga. August 30, 2012); see also Pratt v. Gen. Motors Acceptance Corp., 462 F.3d 14, 19 (1st Cir.2006) (“[Njothing in subsection 521(a)(2) remotely suggests that the secured creditor is required to accept possession .... ”); In re Canning, 442 B.R. 165, 172 (Bankr.D.Me.2011); In re Service, 155 B.R. 512, 514-15 (Bankr.E.D.Mo.1993) (<HOLDING>); Hon. W. Homer Drake, Jr., Hon. Paul W.
holding that a patent attorneys argument did not clearly and unmistakably surrender the subject matter holding that a debtor in bankruptcy may claim as exempt the cash surrender value of a life insurance policy insuring the life of the debtor that is payable to a beneficiary other than the debtor under dccode ann  314716a2001 despite the absence of the term cash surrender from the statute holding that the consent of both parties is required to annul their contract holding that as a general rule  affirmative action by the creditor must be taken to make it known to the debtor that the creditor has exercised his option to accelerate recognizing surrender as a contractual act but only with the consent of both parties requiring surrender by the debtor and willing acceptance of title by the creditor