The strict test established by Brunner v. New York State Higher Education Services Corp., 831 F.2d 395 (2d Cir. 1987), for wiping out student loans based on “undue hardship” under Section 523(a)(8)(B) of the Bankruptcy Code “has received a lot of criticism for creating too high of a burden for most bankruptcy petitioners to meet.” Rosenberg v. N.Y. State Higher Education Services Corp., 610 B.R. 454 (Bankr. S.D.N.Y. 2020).But the 7th U.S. Circuit Court of Appeals adopted Brunner. And bound by that precedent, Bankruptcy …