The creditor is arguing that the debtor should have to surrender or pay for the TV that was used as collateral because she has more than one, and that the new statutory definition of “household goods” only allows for a single TV. My argument is going to be that the amendment to section 522(f)(4)(A) did not change the treatment of “household furnishings” or “appliances” in the main part of 522(f). There is also a second issue involving a riding lawn mower which was originally a PMSI loan, but that account was later rolled into a second non-PMSI loan with the same creditor. I’m confident that this defeats their PMSI status, but I don’t know how we can fit this into 522(f). It’s not a household good or furnishing, but it could qualify as an appliance. Is anyone aware of any 522(f) cases involving lawn equipment?