. Title 11 of the United States Code,

. Nothing in this opinion is intended to address whether and to what extent the failure to schedule a secured debt as disputed, or failure to schedule potential counterclaims against a foreclosing lienholder as an asset, has any collateral estoppel or judicial estoppel effect in an action to foreclose that lienholder's security interest. Of course events subsequent to the filing of the bankruptcy petition or the statement of intention may have an impact on the applicability of either of these doctrines. For the most part, such issues should be raised before, and decided by, the state court before which the foreclosure action is pending. In re Kourogenis, 539 B.R. 625 (Bankr. S.D. Fla. 2015). I recognize that many of my colleagues reopen bankruptcy cases to address disputes between debtors and lienholders with respect to surrendered property. However, the time for a lender to seek relief from the bankruptcy court due to a debtor's failure to perform a statement of intention is during the bankruptcy case, and the lender’s failure to do so should foreclose the lender’s return to bankruptcy court for such relief. See In re Rodriguez, No. 12-12043-BKC-AJC, 2015 WL 4872343, at *2 (Bankr. S.D.Fla. Aug. 12, 2015) (During the bankruptcy case a lender failed to tender a reaffirmation agreement to a debtor and did not move to compel the debtor to present a reaffirmation agreement notwithstanding the debtor's stated intention to reaffirm. The court refused to reopen the bankruptcy case three years later to compel the debtor to surrender the property because, among other reasons, the lender had "sat on its rights”. The debtor’s failure to perform his stated intention is a failure that the lender should have brought before the court during the pendency of the bankruptcy case.).

. At a hearing on November 9, 2015, both parties agreed that surrender is not synonymous with physical turn over of the Property. Virtually every court that has considered the meaning of surrender has agreed that surrender and turn over are not synonymous, whether surrender is to the chapter 7 trustee or to a lienholder, and whether surrender is in chapter 7 or chapter 13. See, e.g., Pratt v. General Motors Acceptance Corp. (In re Pratt), 462 F.3d 14 (1st Cir. 2006) (surrender means to make the collateral available); In re Plummer, 513 B.R. 135, 143 (M.D.Fla. 2014) (" ‘Surrender’ does not require the debtor to turn over physical possession of the collateral” but rather allows the secured creditor or chapter 7 trustee, as the case may be "to obtain possession by available legal means without interference."); In re Kasper, 309 B.R. 82 (Bankr.D.D.C. 2004); In re Kourogenis, 539 B.R. 625 (Bankr.S.D.Fla. 2015); In re Metzler, 530 B.R. 894 (Bankr.M.D.Fla. 2015). Accord Internal Revenue Serv. v. White (In re White), 487 F.3d 199, 205 (4th Cir. 2007) (Surrender in a chapter 13 case "entails the seemed creditor ultimately holding all rights, including the right of possession, in the property securing the claim.”); In re Cornejo, 342 B.R. 834, 836 (Bankr.M.D.Fla. 2005) (" '[Surrender,’ in the context of a Chapter 13 plan, means the relinquishment of any rights a debtor has in the collateral.”). See also 4 Collier on Bankruptcy ¶ 521.16. p. 521-61 (16th ed. 2015).

As a practical matter, in most consumer chapter 7 cases, the debtor surrenders only constructive possession of property to the trustee, unless the trustee demands that physical possession also be surrendered.... In this regard, the use of the word "surrender” rather than "turn over” is significant. Unlike the duty of a third patty holding property of the estate to turn over that property under section 542, the debtor's duty is simply to relinquish the debtor’s rights in property to the trustee, and to cooperate with the trustee’s efforts to take possession of it should the trustee choose to do so.

I also agree that "surrender” and "turn over” are not synonymous.

However, courts do not necessarily agree what "not interfering” with the lender means. Compare Failla v. Citibank, N.A. (In re Failla), 542 B.R. 606, 610-12 (S.D.Fla. 2015) (Surrender means the debtor is prohibited from "interfering or impeding the secured creditor’s efforts to take possession of the property by available legal means.”); In re Calzadilla, 534 B.R. 216 (Bankr.S.D.Fla. 2015) (same) with Rodriguez, 2015 WL 4872343 at *4 (Failure to surrender entitles a lienholder stay relief; surrender is "not a bar by injunction to defending a foreclosure action which would be unconstitutional, inequitable and unjust.”).

. Official form number 8.

. 11 U.S.C. §§ 1207, 1306, 1115.

. For an excellent discussion on the different options set forth in 11 U.S.C. § 521(2) (predecessor to 11 U.S.C. § 521(a)(2)), see In re Kasper, 309 B.R. 82.

. While only a chapter 7 individual debtor is required to file a statement of intention, in an example of poor statutory drafting, 11 U.S.C. § 1307 lists as a basis for conversion or dismissal a debtor's failure to file a statement of intention as required by section 521(a)(2), 11 U.S.C. § 1307(c)(10), and includes in a chapter 13 trustee’s duties an obligation to make sure the chapter 13 debtor performs his statement of intention as required by section 521(a)(2). 11 U.S.C. § 1302(b)(1) incorporating by reference 11 U.S.C. § 704(a)(3). Since a chapter 13 debtor has no obligation under section 521(a)(2) these Bankruptcy Code sections are meaningless. 4 Collier on Bankruptcy ¶521.14, p. 521-45 (16th ed. 2015).

. The automatic lifting of the stay provided in sections 521(a)(6) and 521(a)(7) (dangling paragraph) and in section 362(h)(1), applies to all personal property securing a claim, irrespective of whether that property is still property of the estate at the time the applicable deadlines have expired.

. 11 U.S.C. § 362(h)(1); 11 U.S.C. § 521(a)(6); 11 U.S.C. § 521(a)(7)(dangling paragraph). This is subject to the rights of the trustee to argue that the property has some value to the estate such that the stay should not be lifted. 11 U.S.C. § 362(h)(2); 11 U.S.C. § 52 l(a)(7)(dangling paragraph).

. It is not clear what "not retain possession” means, Nor is it stated who instead is entitled to the possession, although based on the context, presumably possession would be re*556linquished to the holder of the purchase money security interest. See In re Alvarez, No, 10-B-28565, 2012 WL 441257, (Bankr.N.D.Ill. Feb. 10, 2012).

. 11'U.S.C. § 554(a) or (b).

. To my knowledge, I have not had a case where a chapter 7 trustee has offered, or any secured creditor has requested the trustee, to hand over the creditor’s collateral as provided by 11 U.S.C, § 725.

. 11 U.S.C. § 554(c).

. If the debtor successfully exempts the real property then the property is no longer property of the estate and the property is no long- • er subject to the requirements of section 521(a)(2). However a chapter 7 individual debtor still has the right to redeem the exempt property, as well as property that has been abandoned by the trustee'to the debtor in accordance with section 554, 11 U.S.C, § 722. Conversely, even if the property is abandoned back to the debtor, a lienholder still has its right to pursue its remedies against the collateral, limited only by the discharge injunction which limits the lender's in personam rights against the now former debt- or, but not its in rem rights. See In re Canning, 706 F.3d 64 (1st Cir. 2013).

. In some jurisdictions courts had held there is a fourth option—do nothing—also referred to as “the ride through." See, e.g. Price v. Delaware State Police Fed. Credit Union (In re Price), 370 F.3d 362 (3rd. Cir. 2004); McClellan Fed. Credit Union v. Parker (In re Parker), 139 F.3d 668 (9th Cir. 1998); Homeowners Funding Corp. v. Belanger (In re Belanger), 962 F.2d 345 (4th Cir. 1992). However, those cases have been overruled, at least in part— see n. 26 infra—by BAPCPA. See Daimler-Chrysler Financial Services Americas, LLC v. Jones (In re Jones), 591 F.3d 308 (4th Cir. 2010); Dumont v. Ford Motor Credit Co., 581 F.3d 1104 (9th Cir. 2009); In re Miller, 443 B.R. 54 (Bankr.D.Del,2011). The “ride through" was never an option in the Eleventh Circuit. In Taylor v. AGE Federal Credit Union (In re Taylor), 3 F.3d 1512 (11th Cir. 1993), the court held that an individual chapter 7 debtor must make and perform his statement of intention and if retention is the choice, then the debtor must redeem or reaffirm, Accord Bank of Boston v. Burr (In re Burr), 160 F.3d 843 (1st Cir. 1998); Johnson v. Sun Finance Co. (In re Johnson), 89 F.3d 249 (5th Cir. 1996); In re Edwards, 901 F.2d 1383 (7th Cir. 1990).

. 11 U.S.C. § 521(a)(6).

, 11 U.S.C. § 362(h)(2); 11 U.S.C. § 521(l)(7)(dangling paragraph).

. 11 U.S.C. § 521(a)(4).

. Some courts have cited a footnote in Taylor where, when describing surrender, the court wrote "[sjurrender provides that a debt- or surrender the collateral to the lienholder who then disposes of it pursuant to the requirements of state law.” 3 F.3d at 1514, n.2. This footnote is clearly dicta, In re Plummer, 513 B.R. 135 (Bankr.M.D.Fla. 2014). Had the court analyzed surrender in the context of chapter 7, presumably it would not have made such a broad statement, since surrender of collateral to the lienholder is not an option in chapter 7, except, perhaps with respect to surrender of personal property pursuant to 11 U.S.C, § 521(a)(6), a section of the Bankruptcy Code that did not exist when Taylor was decided. The Taylor footnote illustrates why dicta is not binding—because dicta is recognized as something not relevant or not directly relevant to the facts of the case before the court. As the Eleventh Circuit has repeatedly noted "dicta is not binding on anyone for any purpose.” Edwards v. Prime, Inc., 602 F.3d 1276, 1298 (11th Cir. 2010). See Hittson v. GDCP Warden, 759 F.3d 1210 (11th Cir. 2014); Pretka v. Kolter City Plaza 11, Inc., 608 F.3d 744 (11th Cir. 2010).

.See 11 U.S.C. §§ 1129(b)(2); 1225(a)(5); 1325(a)(5).

. The Metzler court reviewed a chapter 7 case and a chapter 13 case together in its opinion but, notwithstanding the different chapters, analyzed the two cases in the same way. However, that analysis is flawed because while surrender means the same tiling in chapter 7 and chapter 13, the consequences of surrender in chapter 7 and chapter 13 are not the same.

. Several of these courts have also held that such debtors have defrauded the bankruptcy court such that their discharges are at risk or are lost. While not an issue in this case, the remedies suggested by these courts are also in direct conflict with the Bankruptcy Code. The Bankruptcy Code addresses when and under what circumstances a debtor may lose his discharge. Failure to fully perform a statement of intention is not among them. In chapter 7, if the debtor interferes with the chapter 7 trustee’s administration of estate property, .the debtor could lose his discharge. See, e.g. ', 11 U.S.C. §§ 727(a)(2)(B) and' 727(d)(2). If a chapter 12 or chapter 13 debtor fails to surrender property to a lien-holder in accordance with a confirmed plan, that debtor has violated a court order, the consequences of which, pre-discharge may be dismissal, or conversion (11 U.S.C. §§ 1208 and 1307), and, post-discharge is the collateral estoppel effect of the confirmation order. 11 U.S.C. §§ 1227 and 1327 (unless the creditor could prove fraud and only for one year after discharge 11 U.S.C. §§ 1228(d) and 1328(e)). While these courts rely on 11 U.S.C. § 105, the Supreme Court has made very clear that the bankruptcy courts may not use their equitable powers to override express provisions of the Bankruptcy Code, no matter how badly a debtor has behaved. Law v. Siegel, — U.S. —, 134 S.Ct. 1188, 188 L.Ed.2d 146 (2014). Accord Norwest Bank Worthington v. Ahlers, 485 U.S. 197, 108 S.Ct. 963, 99 L.Ed.2d 169 (1988). Cf. 4 Collier on Bankruptcy s ¶ 521.14, p. 521-53 (16th ed. 2015):

The 2005 amendments to the Bankruptcy Code, by specifying particular consequences in certain situations involving the statement of intentions clarify the law [regarding options and ride-through] to some degree. While these [added] provisions ... have their ambiguities and uncertainties, they at least delineate situations in which Congress intended some consequences to flow from the failure to comply with the requirement of filing a statement of intentions or the failure to perform specific acts with respect to the statement. It must be assumed that if Congress intended any other consequences to result from such failure it would have stated them is these new detailed provisions.

. Fla. Stat § 222.25(4). This statute allows a Florida debtor who does not claim, or receive the benefit of, a homestead exemption in a bankruptcy case, to claim an additional $4000 in personal property exemptions, in addition to the $1000 in personal property exemption to which all Florida individual debtors are entitled.

. The court did not address the lender’s delay of three years before seeking relief from the bankruptcy court for the debtor’s failure to stand down in the foreclosure action. Compare In re Rodriguez, 2015 WL 4872343 (the court held a lender’s delay of over three years after a bankruptcy discharge to seek to reopen the chapter 7 case to compel surrender—relief to which the court held the lender was not entitled in any event—was barred by laches, and the court denied the lender’s motion to reopen).

. The court conflates the debtor challenging a debt scheduled as undisputed, an issue addressed by collateral estoppel or judicial es-toppel, see n. 2 supra, with the debtor’s perceived failure to surrender which, as I have already held, has different consequences in different chapters.

. The Taylor court held that "ride through’ should not be a fourth option to a chapter 7 debtor because "[ajllowing a debtor to retain property without reaffirming or redeeming gives the debtor not a 'fresh start' but a ‘head start’ since the debtor effectively converts his secured obligation from recourse to nonre-course with no downside risk”. 3 F.3d at 1516. However, this observation was made in the context of ruling that a debtor who intends to retain property must redeem or reaffirm. The Taylor court, other than its casual inference in a footnote, never discussed the surrender option. See n. 19 supra. The discharge of personal liability with respect to a debt that continues to be secured by collateral is a fundamental aspect of the Bankruptcy Code. To hold that a debtor must either reaffirm a debt secured by real estate or give up the asset is not required by or consistent with the bankruptcy system. Accord Johnson v. Home State Bank, 501 U.S. 78, 111 S.Ct. 2150, 115 L.Ed.2d 66 (1991) (in holding that a chapter 13 debtor whose in personam obligation to a secured creditor was discharged in a chapter 7 case could nonetheless treat the secured creditor’s hen in the chapter 13 plan, the Supreme Court implicitly acknowledged that a debtor whose in person-am liability is discharged can retain possession of the collateral). But see In re Steinberg, 447 B.R. 355 (Bankr.S.D.Fla. 2011) (the case seems to suggest that the lender does not have to accept post-discharge payments on a non-recourse obligation). Collier on Bankruptcy suggests that the additions of sections 521(a)(6), 521(a)(7)(dangling paragraph) and 362(h) in 2005, which'additions clearly eliminate the ride through option for personal property, as well as the enactment of 11 U.S.C. § 5240, evidence first, that until BAPCPA there was a ride through option, and, second, by specifically eliminating the ride through for personal property, Taylor has been partially overruled, and there still is a ride through option for real property. 4 Collier on Bankruptcy ¶ 521.14, p. 521-53 (16th ed. 2015).

. Because debtors were encountering difficulty getting lenders to execute reaffirmation agreements, the Southern District of Florida adopted a local rule giving the debtor the option of filing a motion to compel the lender to perform. Local Rule 1007-3.

. The cases that hold otherwise ignore a fundamental fact—while the Bankruptcy Code requires an individual debtor to file a statement of intention and perform that statement of intention, the Bankruptcy Code does not require the party on the other end of the intention to accept tender of performance. In re Canning, 706 F.3d at 69-70. But, c.f., Pratt v. General Motors Acceptance Corp. (In re Pratt), 462 F.3d 14 (1st Cir. 2006) (secured lender’s refusal to repossess a worthless vehicle or release the lien on the vehicle violated the discharge injunction). A debtor has satisfied his obligations if the debtor has tried to perform his intention. The debtor is not punished if the secured creditor or the trustee does not accept performance. See In re Molnar, 441 B.R, 108 (Bankr.N.D.Ill. 2010) (the debtor timely performed his intention by reaching out repeatedly to the secured lender during the 30 day period to discuss redemption, which overtures the lender ignored); In re Hinson, 352 B.R. 48 (Bankr.E.D.N.C. 2006) (the debtor timely performed her statement of intention by signing a reaffirmation agreement even though the lender did not accept the signed agreement because the debtor had removed attorney fee language that was outside the original loan agreement); In re Alvarez, No. 10-B-28565, 2012 WL 441257 at 7 (Bankr.N.D.Ill., Feb. 10, 2012) (a debtor's obligation to perform his intention “requires only acts within the debtor’s control”).

. Courts are not in agreement regarding when and to what extent a bankruptcy court is bound by the holdings of a district court as controlling precedent. Compare Health Services Credit Union v. Shunnarah {In re Shunnarah), 273 B.R. 671 (M.D.Fla. 2001) (finding bankruptcy courts are "inferior” and bound by published district court opinions, unless an opinion that contains a different holding is published) with In re Romano, 350 B.R. 276 (Bankr.E.D.La. 2005) (holding a single decision of a district court in a multi-judge district is not binding upon a bankruptcy court in the district). I have previously ruled that in the absence of direction from the Eleventh Circuit to the contrary, at least in non-single court districts such as the Southern District of Florida, district court opinions may be persuasive, but they are not binding precedent. Committee v. FDIC as Receiver {In re BankUnited Financial Corp.), 442 B.R. 49 (Bankr.S.D.Fla. 2010).

. A bankruptcy court may reopen a case to "administer assets, to accord relief to the debtor, or for other cause. 11 U.S.C. § 350. "A decision to reopen a case under section 350(b) is based on ‘the particular circumstances and equities of each case’.... When deciding whether to reopen a closed case, courts generally consider the benefit to creditors, the benefit to the debtor, the prejudice to the affected party and other equitable factors.” In re Rodriguez, 2015 WL 4872343 at *1-2.