The same is true respecting most types of unrecorded liens or encumbrances. The liens against the businesses involved unpaid employee payroll taxes. The judgment may be collected through wage garnishment and liens. This include collections, charge offs, repossession, foreclosures, bankruptcies, liens and judgments. Forms of security rights include mortgages, pledges and liens. However, BAPCPA limited the ability of debtors to avoid liens through bankruptcy. Notices of releases of liens generally must be filed before property may be transferred. Tax liens and tax deeds can be purchased by an individual investor. Most liens, however (such as real estate mortgages and security interests for car loans), survive. Some types of liens may be avoided through a Chapter 7 bankruptcy case. They may be financial (for example, liens) or non-financial (for example, easements, private restrictions). The documents include fake liens, deeds, and property claims. Filing fraudulent notices of liens or documents is both a crime and a civil offense. The English common law recognized mechanic's liens respecting only personal property. Clearing up fraudulent notices of liens may be expensive and time-consuming.