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In Milavetz, Gallop & Milavetz, PA. v. United States, the Supreme Court of the United States held that, under section 227 of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA), attorneys who provide bankruptcy counsel are "debt relief agencies." The Court also held two BAPCPA provisions constitutional: one provision that prevented debt relief agencies from advising a debtor to incur more debt in contemplation of bankruptcy and another that imposed disclosure requirements on debt relief agencies. In light of the inconsistent and unclear interpretations of BAPCPA provisions considered in this case, the Court's ruling acts to ease concerns that stem from incipient First Amendment6 challenges to BAPCPA.