Issue link: https://mbozikis.ufcontent.com/i/1422521
60 temporary administrative holds, or freezes, on a debtor's deposit accounts while the institution seeks relief from the stay to permit a setoff. Citizens Bank of Md. v. Strumpf, 516 U.S. 16 (1995). Section 362 of the Bankruptcy Code also expressly excepts certain actions from the automatic stay. These exceptions apply in voluntary and involuntary cases under the Bankruptcy Code as well as to applications under the Securities Investor Protection Act (SIPA). 26 Although the automatic stay does not apply to such actions, the trustee or debtor-in-possession may affirmatively seek a stay of such actions under Section 105(a) of the Bankruptcy Code, which provides for permissive injunctive relief. Pursuant to Section 362(b) of the Bankruptcy Code, the filing of a bankruptcy petition or a case under SIPA does not operate or continue to stay the following: (i) criminal actions against the debtor; (ii) various domestic relations actions, such as establishment of paternity, establishment of domestic support obligations, child custody or visitation actions, dissolution of a marriage, or regarding domestic violence, and various collection actions or remedies in connection therewith; (iii) acts to perfect or maintain or continue the perfection of an interest in property to the extent that the trustee's rights and powers are subject to such perfection under Section 546(b) of the Bankruptcy Code or to the extent that such perfection is accomplished within the grace period provided under Section 547(e)(2)(A) of the Bankruptcy Code; (iv) the exercise of police or regulatory powers to promote public health and safety, or against enforcement of a 26 SIPA is discussed more fully in Chapter VII.F.