Detroit Trust Company v. Pontiac Savings Bank…
“ Replying to the contention that an assignee for the benefit of creditors in Michigan may avoid unrecorded chattel mortgages, and that the rights of a trustee in bankruptcy are not less, the circuit court of appeals further said: 'As we pointed out in the Huxoll Case, the Michigan decisions mean no more than that the assignee is by the assignment given a lien upon the property which did not before exist. The mere fact that a lien is created under statutory assignment for the benefit of creditors does not give a lien under the bankruptcy act. ”
