The New York legislature established formal requirements for lifetime trusts in 1997, including that a lifetime trust in personal property be in writing. See Fasano v. DiGiacomo, 49 A.D.3d 683, 853 N.Y.S.2d 657, 659 (2d Dep't 2008) ( citing Practice Commentaries to EPTL 7–1.17); see alsoRestatement (Third) of Trusts § 20 (2003). In affidavits submitted in support of the motion to impose a constructive trust, the Debtor and Defendant allege that the Defendant “allowed” title to the Vehicle to be in the Debtor's name “on [the] basis of a relationship of trust and confidence,” and that Defendant “fully performed his end of the agreement, having made ALL payments for the purchase of the Vehicle and having fully paid the Note on the Vehicle.”