Viewed as totally independent of the discharge exception which required the false statement to be in writing, a false representation did not need to be in writing. Gear v. Davis, 20 Utah 2d 184, 435 P.2d 923 (1968). Oral misrepresentations made to procure a loan were given no protection.
1A Collier on Bankruptcy ¶ 17.16 at 1637-8 (14 ed. 1926). See also 8 Remington on Bankruptcy § 3319 at 177 (1955); Gear v. Davis, 20 Utah 2d 184, 435 P.2d 923 (1968). False representations made in the form of a false financial statement, on the other hand, by the express provisions of the statute must be in writing.