How have the courts interpreted the meaning of Section 523(a)(8)(A)(ii) of the federal bankruptcy code?

⁴ In Desormes v. U.S. Tr. (In re Desormes), a pro se debtor sought to discharge in bankruptcy a private loan he took out to attend a for-profit law school. See 569 F. App'x 42, 43 (2d Cir. 2014). The bankruptcy court's refusal to discharge the loan under 523(a)(8)(A)(ii) was affirmed, but the (non-binding) order did not squarely take on the statutory interpretation question at the center of this appeal. The debtor's primary contention was that his loan fell outside of 523(a)(8)(A)(ii) s scope because he did not receive funds directly. The panel's single sentence of analysis rejects that argument. See id. And while the debtor's briefing did raise an argument about the scope of 523(a)(8)(A)(ii), the panel did not engage with it.