What is the test for a creditor to succeed in a claim for misrepresentation under section 523(a) (2) of the Federal Trade Act?

Even where a creditor can prove a knowingly false representation was made, and further establish an intent to deceive, a creditor generally cannot succeed unless the creditor also can prove reliance on the false representation. Field v. Mans, 516 U.S. 59 (1995). While 523(a) (2) (A) does not, on its face, expressly require reliance, the requirement has been inferred from the fact that the debt must have been "obtained by" the fraud or misrepresentation. Field, 516 U.S. at 66. That is, the fraud must have caused the debt which, in turn, requires that the claimant have relied upon the misrepresentation.