What is the test for finding fraud under Section 523(a)(2)(A) of the Bankruptcy and Insolvency Act?

8 To find fraud under 523(a)(2)(A), a creditor must successfully demonstrate five elements: (1) The debtor must have made a representation; (2) at the time the representation was made the debtor must have known it was false; (3) it must have been made with the intention and purpose of deceiving the creditor; (4) the creditor must have relied on the representation; and (5) the creditor must have sustained damage because of that as a proximate cause. Lee-Benner v. Gergely (In re Gergely), 110 F.3d 1448, 1453 (9th Cir. 1997).