The EPA and TCEQ provide all secured creditors with guidance to minimize their potential liability under CERCLA and the TSWDA, respectively, for the cost of cleanup and environmental contamination. The primary protection is the “secured creditor” exemption which exempts persons who would otherwise be liable as owners or operators from liability for cleanup costs. The exemption applies to “any person who, without participating in the management of a facility, holds indicia of ownership primarily to protect his security interest in the facility.” It is available under both CERCLA and the TSWDA.