A Claim Accrues Under an Installment Contract with an Optional Acceleration Clause When the Creditor Takes an Affirmative Action to Make Clear to the Debtor That It Has Exercised the Acceleration Option. 

 
When a creditor has a contractual right to accelerate a debt without notice, it must take “some affirmative act to make clear to the debtor it has accelerated the obligation.”  A variety of actions, including repossession of property, can be sufficient to demonstrate that the creditor has exercised its option to accelerate the payments.  An internal write off is not, however, such an affirmative act but rather merely an internal accounting procedure.  Baseline Financial Services v. Madison, 1 CA-CV 11-0557, 6/5/12.