If you go bankrupt, can you borrow a down payment for a house using a co-signer?

I didn't have enough money for a down payment so they told me to go get a "gift" from a relative, instead I went to a different bank and got a loan and used that as a down payment. My brother went bankrupt a few years ago and they told him he needed 20% down in order to buy a house. Couldn't he just do what I did with a co-signer for the down payment loan?