  Accretion disks in white dwarf systems are believed to be tilted. In a recent
publication, the lift force has been suggested to be a source to disk tilt, a
source that is likely relevant to all accretion disk systems. Lift is generated
by slightly different supersonic gas stream speeds flowing over and under the
disk at the bright spot. In this conference proceeding, we focus on whether a
brown dwarf donor star accreting onto a white dwarf primary has enough mass to
contribute to disk tilt. We also would like to obtain whether a white dwarf -
brown dwarf close binary system has enough mass to induce and maintain a disk
tilt of four degrees. We adopt SDSS 103533.03+055158.4 as our model system
which has a mass transfer rate of ((10\pm2) \times 10^{-12}) M$_{\odot}$
yr$^{-1}$. We find that the brown dwarf in SDSS 1035 does not have enough mass
to contribute to disk tilt. We find a gross magnitude of the minimum mass
transfer rate to be $\sim10^{-10}$M$_{\odot}$yr$^{-1}$. We conclude that SDSS
1035 does not seem to have a high enough mass transfer rate to induce and
maintain an observable disk tilt. Hence one reason why brown dwarf donor
systems may be so difficult to find could be due to their low mass transfer
rates which do not induce observable dynamical effects that is typical in white
dwarf-red dwarf CVs.
