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From the Editor’s Desk – Postconfirmation Modification

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By The Honorable William Houston Brown (Retired)

Decline in value did not permit modification and stripping of junior lien. When equity existed at confirmation to partially support second mortgage, alleged decline in value after confirmation did not permit modification to strip lien; effect of confirmation protected mortgage. If there were cause to reconsider the claim under § 502(j), that would not permit reclassification of the claim that was partially secured and protected from modification at confirmation. Warren v. PNC Bank, Inc. (In re Warren), 499 B.R. 914 (Bankr. S.D. Ga. 2013).

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