By The Honorable William Houston Brown (Retired)
Change of circumstances required for post-confirmation modification. Reviewing issues concerning the requirements for modification of confirmed plans, the court noted first that § 1329 provides for the court’s discretion in whether to approve modification, and that there was a split of authority on whether a change in circumstances is required as a threshold. The court held that in considering motions to modify, it would consider whether the proposed modification fits within the statutory grounds of § 1329, whether the circumstances giving rise to the proposed modification were unknown or . . .
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