By The Honorable William Houston Brown (Retired)
Ninety-day bar date for filing claims applied to secured creditors who wish to receive distribution in Chapter 13 case. The debtor objected to untimely proofs of claim filed by the mortgage lender, and the creditor argued that Rule 3002(c)’s 90-day deadline only applied to unsecured claims. If a creditor expects to receive a distribution in a Chapter 13 case, a proof of claim must be filed, whether the debt is unsecured or secured. Acknowledging that Rule 3002(a) specifically addresses only unsecured creditors and that . . .
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