By Ken Siomos, Staff Attorney to Chapter 13 Trustee John H. Germeraad (Springfield, IL)
The Bankruptcy Code allows debtors to “cure” defaults and save their property or simply return to a no-default status on unsecured debts.1 The terms of the cure are determined under applicable non-bankruptcy law and the debtors’ contract.2 Historically, Courts have understood the cure provisions to allow debtors to put themselves in a position “as if the default had never occurred.”3 But the Fourth and Ninth Circuit Courts . . .
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