From the Editor – Confirmation

By The Honorable William Houston Brown (Retired)

Plan did not properly address 910 creditor’s liens. Finding that the plan did not satisfy one of the three options for addressing a secured claim under § 1325(a)(5), specifically failing to provide for the 910 creditor’s retention of lien, the Panel observed that in response to the creditor’s objection to confirmation, the debtors could have amended the plan to include a nonstandard provision addressing lien retention. Such a nonstandard provision would have allowed the plan to conform to § 1325(a)(5), and that nonstandard provision . . .

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