As a prerequisite to a claim’s payment, Rule 3002.1 requires certain secured creditors to provide to the trustee and the debtor notice of the full value of the secured creditor’s claim, including any “fees, expenses, and charges” related to the claim. Two bankruptcy courts have demonstrated a willingness to expand the reach of Rule 3002.1’s noticing requirements. These courts generally require creditors holding claims secured by any interest in the debtor’s real property to comply with Rule 3002.1’s noticing requirements despite not falling within the reach of Rule 3002.1’s . . .
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