Section 1329(c), as it currently exists, forecloses the ability of Chapter 13 debtor to modify a confirmed plan to alter the plan payment amount while maintaining an extended plan, previously approved under the CARES Act. (Hanan) In re Nelson, 2022 WL 6795096 (Bankr. E.D. Wis. October 11, 2022)
Immediately after the onset of the COVID-19 pandemic, Congress sought to assist debtors who were in Chapter 13 cases but had been financially impacted by the pandemic. Congress enacted the CARES Act which, amongst other things, specifically allowed Chapter 13 . . .
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