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§ 1322(c)

In re Smith

Ruling
Plan could modify interest rate on note that was immediately due and payable.
Issue(s)
Could debtor's plan modify interest rate on loan that had reached maturity and was due and payable in full?

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Consumer opinion summary, case decided on August 23, 2013 , LexisNexis #0913-101

Fannie Mae v. Griffin (In re Griffin)

Ruling
Debtor could pay off deceased mother's reverse mortgage in installments through plan.
Procedural posture

Debtor filed a petition under chapter 13 and proposed a plan for paying his creditors that paid a $62,602 debt owed to a mortgagee over forty-seven months. The mortgagee filed an objection to confirmation of the debtor's plan and moved for relief from the automatic stay. The court held a hearing on the mortgagee's objection.

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Consumer opinion summary, case decided on March 15, 2013 , LexisNexis #0413-099

In re Keita

Ruling
Plan providing for payment of note that matured prior to petition date could be confirmed.
Procedural posture

Chapter 13 debtor sought confirmation of his plan, A creditor filed a motion to dismiss the case and, along with other creditors, filed objections to confirmation.

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Consumer opinion summary, case decided on December 12, 2012 , LexisNexis #0113-033

Geller v. Grijalva (In re Grijalva)

Ruling
Debtor could bifurcate under-secured short term mortgage and cram down unsecured portion.
Procedural posture

Respondent debtor proposed to modify the first-position lien on her principal residence in her amended chapter 13 plan. Movants were trustees of family trusts.

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Consumer opinion summary, case decided on April 02, 2012 , LexisNexis #0412-134

In re Smoak

Ruling
Loan servicer had standing to pursue proof of claim as agent for bank.
Procedural posture

Debtors filed an objection to a proof of claim of filed by a loan servicer as agent for creditor bank. At issue was the effect of a pooling and servicing agreement of some 8,226 sub- prime loans upon the standing of the bank, which was in physical possession of debtor's note.

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Consumer opinion summary, case decided on September 28, 2011 , LexisNexis #1111-098

In re Holmdahl

Ruling
Proceeds of foreclosure sale ordered to be applied to arrearages.
Procedural posture

The chapter 13 debtors sought to cure their pre-petition defaults pursuant to 11 U.S.C.S. § 1322(c)(1). A bank objected to the debtors' proposal to apply forfeited funds from a failed foreclosure sale to their mortgage arrearages.

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Consumer opinion summary, case decided on November 03, 2010 , LexisNexis #1210-098

In re Boudreaux

Ruling
Relief from stay denied where plan would pay mortgage arrearage and bring loan current at completion.
Procedural posture

As of the date that a debtor filed her petition for relief under chapter 13, her home loan was fully accelerated because she failed to maintain the required insurance on the property. The creditor, who held a reverse mortgage executed by the debtor, filed a motion to lift the stay, and the debtor opposed the motion.

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Consumer opinion summary, case decided on February 24, 2010 , LexisNexis #0610-059

In re Jenkins

Ruling
Debtor's plan could cure mortgage default where foreclosure sale was complete but deed had not been delivered or recorded.
Procedural posture

A bankruptcy debtor proposed a plan which provided for cure of the debtor's mortgage arrearage under 11 U.S.C.S. § 1322(c)(1) since a foreclosure sale of the debtor's residence was not finalized prior to the debtor's bankruptcy. The debtor's mortgage creditor objected to confirmation of the debtor's plan on the ground that Ark. Code Ann. § 18-50-101(8) (2003) deemed the property sold when the highest bid was accepted which was pre-bankruptcy.

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Consumer opinion summary, case decided on January 12, 2010 , LexisNexis #0210-027

In re Carter

Ruling
Debtor could pay mortgage that matured prepetition, on house inherited from mother, over course of plan.
Procedural posture

Debtor filed a petition under chapter 13 of the Bankruptcy Code and a plan for repaying his creditors. A bank filed an objection to the debtor's plan because it proposed to pay a mortgage on a house he inherited from his mother under his plan, and also filed a motion for relief from the automatic stay.

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Consumer opinion summary, case decided on December 28, 2009 , LexisNexis #0210-126

In re Medaglia

Ruling
Relief from stay granted to allow recordation of deed from prepetition foreclosure sale that cut off debtor's right to cure.
Procedural posture

Buyer purchased the debtor's property at a prepetition foreclosure auction. A memorandum of sale was executed on the same day of the auction, and the buyer paid the required deposit. Before the buyer recorded his deed, the debtor filed a chapter 13 case. The buyer moved for relief from the automatic stay in order to record a deed and to take possession of the property.

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Consumer opinion summary, case decided on April 01, 2009 , LexisNexis #0609-066