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§ 1322(e)

Robinson, In re

Ruling
Bankruptcy court allowed debtors to cure default on real estate installment contract throughChapter 13 plan, overruling creditor's objections. (Bankr. C.D. Ill.)
Issue(s)
Contents of Plan; Determination of Amount Necessary to Cure Default.

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Consumer opinion summary, case decided on June 27, 2024 , LexisNexis #0924-022

Allegretti, In re

Ruling
Court overruled debtors' objection as bank showed that its fees and costs were in factcommercially reasonable. (Bankr. N.D. Ill.)
Issue(s)
Contents of Plan; Determination of Amount Necessary to Cure Default.

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Consumer opinion summary, case decided on April 24, 2018 , LexisNexis #0718-024

In re Dennis

Ruling
Objection to acceleration fees included in proof of claim overruled.
Procedural posture

Debtor objected to proofs of claim (POCs) filed by claimant, a creditor that was the assignee of debtor's deed of trust and of the two promissory notes which were secured thereby. Though debtor did not contest the principal amounts reflected by the POCs, she objected to acceleration fees that had been charged on each of the two notes on the ground that 11 U.S.C.S. § 1322 provided for the elimination of such fees.

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Consumer opinion summary, case decided on February 15, 2013 , LexisNexis #0313-065

In re Alvarez

Ruling
Mortgage creditor not entitled to claim for attorneys' fees incurred in filing foreclosure action.
Procedural posture

Debtor filed a petition under Chapter 13 of the Bankruptcy Code, and a mortgagee filed claim against the debtor's bankruptcy estate, seeking payment of attorney fees it incurred to file a foreclosure action against real property the debtor owned. The debtor filed an objection to the mortgagee's claim and the mortgagee filed an objection to a plan the debtor proposed for repaying her creditors.

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Consumer opinion summary, case decided on September 06, 2011 , LexisNexis #1011-027

Deutsche Bank Natl Trust Co. v. Tucker

Ruling
Creditor may add interest, fees and costs recoverable outside bankruptcy to cure amount regardless of whether fully secured.
Procedural posture

The District Court for the Eastern District of Kentucky certified a question to resolve whether the proper arrearage amount to appellant creditor included fees and costs permitted by the contract terms and applicable nonbankruptcy law even though the creditor was undersecured.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on September 15, 2010 , LexisNexis #1010-026

In re Thompson

Ruling
Objection to inclusion of costs of title insurance premium incurred in the pre-petition state foreclosure action overruled.
Procedural posture

The debtors, whose real property was subject to a foreclosure action initiated by movant lender, objected to a charge for the costs of a title insurance premium incurred in the pre- petition state foreclosure action as part of the creditor's allowed claim in the chapter 13 bankruptcy case, pursuant to 11 U.S.C.S. § 1322(e).

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Consumer opinion summary, case decided on December 15, 2009 , LexisNexis #0110-027

In re Adejobi

Ruling
Creditor entitled to contract default rate of interest pursuant to underlying agreement.
Procedural posture

A chapter 13 debtor filed a motion to reduce a secured creditor's proof of claim for pre-petition arrears at a contractual default interest rate.

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Consumer opinion summary, case decided on April 29, 2009 , LexisNexis #0709-060

In re Harris

Ruling
Creditor not entitled to payment of interest on interest where not provided for in underlying agreement.
Procedural posture

The debtor moved for confirmation of his uniform chapter 13 plan and for valuation of collateral. The mortgage creditor objected to the plan. At issue was whether the agreement between the debtor and that creditor provided for interest to be earned on arrearage of unpaid interest on the loan.

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Consumer opinion summary, case decided on November 16, 2007 , LexisNexis #1207-087

Case v. Wells Fargo Bank (In re Case)

Ruling
Reconsideration was proper procedure for debtors to contest "interest on interest" chapter 13 plan payments.
Procedural posture

In a consolidated action, plaintiffs, chapter 13 debtor-mortgagors, asserted that their respective defendant creditors were paid "interest on interest" through their respective chapter 13 plans in violation of 11 U.S.C. § 1322(e). All adversary complaints were met with motions to dismiss filed by all creditors.

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opinion summary, case decided on October 31, 2006 , LexisNexis #1206-139

In re Evans

Ruling
Court sustained debtors' objection to some of a creditor mortgagee's proof of claim for attorneys'fees and costs since the creditor could not make a secured arrearage claim under section 1322(e) if the fees and costs did not first qualify as part of a secured claim under section 506(b).
Procedural posture

In a chapter 13 bankruptcy case, debtors objected to a proof of claim filed by creditor, a mortgagee. More specifically, they objected to the extent of creditor's claim. The court conducted a hearing on the objection.

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opinion summary, case decided on January 20, 2006 , LexisNexis #0206-048