In re Moberg

Bank that did not file a timely proof of claim lacked standing to object to confirmation based on sale of collateral.
Procedural posture: 
A creditor bank, the holder of one unsecured note and a note secured by personal property, objected to confirmation of the debtors chapter 13 Plan. While the bank had not filed a proof of claim, and the time to file a claim had passed and would have been disallowed, the bank asserted that because it held the notes, it was a party in interest with standing to object to confirmation under 11 U.S.C.S. § 1324(a).
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Consumer case opionion summary, case decided on August 25,2011, LexisNexis #0911-100