The Ninth Circuit split with the Sixth Circuit in the interpretation of the ‘hanging paragraph’ in Section 541(b)(7). Courts are divided four ways on whether or how much a ‘13’ debtor may contribute to voluntary retirement plans after filing.
Jan 2025
Despite Section 1325(a)(5)(B), an auto lender was entitled to retain a lien when there were co-debtors.
The expiration of Section 1329(d) in March 2022 means that 84-month chapter 13 plans amended now must revert to 60-month plans.