A claim must be disallowed based on the invalidity of the debt before the associated lien can be voided under Section 506(d), the Ninth Circuit ruled in upholding the BAP.

First Circuit Issues a Landmark Opinion on Valuation of Disputed Claims

The value of a disputed claim is proven by showing the likely validity of the claim and the likelihood of recovery, not just by establishing the possible damages.

In the Minority, 8th Circuit BAP Disregards Equitable Considerations in Allowing Default Interest

As long as the rate is legal under state law, considerations of equity will not allow a court to disallow default interest to an oversecured creditor under Section 506(b).