A claim must be disallowed on the validity of the debt before the associated lien can be voided under Section 506(d), the Ninth Circuit BAP holds.
The addition of Section 362(b)(3) is held not to affect the ‘freeze rule’ with regard to lapsing security interests.
Judge Barnes won’t allow a chapter 13 debtor’s counsel to be paid at the expense of secured creditors.
Bankruptcy judge says a chapter 13 debtor receives ‘several benefits’ from paying 8% in commissions on mortgage payments through the trustee.