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Direct Mortgage Payments Are ‘Under the Plan,’ Ninth Circuit BAP Says

BAP joins the majority of courts by saying that defaulting on direct mortgage payments precludes a chapter 13 debtor from receiving a discharge.
Court: 

Refunds by Creditors After Chapter 13 Discharge Go to Creditors, Not the Debtor

The logic of Harris v. Viegelahn doesn’t mean that chapter 13 debtors receive distributions refunded by creditors.

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