Plan Confirmation

Till Doesn’t Require Starting with the Prime Rate, Eighth Circuit Says

The Treasury rate and prime rate are both proper starting points for pegging post-petition interest rates, but starting with Treasurys requires a larger risk premium.
Court: 

Circuits Are Now Split on Who Gets Appreciation in a Home When a ‘13’ Converts to ‘7’

Splitting with the Tenth Circuit, the Ninth Circuit holds that chapter 13 debtors lose post-petition appreciation in a home if the case converts to chapter 7.
Court: 

Recoveries on Postpetition Tort Recoveries Do (Do Not) Belong to Creditors in ‘13’

Rather than invoking the best interests and disposable income tests for plan confirmation, the Eleventh Circuit may have departed from the statute by ruling that the ‘ability to pay’ gives postpetition tort claims to creditors in chapter 13.

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