Till v. SCS Credit Corp.

To qualify for court approval under Chapter 13 of the Bankruptcy Code, an individual debtor’s proposed debt adjustment plan must accommodate each allowed, secured creditor in one of three ways: (1) by obtaining the creditor’s acceptance of the plan; (2) by surrendering the property securing the claim; or (3) by providing the creditor both a lien securing the claim and a promise of future property distributions (such as deferred cash payments) whose total “value, as of the effective date of the plan, ... is not less than the allowed amount of such claim.”1 The third alternative is *469commonly…